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JAN 2 6 2015 ENVIRONMENTAL.. HEAM4 r1Cor6DT�ACKIT standard,and as indicated on the nameplate,tanks are factory tested at five(5)psi prior to shipment and do not exhibit permanent wall displacement from factory testing. It is unclear why or how the tank walls became permanently displaced,however, inspection of the interstitial space suggests that the primary tank's integrity has not been compromised. Discussion of these conditions with Dave Dooley,a technical support representative for Containment Solutions Inc.,resulted in him stating that, in his opinion,a pressurized integrity test of the tank was unnecessary,so long as inspection of the interstitial space did not indicate a breach of the primary tank. The tank is seismically braced with six brackets,two on each long side and one on each short side,to reduce the likelihood of lateral movement of the tank during an earthquake. The braces are secured to the floor using 1/2 inch diameter anchor bolts, and are positioned against the tank,but are not fastened directly to the tank.The tank is located in a narrow room such that the tank is unlikely to overturn. 3.10 Tightness Testing [CCR§66265.192(k)(10)] Discussion with Dave Dooley,technical support representative for Containment Solutions, Inc.,indicated that Containment Solutions does not have a formal manufacturer's procedure for integrity testing in-service tanks.Mr. Dooley stated that they generally recommend following SPCC testing requirements which often rely on industry inspection standards such as Steel Tank Institute's(STI)SP001 Standard for Inspection of Aboveground Steel Tanks. SP001 inspection requirement for tanks of the size and configuration described in this document is periodic visual inspection. On 6 January 2015 the tank was inspected for tightness by visually inspecting the interstitial space between the primary and secondary tank walls for signs of leakage.No visible indication of product was present during the inspection.There was,however, oily residue and accumulation on the top and sides of the tank and several layers of absorbent mats placed around and under the tank which appeared to have soaked up some quantity of oil.There was no indication of an apparent source.The tank and pipe attachments(inlet,outlet,vent)should be cleaned, absorbent mats removed,and the tank and connections monitored for change per the daily inspection log. The piping system was also inspected for tightness on 6 January 2015 by visually inspecting the inlet piping and fittings during transfer of oil into the tank. Outlet and vent pipes were also visually inspected,though not during use.No apparent leaks were identified during the inspection,however, it was noted that many of the fittings and pipes had oily residue and drips on them suggesting a historical issue or slow leak.The pipes should be cleaned and monitored for change per the daily inspection log. 3.11 Remaining Service Life [CCR§66265.192(k)(11)] The tank is anticipated to be serviceable until recertification is required in 5 years.This certification is good for up to 5 years from the date on the coversheet. Ha=ardour Waste Tank System Assessment and Certification Page 8 of 11 NES,Inc. Broadbase,Inc. NESJob#276.EC1957.00 Lodi,California