COMPLIANCE INFO_JULY 2012-OCTOBER 2013

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Daze: Rev.December 17,2007 Praxair Services,Inc.QA Daze: December 17,2007 Praxair Services,Inc.QA Revised by: Randy Golding Tracer Tight* Revised by: Randy Golding Tracer Tight® Approved by:Randy Golding Version 6 Approved by:Randy Golding Version 6 Description Work Plan The process is described in the following steps: SPreparation Site Owner Probe Array Installation Name Tracy BP Services ABC Petroleum Confirmation Test Address 7475 Tracy Blvd 6951 S.Front RD. Inoculation •Leak Simulation City and State Tracy,CA T ivermore,CA Sample Collection Analysis Spill Bucket Test Reporting In Service Enhanced Leak Detection Protocol (IS-ELD) (The IS-ELD Method Utilizes an Onsite Site Laboratory for Real-Time Results) Introduction Preparation In Service Enhanced Leak Detection(IS-ELD)means a test method which is approved by the Califorrria Water Resources All necessary permits must be acquired and appropriate notices to local regulators must be given prior to arrival at the site. Control Board that ascertains the physical integrity of an underground tank system by introduction,and extemal detection, Upon arrival,the crew reviews the tank information that has been made available and uses this information to plan the of a substance that is not a component of the fuel formulation that is stored in the tank system while the system is in installation of the sampling probe array.If"as built"plans or site plans have not been made available,the crew inspects service. The test method is third party certified for the capability of detecting both vapor and liquid phase releases from all accessible portions of the system to learn as much as possible about the location of all UST system components.If the the underground storage tank system. The Enhanced Leak Detection test method is capable of detecting a leak rate of at site is under remediation,soil vapor extraction systems,air-sparging systems and bio-venting systems must be turned off least 0.005 gph or less,with a probability of detection of at least 95%and a probability of false alarm no greater than 5%. during the test.Groundwater measurements are to be taken within the tank excavation zone. Concept Probe Array Installation Tracer Tight®is a unique method of testing underground storage systems for tightness. A unique chemical called a tracer The following ELD probe installation was approved by the Water Resources Control Board. Vertical PVC sampling is added to the product stored in the tank. The tracer is an inert chemical that evaporates readily from the fuel. After probes are installed within eight horizontal feet of all possible leak locations(a maximum of 15 feet apart).In situations tracer is added to the system,it is distributed between the vapor and liquid inside the tank. Use of the system carries the where tank pits and piping trenches do not contain engineered backfill(sand or pea-gravel),the sampling probes are tracer throughout the piping. If any small leak exists in the system,the tracer is allowed to escape from the system,either installed with a maximum 10-foot spacing.Tank probes are installed along the side of each tank,generally at a depth as a vapor or as a dissolved component of the liquid. Once outside the system,the dissolved tracer evaporates from the centered on the tanks.Maximum probe depth is 15 feet(or just above the water table if applicable).Additional probes are liquid and the tracer vapors begin to migrate away from the location of the leak in all directions. After an appropriate installed near any appurtenances along the tank ridge where a containment sump is not present.Piping probes are placed wailing period,the tracer vapors are detectable at least ten feet or more away from the leak in all directions. Samples of along the product distribution,vapor recovery and vent piping trenches,to one half the depth of the piping or until the end air collected from the soil within the radius of detection of the tracer reveal the leak as a presence of the tracer chemical. of the probe is within engineered backfill.Probes are generally installed at a depth of I to 1.5 feet below grade.Probes are Because the tracer chemical is not normally found in the environment or in fuel products,the Tracer Tights method is able installed by coring a hole in the pavement and inserting a sampling probe into the excavation zone of the tank or pipe.The to discriminate between previous contamination and current leakage. top of each probe is fitted with a PVC sampling cap that will allow access for the collection of samples. Contractor Confirmation Test It is important that before Praxair arrives on site that the tanks receive enough fuel to avoid deliveries until the Confirmation Test(Pre-certification tightness test)is completed before the system is inoculated. The test is used to testis completed. If a fuel drop becomes necessary in order to keep the station open then contact Praxair's site confirm the tightness of all the accessible fittings. This is done to ensure that the facility is tight before adding the tracer. project manager and schedule the drop while the crew is onsite. A clean fuel drop reduces the possibility of having A repair technician should be on site with all tools and parts to complete repairs to any and all components that are to retest the site. accessible. The technician should be qualified/certified to program and operate the electronics controlling the fueling system. A contractor capable of repairing any exposed component in the system including having spare parts must be onsite to expedite repairs. The contractor skills must include the ability to operate and make adjustments to the Inoculation settings of the electronics controlling the fueling system. The contractor must be capable and committed to Inoculation is the process of adding chemical tracer to the product in the system to be tested. Product is inoculated with a working longer hours and extended days outside of normal work week. The owner's contractor will be incomplete predetermined amount of tracer,though the fill riser. Tracer is mixed with the product by using the system. Once control of the fueling system and it is the contractor's responsibility to operate the fueling system properly and to sufficient amount of tracer labeled product has been moved through each dispenser,the product is tested at each dispenser reassemble the system back into a pretest configuration. Praxair Service,Inc.is only responsible for testing the to confirm that tracer is present. By keeping the dispenser nozzle inside a receiving container,additional product is fueling system and is not responsible for its operation. pumped into the container to push tracer labeled vapors through the vapor return piping back to the tank. The tracer/vapor mixture is then pushed from the UST out to the vent riser into a container of sufficient size that the tracer/vapor mixture THISINFORVI1TIONIS THE PROPERTY OF PRAIAIR SERVICES INC. THISINFORMATIONIS THEPROPERTY OFPRATAIR SERVICES INC.. I of 3 2 of 3