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HomeMy WebLinkAboutTANK LINING 2024 1301 Academy Ct. Fort Collins, CO 80524 www.cgrs.com 800.288.2657 Fiesta Liquor 2023 Baker St. Bakersfield, CA 93304 CGRS Project # 28445 Fiesta Liquor – Bakersfield, CA UST LINING INSPECTION REPORT August 14, 2024 Prepared for: Fiesta Liquor TABLE OF CONTENTS 1.0 INTRODUCTION .......................................................................................................................................................... 3 2.0 SCOPE ......................................................................................................................................................................... 3 3.0 TANK INSPECTION AND FINDINGS ........................................................................................................................ 3 3.1 Subject UST........................................................................................................................................................... 3 3.2 Inspection .............................................................................................................................................................. 4 3.3 Dry-Film thickness testing ..................................................................................................................................... 4 4.0 CONCLUSION ............................................................................................................................................................. 5 APPENDICES Appendix A: Photo Log Appendix B: Certifications April 28, 2023 1.0 INTRODUCTION This report summarizes the internal inspection and determination of fitness for continued service of three (3) existing underground fuel storage tanks (USTs) located at 2023 Baker St. Bakersfield, CA 93305 (Fiesta Liquor). Three USTs on site were inspected as part of the 10 and 5-year inspection program. All three tanks are 12,000-gallon Fuel UST’s. As a part of routine maintenance and EPA CFR 40 Part 280.21 and CCR Title 23-2663 (h), CGRS, Inc. of Fort Collins, CO performed 5-year internal lining inspections. This report presents UST shell and bulkhead coating thicknesses and visual inspection results. The report also provides CGRS’s opinion on the USTs fitness for continued use. 2.0 SCOPE CGRS was hired by Fiesta Liquor to provide internal UST lining inspections. The scope of the work included making the USTs safe for confined space entry, clean the USTs for observations, visually evaluate the USTs to determine if the tanks have any major or minor coating damage. Perform dry-film (coating) thickness readings and visual inspections. The inspection shall follow a modified fit-for-service analysis as prescribed by American Petroleum Institute API 1631 “Interior Lining and Periodic Inspection of Underground Storage Tanks,” National Leak Prevention Association (NLPA) Standard 631, and industry-standard structural standards for UL-1316 tanks. To meet the Water Board requirements of CCR Title 23-2663, Interior Tank Lining Requirements, the special inspector (Niko Retes NACE Coatings Inspector Level 2) entered and inspected the entire interior surface of the tank and certified the tank based on the inspection criteria below. 3.0 TANK INSPECTION AND FINDINGS 3.1 Subject UST Fiesta Liquor operates a service station and convenience store providing diesel, unleaded, and premium fuels at the site. The manufacturer and age of the UST was not identified. The dimensions of the tanks are as follows: a.) UST-1 8’ X 33’ b.) UST-2 8’ X 33’ c.) UST-3 8’ X 33’ The tanks are buried approximately 4-feet below a concrete surface deck. The tank was accessed through the fill sump with an integral tank manway lid. Photographs are provided in Appendix A. The Steel Tank was inspected based on the following criteria: a) CGRS cleaned the tank so that no residue remained on the tank walls. b) CGRS visually checking the tank interior and lining for discontinuity, compression, tension cracking, and corrosion. c) For steel tanks, testing the entire tank interior using a thickness gauge on a one-foot grid pattern with metal wall thickness recorded on a form that identifies the location of each reading in order to verify that average metal thickness is greater than 75 percent of the original wall thickness. d) Testing for liner thickness and hardness of the lining in accordance with nationally recognized industry codes to verify that the lining meets the standards under which the lining was applied. e) For steel tanks, testing the lining using an electrical resistance holiday detector in accordance with nationally-recognized industry codes. The owner or operator