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TANK TESTING <br /> American Environmental Management Corporation (AEMC) inspected the three tanks in <br /> September 1986 to determine the feasibility of conducting precision leak testing. Based <br /> upon this inspection, AEMC has determined that the three No. 6 fuel oil tanks cannot be <br /> precision tested in accordance with State regulations (Section 2643, Title 23, California <br /> Administrative Code), for the following reasons: <br /> 1. All three tanks consist of buried concrete vault-like structures which lack <br /> standard fill pipes. Access to the tanks is limited to openings ranging in size <br /> from a two foot diameter concrete-formed manway (for the two 90 barrel <br /> tanks) to a five foot by five foot square access (for the 5,500 barrel tank). The <br /> tank accesses cannot be properly sealed to allow for use of an above ground <br /> standpipe which is needed to perform a full static head pressure test. <br /> 2. The 5,500 barrel tank is a cylindrical concrete-lined sump covered by a wood <br /> and tarp roof structure. The primary function being to keep rain from <br /> entering the tank, the tarp roof structure is not designed to hold product. It is <br /> in this above-ground roof structure that the five by five foot access is located. <br /> Low level testing of the smaller tanks (tank only testing) may be possible. However, due to <br /> the large product surface area by virtue of the two foot opening, accuracy may not be <br /> adequate. During a normal low level test, the product level in the tank is located about <br /> one inch into the tank's fill pipe and has a surface area ranging from about three to twelve <br /> square inches. This small surface area is necessary to obtain an accurate calibration of the <br /> observed leak rate during a low level test. Since the tanks lack standard fill pipes, the <br /> product surface area would be controlled by the area of the access openings. In the case of <br /> the smaller tanks, these large surface areas may not allow for an accurate calibration and <br /> could result in an accuracy that may not comply with the 0.05 gallon per hour or less <br /> criteria set by Title 23 for precision tank test accuracy. <br /> ��c=� Page 2 <br />