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HomeMy WebLinkAboutTANK INTEGRITY 2017 SERVICE SHOP USED OIL / ANTI-FREEZE TANKS SYSTEM INTEGRITY REPORT FOR CARMAX FACILITY BAKERSFIELD, CA APRIL 5, 2017 Prepared by: HMT Inspection A Division of HMT LLC 250 W. Channel Rd., Suite H Benicia, CA 94510-1159 707.747.0444 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM INTRODUCTION HMT Inspection, a division of HMT LLC, was subcontracted by Tait Environmental, to provide on-site inspection services at the CarMax Facility in Bakersfield, California for evaluating compliance for used oil tanks identified as: Used Oil Tank and associated piping outside the Service Shop. Used Anti-Freeze Tank and associated piping outside the Service Shop. This report documents the findings of the examinations and assessment performed on April 5, 2017 regarding these tanks / system. It should be noted that the term “tank” is used herein as defined in the California Code of Regulations for aboveground storage tanks (ASTs). HMT Inspection provided the following personnel: Nelson Acosta API 653 Certified Tank Inspector Certification Number: 0272 California Registered Professional Engineer No. C57820 (Civil) STI Certification Number: AC 14408 David Udosen API 653 Certified Tank Inspector Certification Number: 36010 STI Certified Tank Inspector Certification Number: AC 12181 Level II Technician 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM TABLE OF CONTENTS 1.0 DESCRIPTION ....................................................................................................................... 5 2.0 SIGNIFICANT FINDINGS ...................................................................................................... 7 3.0 EVALUATION FOR CCR COMPLIANCE – USED / WASTE OIL STORAGE TANK ............ 11 3.1 CONTAINMENT AREA ASSESSMENT AND EVALUATION .................................. 15 3.2 PIPING AREA ASSESSMENT AND EVALUATION ................................................. 16 4.0 DRAWINGS ........................................................................................................................... 18 4.1 USED OIL TANK LAYOUT ....................................................................................... 18 4.2 ANTI-FREEZE TANK LAYOUT ................................................................................ 19 5.0 NDE INSPECTION ................................................................................................................. 20 5.1 NDE INSPECTION SCOPE ...................................................................................... 20 6.0 EQUIPMENT .......................................................................................................................... 21 6.1 ULTRASONIC ........................................................................................................... 21 7.0 TABLES ................................................................................................................................. 22 TABLE A SHELL READINGS ......................................................................................... 22 TABLE C SHELL READINGS ......................................................................................... 24 8.0 WARRANTY ........................................................................................................................... 26 9.0 PHOTOGRAPHS ................................................................................................................... 27 10.0 CERTIFICATIONS ............................................................................................................... 48 Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA HMT Inspection April 5, 2017 Page 5 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM 1.0 DESCRIPTION GENERAL: TANK IDENTIFICATION: Used Oil Tank (10GA) OWNER: CarMax DESIGN STANDARD: UL 142 TANK LOCATION: Bakersfield, CA MANUFACTURER: Highland Tank TANK CONSTRUCTION: Double-Wall Tank (Carbon Steel) TANK THICKNESS: 0.187 inch (nominal) CONNECTING PIPING: Carbon Steel PRODUCT: Used Oil TANK EMPTY AT INSPECTION: No HYDROSTATIC TEST: No Data Available DATA PLATE PRESENT: Yes (Name Tag only) DIMENSIONS: HEIGHT: 5.00 ft. (Containment Tank) LENGTH: 10.92 ft. (Containment Tank) WIDTH: 2.71 ft. (Containment Tank) CAPACITY GROSS: 1,000 gals. GEOMETRY: FOUNDATION: Steel Channel Supports (3) on Concrete Base SHELL: Single Plate (Fillet Welded at Edges) TOP OF TANK: Single Plate (Fillet Welded at Edges) DATES: YEAR BUILT: No Data Available (Installed = 2012) LAST COATED: No Data Available LAST INSPECTION: No Data Available ACCESS: STAIRWAY: N/A COATINGS: SHELL: External - Blue Paint Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA HMT Inspection April 5, 2017 Page 6 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM DESCRIPTION (CONT’D.) GENERAL: TANK IDENTIFICATION: Used Anti-Freeze Tank (12GA) OWNER: CarMax DESIGN STANDARD: