COMPLIANCE INFO_FILE 6 - Laserfiche WebLink

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Attachment A (Continued) Comment #1. For each of the months July 1992 through November 1992, monthly inventory calculations showed that allowable variations were exceeded for tank systems 879-G1U1 and 879-G2U1. A telephone report was made to Bill Snavely of your office each month. Initially we were not able to explain these variations, although the data failed to show a consistent loss that would indicate a leak. In December 1992, an audit of procedures showed that data was being incorrectly recorded on the "Daily Inventory Reconciliation Log" form. Specifically, "Calculated Inventory" from column four was entered daily into the following day's column one, "Opening Dipstick Reading". To be correct, "Closing Dipstick Reading" (not "Calculated Inventory") from column five should have been entered in column one for the following day. When the July 1992 through November 1992 forms were redone and recalculated, the monthly variations were shown to be within allowable limits. Comment #2. The April 1993, monthly variation for tank 879-G2U1 was initially calculated as 233 gallons compared to an allowable variation of 184 gallons. The operators understood that the allowable variation was exceeded because of erroneous data recorded on April 22. On that date the tank was overfilled for tank integrity testing. The sticking data recorded for that day represented an attempt to estimate volume when the liquid level was above the graduations on the dip stick. When the monthly variation is calculated without the April 22 variation, the monthly variation is 2 gallons. No report was made (Section 2646(1)). Comment #3. The June 1993 monthly variation for tank 879-G2U1 was 222 gallons. The allowable variation for this tank system was 169 gallons, 53 gallons less than the actual variation. At the time of our telephone report to Bill Snavely, we did not know the cause of the June variation. An evaluation of inventory reconciliation procedures was completed to determine why the allowable variation was exceeded. Review of daily inventory reconciliation data showed a significant variation on June 11. On that date, both of the Building 879 facility people experienced with tank gauging (sticking) were away from the facility, and an inexperienced third person performed sticking. It appears that the technique used to perform sticking on this day resulted in an imprecise measurement causing a large daily variation that, in turn, resulted in a monthly variation that exceeded the variation allowed by the tank regulations. (Since June, actual monthly variations for 879-G2U1 have been less than allowable variations.) TAGG 93-183