shall have all holidays repaired and checked in accordance with nationally recognized industry codes. f) Certification from the special inspector or coatings expert that the tank is: Not Suitable for continued use. 3.2 Inspection CGRS Inc. prepared the USTs for entry by opening the fill port sump, removed fill and vapor sump to access the UST’s manway lid. The team purged the USTs of vapors, and conducted confined space protocol air monitoring, prior to entering the tanks and inspecting the USTs. Sediment and remaining fuel were cleaned from the tank. Once the fuel was removed, all three tanks showed signs of advanced damage. From visual inspections, it appeared that an original liner was placed in all three tanks, but this liner was too thin. Average original liner thicknesses were between 19 and 43mils, significantly below the required 100 mils needed to line a UST. It appears that after the original liner a second liner was attempted. The adhesion of the second liner was poor. Likely due to a poor surface prep profile, almost all of the second liner had been delaminated and was no longer present. All tanks had areas greater than 10 percent that were bare steel. No advance corrosion or pitting was observed in these areas. 3.3 Dry-Film thickness testing Typically, a Dry-Film Thickness gauge is used to measure coating thickness. In this instance, the coating was greatly deteriorated and it was not possible to properly utilize the dry-film thickness tester. In Appendix A, the photo log displays the extent of the coating deterioration, showing large portions of the coating falling off the steel. It was also noted that the first coating that was applied was deemed too thin and a second coating was applied on top of the first coat. In the California Code of Regulations, Title 23, Division 3, Chapter 16 § 2661. Requirements for Repairing Underground Storage Tanks it states “A tank may be repaired once using the interior lining method specified in section 2663. A previously lined tank may not be repaired using the interior lining method.” For safety purposes, the interior lining can only be applied once, which in this case it was lined twice. In the California Code of Regulations, Title 23, Division 3, Chapter 16 § 2663. Interior Tank Lining Requirements it also states the following: “Tank lining may be used to satisfy part of the upgrade requirements of section 2662 or to repair a tank pursuant to section 2661. However, a tank that has been repaired using the interior lining method may not be repaired a second time with the interior lining method. The evaluations described in subdivisions (b) and (c) of this section shall be completed before the lining of a primary container may be authorized by the local agency. The local agency shall deny the proposed lining if the owner fails to demonstrate that the lined primary container will provide continued containment based on the evaluations described in subdivisions (b) and (c). (h) If a steel tank is lined for the purpose of satisfying the requirements of section 2662(c), or if any tank is repaired using the interior lining method, it shall be inspected by a coatings expert or special inspector within 120 months of lining and every 60 months thereafter.” 4.0 CONCLUSION Limitations: This inspection was conducted in accordance with generally accepted industrial standards and represents site conditions during the time of the visit. The inspection did not include review of design drawings or weld inspection reports. If external UTs were performed, they are an average and may not find all flaws. As such the limits of this report are as an overall survey of the tank this report does not serve as a guaranty of future system performance. Due care has been taken to verify and confirm the accuracy of this report. The inspection focuses on a failure mode which can be determined by visual and may not identify modes of failure such as stress corrosion cracking, hydrogen embrittlement, and micro effects of metal flaws in steel manufacturing which would require a more extensive non-destructive and destructive testing. A safety factor is used to accommodate these unknowns and is typical in engineering analysis. As such, CGRS finds the USTs ARE NOT SUITABLE for continued use. If you have any questions please contact the undersigned inspector, Niko Retes at (360) 823-6265. Sincerely, CGRS, Inc. Niko Retes., Project Manager. APPENDIX A Photo Log 1 | P a g e Fiesta Liquor | August-2024| Photo Log 2 2 | P a g e Fiesta Liquor | August-2024| Photo Log 3 | P a g e Fiesta Liquor | August-2024| Photo Log END OF PHOTOS APPENDIX B CERTIFICATIONS APPENDIX B CERTIFICATIONS APPENDIX B CERTIFICATIONS APPENDIX B CERTIFICATIONS