UL 142 TANK LOCATION: Bakersfield, CA MANUFACTURER: Highland Tank TANK CONSTRUCTION: Double-Wall Tank (Carbon Steel) TANK THICKNESS: 0.187 inch (nominal) CONNECTING PIPING: Carbon Steel PRODUCT: Used Anti-Freeze TANK EMPTY AT INSPECTION: No HYDROSTATIC TEST: No Data Available DATA PLATE PRESENT: Yes DIMENSIONS: HEIGHT: 2.92 ft. (Containment Tank) LENGTH: 5.20 ft. (Containment Tank) WIDTH: 2.17 ft. (Containment Tank) CAPACITY GROSS: 280 gals. GEOMETRY: FOUNDATION: Steel Channel Supports (2) on Concrete Base SHELL: Single Plate (Fillet Welded at Edges) TOP OF TANK: Single Plate (Fillet Welded at Edges) DATES: YEAR BUILT: No Data Available (Installed = 2012) LAST COATED: No Data Available LAST INSPECTION: No Data Available ACCESS: STAIRWAY: N/A COATINGS: SHELL: External - Blue Paint Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA HMT Inspection April 5, 2017 Page 7 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM 2.0 SIGNIFICANT FINDINGS The following is a summary of the significant findings of the inspection. History: This is the first inspection performed at the CarMax facility located in Bakersfield, CA on the Used Oil and Anti-Freeze Tanks by HMT Inspection. The Used Oil and Anti-Freeze Tanks are carbon steel tanks constructed to UL 142 design standard by Highland Tank. The tanks were installed new and have been in service at this location since the facility was built and started operation in March 2012 (per client). Tank as identified below: Configuration and nominal capacity for the Aboveground Storage Tanks (ASTs): Used Oil Tank: 1,000 Gallons Used Anti-Freeze Tank: 280 Gallons Inspection of the Aboveground Outside Bulk Storage Tanks revealed no areas of defects or anomalies that would require immediate corrective action at this time or that should be addressed for future maintenance during the next service cycle. Reference Section 3.0 for the identification, diagram and area layouts of the tanks, piping and containment details inspected. Aboveground Outside Bulk Storage Tank Facility FOUNDATION: The Used Oil and Used Anti-Freeze Tanks sit outside the service shop in a large concrete containment and are both individually supported on steel structural supports resting on the concrete base. Visual (VT) inspection of the steel supports found them in acceptable condition at this time. The supports are bolted to the concrete with random areas of minor coating failure and light rust present. These details should be monitored for signs of worsening conditions in the future. Visual (VT) inspection of the concrete containment and foundation found it in acceptable condition at this time. The concrete containment detail has construction joints with random areas of hairline cracks present. Consideration should be given to coating the concrete containment to minimize future deterioration. The concrete containment foundation measures 17.67 ft. long x 14 ft. wide x 13 inches high. There are three (3) tanks present inside this containment, two (2) 1,000 gallon tanks and one (1) 280 gallon tank. The containment is large enough to contain the volume of the largest tank inside the area in case the tank were to fail. The containment has a drain port present with valve. The valve is locked shut at this time. It should be noted that there is debris present inside the containment and collecting around the drain port. Consideration should be given to cleaning this area at this time. Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA HMT Inspection April 5, 2017 Page 8 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM SIGNIFICANT FINDINGS (CONT’D.) Aboveground Outside Bulk Storage Tank Facility (CONT’D.) USED OIL TANK: The Used Oil Storage Tank is a double-wall horizontal rectangular tank resting on three (3) steel structural supports that are bolted to the concrete floor outside the service shop. The tank has a capacity of 1,000 gallons (nominal). Used oil is manually transferred to the tank by service personnel using a collection pan and also transferred via approximately 420 feet of 1-inch carbon steel piping from the used oil collection drums (3 collection stations) inside the service shop to the nozzle inlet on top of the tank. Used oil is pumped out from a collection drum through1-inch connecting piping. The filter press machine also drains into the collection drum that is pumped out to the used oil tank. The piping runs along the shop walls from the three (3) collection stations and overhead on the rafters and down through the wall to the tank entry point. The carbon steel piping measures 0.132 inch to 0.134 inch wall thickness. This connecting piping is 1-inch Sch. 40 with nominal thickness of 0.133 inch. The used oil is collected and then subsequently trucked off-site for disposal or recycling. A monthly or bi-weekly pick-up and service log is available and accessible at the tank. The thickness readings on the primary tank shell measured from 0.176 inch to 0.182 inch (nominal thickness is 0.187 inch). The thickness readings on the secondary tank shell measured from 0.128 inch to 0.130 inch (nominal thickness is 0.125 inch). Visual (VT) inspection and Ultrasonic (UT) testing found the tank in serviceable condition. The shell coating is in acceptable condition at this time. USED ANTI-FREEZE TANK: The Used Anti-Freeze Storage Tank is a double-wall horizontal rectangular tank resting on two (2) steel structural supports that are bolted to the concrete floor outside the service shop. The tank has a capacity of 280 gallons (nominal). Used Anti-Freeze is manually transferred to the tank by service personnel using a collection pan. There is no transfer piping or hose connected to the tank. It should be noted that due to low frequency of use, the tank fill / pick-up interval for disposal or recycling is longer than for the Used Oil Tank. The used anti-freeze is collected and subsequently trucked off-site for disposal or recycling. A quarterly pick-up and service log is available and accessible at the tank. The thickness readings on the primary tank shell measured from 0.176 inch to 0.180 inch (nominal thickness is 0.187 inch). The thickness readings on the secondary tank shell measured from 0.119 inch to 0.122 inch (nominal thickness is 0.093 inch). Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA HMT Inspection April 5, 2017 Page 9 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM SIGNIFICANT FINDINGS (CONT’D.) Aboveground Outside Bulk Storage Tank Facility (CONT’D.) USED ANTI-FREEZE TANK (CONT’D.): Visual (VT) inspection and Ultrasonic (UT) testing found the tank in serviceable condition. The coating is weathered and beginning to fail with slight surface rust in random areas. Consideration should be given to maintaining the coating as necessary. It should be noted that personnel are present during tank product fill / withdrawal operations. Aboveground Outside Bulk Storage Tank Facility SECONDARY CONTAINMENT EVALUATION (Bulk Storage Tank Facility): USED OIL TANK: The Used Oil Tank is a double-wall horizontal rectangular tank. Since the tank is double-wall, the need for separate spill capacity around the tank does not apply. These details meet the requirements for secondary containment per EPA regulations for the maximum 72-hour clean-up period for spills. Since the Bulk Storage Tank rests inside its own Secondary Containment Structure, it is not subject to rainfall or other runoff accumulation per the EPA 25-year, 24-hour maximum rainfall / runoff accumulation requirement for the containment area. The Secondary Containment Structure is suitably large enough to contain the volume of the tank within (1,000 gallons in this case). USED ANTI-FREEZE TANK: The Used Anti-Freeze Tank is a horizontal rectangular double-wall tank. Since the tank is double-wall, the need for separate spill capacity around the tank does not apply. These details meet the requirements for secondary containment per EPA regulations for the maximum 72-hour clean-up period for spills. Since the Bulk Storage Tank rests inside its own Secondary Containment Structure, it is not subject to rainfall or other runoff accumulation per the EPA 25-year, 24-hour maximum rainfall / runoff accumulation requirement for the containment area. The Secondary Containment Structure is suitably large enough to contain the volume of the tank within (280 gallons in this case). INTERSTITIAL SPACE: The Used Oil / Anti-Freeze Tanks are each double-wall with an interstitial space for monitoring leaks. Also, there is adequate venting present for the secondary space. The primary tanks have atmospheric and emergency vents present. At this time the interstitial space could not be tested for the presence of hydrocarbon vapor with a gas monitor. It should be noted that each interstitial space has a detection device present to monitor for leaks. The leak detection device on the used Anti-Freeze tank is damaged and should be replaced at this time. Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA HMT Inspection April 5, 2017 Page 10 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM SIGNIFICANT FINDINGS (CONT’D.) TRANSFER PIPING EVALUATION: Used oil is pumped from the collection drum and oil filter press machine at three (3) locations inside the Service Shop and transferred via 460 feet of 1-inch carbon steel piping along the shop wall, overhead on the rafters and through the wall and to the tank (ref. photos). Ultrasonic (UT) testing of the piping in accessible areas measured the thickness from 0.132 inch to 0.134 inch. The carbon steel piping is 1-inch Sch. 40 piping with a nominal thickness of 0.133 inch. Visual (VT) inspection of the piping found no defects that would warrant further evaluation or require repair at this time. Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA HMT Inspection April 5, 2017 Page 11 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM 3.0 EVALUATION FOR CCR COMPLIANCE – USED OIL STORAGE TANK SUMMARY OF CA DTSC EVALUATION PER TITLE 22 CCR, Part 66265.191: Pursuant to Title 22, §66265.191 of the California Code of Regulations, the following highlights provide a summary evaluation of the major areas of concern regarding the aboveground Used Oil Storage Tank under those regulations: 1. The primary design basis utilized in the construction of these tanks is normal industry practice for horizontal aboveground storage tanks on structural supports. The ancillary equipment includes carbon steel piping and couplings. 2. The products in these aboveground storage tanks include used motor oils / anti- freeze that are temporarily stored prior to disposal off-site. 3. Corrosion protection measures directly applicable to the tanks and the ancillary connections involve coatings on the tanks (paint or material resistant to degradation). The walls of the tanks that are in contact with the stored liquid are all of carbon steel construction resistant to corrosion from oil. The ancillary connections are made of resistant material such as carbon steel to protect against corrosion. These materials continue to be resistant to the stored liquid based on current condition and age. 4. The aboveground storage tanks and ancillary connections have been on this site and in operation for approximately 5 years (per client). The tanks and connections show no evidence of deterioration at this time. If properly maintained now and into the future, the tanks and connections should have a remaining useful life of at least 20 years based on current condition and thickness measurements. The next inspection interval for the tanks and connections has been established at approximately 5 years based on the need to verify continuing integrity of the material in contact with the stored liquid. Refer to corrosion rate calculations in Tables B and D included herein. 5. Flow into the tanks comes through ancillary connections and is controlled manually using pumps and switches located inside the service shop and on the tanks or is processed manually. This equipment is monitored visually at the unit by the service technicians. This equipment is suitable for continued service until the next out-of-service or maintenance cycle. Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA HMT Inspection April 5, 2017 Page 12 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM EVALUATION FOR CCR COMPLIANCE – USED OIL STORAGE TANK (CONT’D.) SUMMARY OF CA DTSC EVALUATION PER TITLE 22 CCR, Part 66265.191: 6. Our close Visual (VT) external inspection of the aboveground storage tanks and of the ancillary connections (all equipment was in service) found no evidence of defects in the walls or structural components of the tanks, or other concerns such as metal loss from service conditions. The structural integrity is adequate until the next inspection without concern regarding the possibility of leaks of any hazardous liquids or failure of the components under service conditions. The tanks and ancillary connections situated outside the service shop are exposed to corrosion from the elements. The carbon steel Used Oil and Anti-Freeze Tanks and their ancillary connections are coated. The connecting piping situated inside the service shop is not exposed to corrosion from the elements. In addition to complying with empirical design rules for continued service of steel tanks, we have evaluated these storage structures and surrounding area in accordance with the specified requirements of California Dept. of Toxic Substances Control Regulations §66265.190 through §66265.200 (as applicable) and find the following to be true: Pursuant to 22 CCR §66265.191, these structures now contain and will continue to contain for the foreseeable future products that can be classified as non-RCRA hazardous wastes; Pursuant to 22 CCR §66265.191, these structures are of sufficient capacity as to not be exempt from this regulation; Pursuant to 22 CCR §66265.191, the tanks have been adequately designed to industry standards for aboveground welded steel storage tanks and have sufficient structural strength and product compatibility to store these non-RCRA hazardous wastes on a long-term basis without collapse, rupture or failure; Pursuant to 22 CCR §66265.191(k), the Used Oil / Anti-Freeze Tanks do have secondary containment details that meet the requirements of 22 CCR §66265.193, therefore; Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA HMT Inspection April 5, 2017 Page 13 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM EVALUATION FOR CCR COMPLIANCE – USED OIL STORAGE TANK (CONT’D.) Pursuant to 22 CCR §66265.191(k), the following assessment details are known or have been evaluated: (k)(1) Tank configurations are horizontal and rectangular and raised on steel supports bolted to the concrete floor with maximum gross capacities of 1,000 gallons and 280 gallons for the Used Oil and the Used Anti-Freeze tanks, respectively; (k)(2) The