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,} t rroject Memo Date. Friday,January 24,2003 To: Mr.Ray von Flue,E.H.S. From: John Lynch,Wright Environmenal Services, Inc. RE: Kaiser Permanente,7373 West Lane,Stockton CA In Place Closure and Replacement of Fuel Lines BACKGROUND Secondary Containment Piping Testing of the of the four existing fiberglass secondary containment piping runs resulted in three failing, and, one passing a 5-psi test. Two existing black iron metallic supply and two return lines between the tank piping sump and the transition fittings where the supply and return lines transition to above grade piping in the boiler and generators rooms were tested. These lines were understood to be safe suction base on field observations and information provider by the clientloperator. Additional tests were initiated to attempt to isolate the leaks in containment piping. These tests did not isolate the leaks within the secondary containment piping. No leaks were observed in the primary supply and return lines and no diesel fuel was observed within the containment piping or piping sump. Upon further inspection of the system and after consulting with engineers at the facility and PHS-EHD representatives it was determined that the supply lines have check valves within the tank as well as at the suction pumps. Therefore,the piping is not safe suction and secondary containment is required for the supply lines. The operator has contracted with Wright Environmental Services, Inc. (Wright)to replace the existing supply and return lines and to install appropriate secondary containment on those lines in conformance to the regulations. Replace Supply and Retum Piping Operator desires to have supply and return secondary containment that complies with AB-2481 and Title 23 CCR. Wright will install new supply and return lines with new secondary containment from the existing tank piping sump. These new lines will roughly parallel existing supply and return line underground to the building. The new piping proposed is UL Certified,Total Containment Piping. Cut- sheets for the new piping and component parts are provided for your review. At the building, the new Total Containment lines will transition above grade where they will also transition to black iron metallic pipe with predominantly welded steel fittings and valves.Where the steel piping enters the building, it will be routed to and attached to the existing aboveground black iron piping serving the boilers, and backup generator as backup fuel supply system. The proposed route for the new underground Total Containment piping that roughly parallels the existing piping is shown on Drawing 1-1. Wright will schedule inspections with your office in advance as required. 1