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Recommendations Letter In-Service AST Inspection Report Tank 2 CDCR—NCYCC Page 2 • A pump for product dispensing was installed on the top of the Tank. Evidence of a leak from the pump or nearby piping was observed. The leak did not appear to be active during the inspection. Site personnel reported that a tank contractor had previously been working on the pump and repairs were not complete. • Several instances of shell coating(paint) failure with surface corrosion were observed Shell Testing/Observations The Tank is double walled and thickness measurements of the primary (inner) tank are not required. Measurements of the secondary(outer)tank shells is not required unless liquid is identified in the interstitial area or external corrosion is observed. Visual observations of the Tank were made for the purpose of identifying corrosion, dents,buckling or other damage. Coating of the Tank exterior surfaces appeared to be in fair condition. Tank coating(paint) failure and external corrosion was observed predominantly along to the topside and west end of the Tank. Areas of coating failure and surface corrosion were observed on the piping.Thickness measurements were collected in several areas of external corrosion(see Figure 1)and from unaffected areas for comparison. Steel thickness measurements from several areas of coating failure were similar to the steel thickness measurements of areas where coating was intact. Coating failure in the areas measured, did not appear to have impacted the integrity of the Tank. Signs of modifications to the Tank(after initially manufactured)that would have required welding on the Tank's shell were not evident. Requirements for Continued Use Based on current industry practices and regulatory requirements, Condor recommends the following: • Replace the expired 2-inch operational vent with a 4-inch pressure and vacuum vent. See the Section 1.9.2 of the Tank Inspection Report on venting and report recommendations for more detail. • Remove surface corrosion and paint the Tank and connected piping as necessary. • Calibrate the liquid level gauge to read within one inch or less of the manual measurements. • Investigate possible leaking dispensing components on top of the Tank and repair as necessary. Clean product stains from the exterior of the Tank. • Continue to document monthly and annual inspections in accordance with the Facility SPCC Plan. Inspector Recommendations for Continued Use • Test and adjust (as necessary) the overfill prevention shutoff valve annually in accordance with manufacturer procedures. • Periodically check for water inside the primary compartment and interstitial area consistent with the monthly and annual inspections. • Provide training for personnel performing the monthly and annual inspections to include identification of the applicable Tank equipment and proper completion of the forms. • Properly label the Tank consistent with local Fire Code which may include NFPA diamonds, description of contents, and warnings. *s s■ot CONDOR