tank construction standard is known (UL 142) and meets empirical design criteria and normal industry practice for horizontal welded steel structures; (k)(2)(A) Material of construction (all parts in contact with liquid waste) is carbon steel (grade not known); (k)(2)(B) Material thickness of the tanks as measured are 0.187 inch nominal for the Used Oil and Anti-Freeze Primary Tanks, and 0.125 inch and 0.093 inch for the Used Oil and Anti-Freeze Secondary Tanks, respectively; (k)(2)(C) Tank connections are carbon steel nozzles / couplings up to 6 inches in size; (k)(2)(D) Flow into or out of the tanks is manually controlled; (k)(2)(E) Tank details - basic dimensions are as given in the Tank Data page included above; (k)(3) The tanks have been on location and in service for approximately 5 years. CarMax built the facility in March 2012, started operation and installed the tanks during the same time frame (per client); (k)(4) Details of installation include double-wall carbon steel with suitable containment details surrounding the tanks. These tanks rest on a concrete base of adequate design to withstand the loads imposed by the tanks resting on top and are anchored to the concrete. Frost heave is not a consideration in the design of this concrete slab at this location; (k)(5) There is no cathodic protection system currently in place for any of these tanks; Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA HMT Inspection April 5, 2017 Page 14 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM EVALUATION FOR CCR COMPLIANCE – USED OIL STORAGE TANK (CONT’D.) (k)(6) Filling of the tanks is controlled and monitored manually. The Used Oil and Used Anti-Freeze Tanks have overfill prevention devices installed; (k)(7) The non-RCRA liquid waste streams into these tanks are not treated and are only stored in the tanks until off-site disposal is arranged (approximately every 30 days per pick-up / service log, or slightly longer for the anti-freeze tank); (k)(8) The condition of the tanks indicates no structural integrity issues (no excessive settlement, no measurable metal loss from corrosion). There are no construction defects or installation issues that would lead to possible leak from these tanks in the near future; (k)(9) The tanks are constructed of carbon steel materials compatible with the stored product and are resistant to any corrosive effects without the need for internal lining; (k)(10) The estimated remaining service life of the tanks is 20 years based on the current condition and Ultrasonic (UT) testing, after which a recommended remaining service life can be re-established following periodic re-inspection and updated thickness readings. Pursuant to 22 CCR §66265.193, the Used Oil / Anti-Freeze Tanks comply with the requirements for secondary containment details as outlined in this regulation; Pursuant to 22 CCR §66265.194 the connections are visually monitored by system operating personnel when the tanks are in use; Pursuant to 22 CCR §66265.194, the Used Oil Storage Tanks fill process is controlled by manually operated pumps and inspected visually, and the tanks are constructed with secondary containment meeting details as outlined in this regulation; Compliance with, or input regarding applicability or method of compliance in the future, for regulations 22 CCR §66265.193 through §66265.200 will be supplied directly by the Owner as appropriate in the regulatory review process. Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA HMT Inspection April 5, 2017 Page 15 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM 3.1 CONTAINMENT ASSESSMENT AND EVALUATION We have evaluated the tank containment and find the following to be true: The tank containment (external steel containment details) has now and will continue to contain in the future liquids that can be classified as non-RCRA hazardous materials. The following assessment details are known or have been evaluated for each tank: 1. Pursuant to 22 CCR §66265.193(b)(1); The secondary containment (double-wall external steel tanks or containment boxes) is designed and constructed such that it will contain any minor leak of stored liquid until it can be properly cleaned; 2. Pursuant to 22 CCR §66265.193(b)(2); The secondary containment has been designed to accepted industry practice for total storage volume and is free of defects and may temporarily retain these non-RCRA hazardous materials until such leaks or spills are detected and cleaned up; 3. Pursuant to 22 CCR §66265.193(c)(1); The concrete base under the tanks is adequately constructed according to accepted industry practice and supports the Used Oil / Anti-Freeze Tanks as required; 4. Pursuant to 22 CCR §66265.193(c)(2); The concrete base under the tanks is properly designed and of suitable strength and thickness; 5. Pursuant to 22 CCR 66265.193(c)(3) & (4); The hazardous materials action plan currently in place at the facility provides that any leakage or spills from the tanks in this area will be cleaned as soon as detected (visual inspection of this area is performed by the operators responsible for this operations area); 6. Pursuant to 22 CCR §66265.193(e)(1)(A); The secondary containment details for the Used Oil and Used Anti-Freeze Tanks are directly exposed to the weather (situated outside the service shop). 