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R&D COMD iance Testin Secondary Containment/SB989 (707) 621-0378 Line/Leak Detectors Tank Monitor Certification California UST Certified Operator #5246802 -UC California UST Service Technician #5246802 -UT SWRCB Tank Testing License #90-1120 Date: October 3, 2016 To: Svetlana Ahl Associate Hazardous Materials Specialist CDCR Deuel Vocational Institution 23500 Kasson Road Tracy, Ca. 95376 Svetlana, after visual inspection of the Water Treatment Plant AST and associated piping both above ground and underground, I have determined that the secondary portion of the underground piping was not installed to be isolated for testing purposes. The AST is a 2,000 Gallon Con Vault. The primary pipe is 1 1/2" steel. The length of the primary pipe that supplies and returns fuel to the emergency generator from the AST to the Day Tank is approximately 40' for the supply and 40 ` for the return. Based on Industry Standard Piping Charts, the volume of this pipe is .105 gallons per foot and would equal 8.4 gallons. The length of the primary pipe that supplies and returns fuel to the filter loop from AST to Generator is approximately 25' for supply and 25' for return. Based on Industry Standard Piping Charts, the volume of this pipe is .105 gallons per foot and would equal 5.25 gallons. I have determined that the associated primary piping, both supply and return represent less than 10% of the volume of the AST and is exempt from secondary containment requirements and testing. I also found two 1/2" inline check valves plumbed into the primary supply lines at the generator. This would indicate that the supply piping has been installed as a Safe Suction Piping System making it exempt from Secondary Containment requirements and Precision Primary Piping testing requirements. The 4" Fiberglass Piping that the primary supply and return piping is sleeved in, is not testable as secondary containment piping in its current configuration. A concrete vault located just outside of the AST Containment Vault, allows access to the primary pipe with standard unions for disconnect if needed. A sensor is located in this concrete vault and is connected to the monitoring panel located at the generator. The sensor has been determined by others to not be functioning at this time. The Local CUPA is requesting a Precision Integrity Test of the Primary Piping due to a past incident that required repairs to the AST System. Due to the configuration of the Safe Suction Supply and Return Piping, I recommend a Full System Precision Integrity Test that will test the AST and all connected piping. Sincerely, Benjamin F. Duncan Jr. R&D Compliance Testing P.O. Box, 1503, Ukiah, Ca. 95482