7. There is direct exposure to normal weathering environment and rainfall for both tanks; Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA HMT Inspection April 5, 2017 Page 16 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM 3.2 PIPING ASSESSMENT AND EVALUATION We have evaluated the tank connecting piping and find the following to be true: Tank connecting piping has now and will continue to contain in the future liquids that can be classified as non-RCRA hazardous materials. The following assessment details are known or have been evaluated: 1. Pursuant to 22 CCR §66265.193(f); The connecting piping above ground is designed and constructed of single-wall details that will not separately contain any minor leak of stored liquid should it occur; 2. Pursuant to 22 CCR §66265.193(f); The connecting piping is free of defects and may temporarily retain these non-RCRA hazardous materials until such leaks or spills are detected and cleaned up; 3. Pursuant to 22 CCR §66265.193(f); The connecting piping to the tank is adequately constructed according to accepted industry practice; 4. Pursuant to 22 CCR §66265.193(f); The connecting piping is properly designed and of suitable strength and thickness; 5. Pursuant to 22 CCR §66265.193(f); The hazardous materials action plan currently in place at the facility provides that any leakage or spills from the tank piping will be cleaned as soon as detected (visual inspection of this area is performed by the operators responsible for this operations area); 6. Pursuant to 22 CCR §66265.193(f); No parts of this connecting piping is buried but there is secondary containment in place that will contain any leak should it occur; 7. The requirement for further containment based on the single-wall above ground construction details have been addressed by the provision of containment details beneath the piping circuits inside and outside the service shop; Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA HMT Inspection April 5, 2017 Page 17 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM PIPING ASSESSMENT AND EVALUATION (CONT’D.) There is no waste treatment processing in the containment area. No further concern is attached to this storage arrangement under the conditions seen at the site and as described further herein. The connecting piping above ground does not currently meet the requirements for secondary containment under DTSC regulations but is monitored for leaks by system operators whenever the piping is in use as allowed for by DTSC regulations. We believe that the above information provides a suitable assessment of the Used Oil Storage Tank Containment Area for CarMax at their facility in Bakersfield, CA for structures containing non-RCRA hazardous waste materials and that the tank containment details and piping details, including monitoring during operations, meet the requirements per CA DTSC Title 22 CCR §66265.193. This report is intended to provide adequate documentation for that purpose. Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA Inspection April 5, 2017 Page 20 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM 5.0 NDT INSPECTION 5.1 NDT INSPECTION SCOPE The following Nondestructive Testing (NDT) was conducted to evaluate the physical characteristics of the tank: A) Visual (VT) inspection of all accessible areas for the detection of anomalies or significant defects that may affect tank integrity. B) Random UT thickness readings on the tanks for the detection of recordable internal metal loss. Performed in accordance with HMT UT Procedure No. 1611.1, Revision No. 5. Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA Inspection April 5, 2017 Page 21 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM 6.0 EQUIPMENT 6.1 ULTRASONIC UT equipment utilized for the inspection was a USM Go Flaw Detector. The transducer utilized was a Britek, 7.5 MHz, 0.312 inch dual element. The calibration block utilized was a 5 step, 4340 steel test block. Echogel 20 and water was used as a couplant. Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA Inspection April 5, 2017 Page 22 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM 7.0 TABLES TABLE A USED OIL TANK SHELL READINGS (in inches) Primary Top of Tank Readings No. Thickness 1 0.180 2 0.182 3 0.182 4 0.176 5 0.178 Secondary Tank Shell Readings No. NORTH EAST WEST SOUTH 1 0.129 0.130 0.128 0.130 2 0.129 0.130 0.128 0.128 3 0.128 0.129 0.129 0.129 4 0.128 0.129 0.130 0.128 5 0.129 0.129 0.130 0.129 Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA Inspection April 5, 2017 Page 23 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM TABLE B USED OIL TANK SHELL PLATE CORROSION RATE CALCULATIONS Nominal/Original or Previous Shell Plate Thickness (inches) 0.187 inch Maximum External Corrosion Depth 0.000 inch Maximum Internal Corrosion Depth 0.000 inch Minimum Acceptable Course Thickness 0.050 inch Year of Inspection (Yi) 2017 year Year of Construction (Yo) if using nominal thickness or Year of previous UT 2012 year Average Remaining Thickness from External Thickness Readings 0.187 inch Average Remaining Thickness from Internal Thickness Readings 0.180 inch External Corrosion Rate 0.0000 inch/yr Internal Corrosion Rate 0.0014 inch/yr Remaining Life Calculation: Minimum Thickness – from UL 142, Sections 17, 24 and 25 = 0.093 inch Least Remaining Tank Shell Thickness from Inspection = 0.176 inch Calculation = Least Remaining Thickness – UL 142 Minimum Thickness ÷ Calculated Corrosion Rate = 0.176 inch – 0.050 inch = 0.126 inch ÷ 0.0014 inch / year > 20 years Remaining Life Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA Inspection April 5, 2017 Page 24 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM TABLE C USED ANTI-FREEZE TANK SHELL READINGS (in inches) External Secondary Side Wall Readings No. NORTH EAST WEST SOUTH 1 0.119 0.121 0.120 0.120 2 0.121 0.120 0.122 0.122 3 0.121 0.120 0.121 0.121 4 0.120 0.119 0.119 0.120 5 0.119 0.121 0.120 0.122 Primary Top of Tank UT Readings No. Reading 1 0.178 2 0.176 3 0.180 4 0.179 5 0.176 Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA Inspection April 5, 2017 Page 25 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM TABLE D USED ANTI-FREEZE TANK SHELL PLATE CORROSION RATE CALCULATIONS Nominal/Original or Previous Shell Plate Thickness (inches) 0.187 inch Maximum External Corrosion Depth 0.000 inch Maximum Internal Corrosion Depth 0.000 inch Minimum Acceptable Course Thickness 0.050 inch Year of Inspection (Yi) 2017 year Year of Construction (Yo) if using nominal thickness or Year of previous UT 2012 year Average Remaining Thickness from External Thickness Readings 0.187 inch Average Remaining Thickness from Internal Thickness Readings 0.178 inch External Corrosion Rate 0.0000 inch/yr Internal Corrosion Rate 0.0018 inch/yr Remaining Life Calculation: Minimum Thickness – from UL 142, Sections 17, 24 and 25 = 0.093 inch Least Remaining Tank Shell Thickness from Inspection = 0.176 inch Calculation = Least Remaining Thickness – UL 142 Minimum Thickness ÷ Calculated Corrosion Rate = 0.176- inch – 0.050 inch = 0.126 inch ÷ 0.0018 inch / year > 20 years Remaining Life Used Oil Tank / Containment Integrity Report For CarMax Bakersfield, CA Inspection April 5, 2017 Page 26 of 53 23263774 Carmax Bakersfield DTSC Report (Rev-2) 4/12/2017 8:09:00 AM 8.0 WARRANTY WARRANTY HMT Inspection, a division of HMT LLC (“HMT”) has evaluated the condition of this tank based on the observations and measurements made by the HMT Tank Inspector. While our evaluation accurately describes the condition of the tank at the time of inspection, the tank owner / operator must independently assess the inspection information / report provided by HMT and any conclusions reached by the tank owner / operator and any action taken or omitted to be taken are the sole responsibility of the owner / operator. With respect to inspection and testing, HMT warrants only that the services have been performed in accordance with accepted industry practice. If any such services fail to meet the foregoing warranty, HMT shall re-perform the service to the same extent and on the same conditions as the original service. The preceding paragraph sets forth the exclusive remedy for claims based on failure or of defect in materials or services, whether such claim is made in contract or tort (including negligence) and however instituted, and, upon expiration of the warranty period, all such liability shall terminate. The foregoing warranty is exclusive and in lieu of all other warranties, whether written, oral, implied or statutory. NO IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FOR PURPOSE SHALL APPLY, nor shall HMT be liable for any loss or damage whatsoever by reason of its failure to discover, report, repair or modify latent defects or defects inherent in the design of any tank inspected. In no event, whether a result of breach of contract, warranty or tort (including negligence) shall HMT be liable for any consequential or incidental damages including, but not limited to, loss of profit or revenues, loss of use of equipment tested or services by HMT or any associated damage to facilities, down-time costs or claims of other damages. 9. 0 P H O T O G R A P H S P a g e 2 7 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM An t i - F r e e z e T a n k S t a n d - o f f Ta n k S t a n d - o f f Ta n k S t a n d - o f f Ta n k S t a n d - o f f 9. 0 P H O T O G R A P H S P a g e 2 8 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Ta n k S t a n d - o f f 9. 0 P H O T O G R A P H S P a g e 2 9 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Na m e p l a t e Pr o d u c t I D Ca p a c i t y NF P A P l a c a r d 9. 0 P H O T O G R A P H S P a g e 3 0 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Se r v i c e L o g Co u p l i n g A L e a k D e t e c t i o n Co u p l i n g B S e c o n d a r y V e n t Co u p l i n g C S e c o n d a r y E m e r g e n c y V e n t 9. 0 P H O T O G R A P H S P a g e 3 1 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Co u p l i n g D P r i m a r y V e n t Co u p l i n g E P r i m a r y E m e r g e n c y V e n t Co u p l i n g F C a p p e d C o u p l i n g Co u p l i n g G L e v e l I n d i c a t o r 9. 0 P H O T O G R A P H S P a g e 3 2 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Co u p l i n g H C a p p e d C o u p l i n g Co u p l i n g I F i l l w i t h C a t c h B a s i n g Fi l l C a t c h B a s i n Ta n k S t e e l S u p p o r t s B o l t e d t o C o n c r e t e 9. 0 P H O T O G R A P H S P a g e 3 3 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Us e d O i l T a n k S t a n d - o f f Ta n k S t a n d - o f f Ta n k S t a n d - o f f Ta n k S t a n d - o f f 9. 0 P H O T O G R A P H S P a g e 3 4 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Pr o d u c t I D Se r v i c e L o g NF P A P l a c a r d Da t a T a g 9. 0 P H O T O G R A P H S P a g e 3 5 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Co u p l i n g A L e v e l I n d i c a t o r Co u p l i n g B F i l l w i t h C a t c h B a s i n Fi l l C a t c h B a s i n Co u p l i n g C C a p p e d 9. 0 P H O T O G R A P H S P a g e 3 6 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Co u p l i n g D O v e r f i l l D e v i c e Co u p l i n g E F i l l f r o m S e r v i c e S h o p Fi l l P i p i n g f r o m S e r v i c e S h o p Co u p l i n g F P r i m a r y V e n t 9. 0 P H O T O G R A P H S P a g e 3 7 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Co u p l i n g G P r i m a r y E m e r g e n c y V e n t Co u p l i n g H L e a k D e t e c t i o n D e v i c e Co u p l i n g I S e c o n d a r y V e n t Co u p l i n g J S e c o n d a r y E m e r g e n c y V e n t 9. 0 P H O T O G R A P H S P a g e 3 8 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Ta n k S t e e l S u p p o r t s B o l t e d t o C o n c r e t e Co a t i n g F a i l u r e o n T a n k T o p 9. 0 P H O T O G R A P H S P a g e 3 9 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Co n t a i n m e n t S t a n d - o f f Co n t a i n m e n t S t a n d - o f f Co n t a i n m e n t S t a n d - o f f 9. 0 P H O T O G R A P H S P a g e 4 0 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Co n t a i n m e n t D r a i n Co n t a i n m e n t D r a i n Tr a n s f e r P i p i n g f r o m S e r v i c e S h o p t o T a n k Tr a n s f e r o n R o o f R a f t e r 9. 0 P H O T O G R A P H S P a g e 4 1 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Tr a n s f e r P i p i n g a l o n g S h o p W a l l a n d R a f t e r Tr a n s f e r P i p i n g a l o n g S h o p W a l l Tr a n s f e r o n R o o f R a f t e r Tr a n s f e r o n R o o f R a f t e r 9. 0 P H O T O G R A P H S P a g e 4 2 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Br a n c h - o f f P i p i n g t o C o l l e c t i o n S t a t i o n 1 Br a n c h - o f f P i p i n g t o C o l l e c t i o n S t a t i o n Br a n c h - o f f P i p i n g t o C o l l e c t i o n S t a t i o n Br a n c h - o f f P i p i n g t o C o l l e c t i o n S t a t i o n 9. 0 P H O T O G R A P H S P a g e 4 3 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Br a n c h - o f f P i p i n g t o C o l l e c t i o n S t a t i o n Br a n c h - o f f P i p i n g t o C o l l e c t i o n S t a t i o n 1 Co l l e c t i o n S t a t i o n 1 Tr a n s f e r P i p i n g C o n t i n u e d f r o m B r a n c h - o f f 9. 0 P H O T O G R A P H S P a g e 4 4 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Tr a n s f e r P i p i n g o n R a f t e r Br a n c h - o f f P i p i n g t o C o l l e c t i o n S t a t i o n 2 Br a n c h - o f f P i p i n g t o C o l l e c t i o n S t a t i o n 2 Br a n c h - o f f P i p i n g t o C o l l e c t i o n S t a t i o n 2 9. 0 P H O T O G R A P H S P a g e 4 5 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Co l l e c t i o n S t a t i o n 2 Co l l e c t i o n S t a t i o n 2 Tr a n s f e r P i p i n g C o n t i n u e d f r o m B r a n c h - o f f Tr a n s f e r P i p i n g o n R o o f R a f t e r 9. 0 P H O T O G R A P H S P a g e 4 6 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Tr a n s f e r P i p i n g o n R o o f R a f t e r Tr a n s f e r P i p i n g o n R o o f R a f t e r Tr a n s f e r P i p i n g t o C o l l e c t i o n S t a t i o n 3 Co l l e c t i o n S t a t i o n 3 9. 0 P H O T O G R A P H S P a g e 4 7 o f 5 3 23 2 6 3 7 7 4 C a r m a x B a k e r s f i e l d D T S C R e p o r t ( R e v - 2 ) 4/12/2017 8:09:00 AM Co l l e c t i o n S t a t i o n 3