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HomeMy WebLinkAboutRISK MANAGEMENTSteve Underwood Wholesale Fuels doc ~ -~~~ ~ ~ ~~~~ ~ ~~~ Page 1~ CORROSION SPECIALISTS SINCE 1993 ~-Itech Corrosion Control October 15, 2005 Wholesale Fuels 2200 E. Brundage Ln Bakersfield, CA Attention Mr. Doug Young. Subject: Cathodic Protection Survey Dear Sir: P.O B o x 1 1 6 5 8 B a k e r s f 1 e i d C A 9 3 3 8 9- 1 6 8 5 8 P H 1~ 6 6 1- 3 1 9- 4 7 6 0 A cathodic Protection Survey was performed on Oct 15, 2005 ctt the Wholesale Fuels Facility located at 2200 E. Brundage Ln. Bakersfield, CA. The system layout is as follows: the rectifier is mounted on the rtirth wall of the store stockroom. The anode bed is located at an undetermined location on the west side of the store property. The tank structure leads come into the rectifier from a northerly direction; the tanks and pump units are Iccated just North of the warehouse building. In order to obtain valid cathodic protection data the reference electrode (11a1f cell) was placed in the dirt area located on the Eastside of the warehouse near the chain link fence. The cathodic protection tests were performed with an interrupter placed in the DC circuit at intervals of 6 seconds on and 3 seconds off. The results are tabulated in the succeeding pa+~es. The tank meets the requirements for cathodic Protection under the Code of Federal Regulations, 40 CFR Part ~$0. The cathodic protection levels of protection were taken with regards to the following NACE Standards: • RP0169-92 Standard recommended practice: Control of Corrosion on Underground or Submerged Metallic Piping Systems. • RP 0285-85 Standard recommended practice: Control ryf External Corrosion on Metallic Buried, Partially Buried, or Submerged Liquid Storage Systems. • STI R892-91 Recommended practice for Corrosion Protection of Underground Piping Networks Associated with Liquid Storage and Dispensing Systems. • American Petroleum Institute (API) Recommended Practice 1632, Cathodic Protection of Underground Petroleum Storage Tanks and Piping Systems. While the Environmental Protection Agency (EPA) and local regulations mandate testing to be conducted on three- year intervals to determine the effectiveness of the installed systems, experience and good engineering practice dictate that an assessment on this type of system be made on ar, annual basis. This, coupled with the required bi- monthly inspections by the Wholesale Fuel Facility personnel, WIII assure the continued effective operation of the installed corrosion control systems. The annual inspection of the cathodic protection systems should consist of structure-to-soil potential measurements, current output of the anode bed, and a summary report to includa field data and recommendations as required. 1 Steve Underwood -Wholesale Fuels.doc ~ ~ ,~v~,~~..~.~x.,.~._,-~~,. Page 2 Wholesale Fuel Facility personnel are required to record the rectifier voltage and current meter outputs on a bi-monthly basis using the form presented herein. Notifying qualified personnel immediately should the readings vary +/- 20% from our initial test data noted in this report is highly recommended. Altech appreciates the opportunity to have assisted you in this effort, please call us at 661-319-4760 with questions regarding any part of this report. Respectfully, AI Perez Project Manager/ Engineering N.A.C.E. Cathodic Protection Tester #23 N.A.C.E. Certificated Corrosion Technologist #3811 N.A.C.E. Intermediate Coating Inspector Training I, II, III, #2039 Steve Underwood- Wholesale Fuels O & M doc ~~ ~ ~~~~~~~ ~~ M Page 1 ALTECH CORROSION CONTROL SERVICE OPERATING AND MAIN'~~NANCE MANUAL CATHODIC PROTEC"~`ION SYSTEMS FOR SIX UNDERGROUND S~`~ORAGE TANKS At WHOLESALE .FUELS PREPARED 1'~R: Wholesale h~-els 2200 E. Brund~~~rre Lane Bakersfield, C~Iifornia PREPARED ~Y: ALTECH CORROSION C0~1~1TROL SERVICE P.O.Box116i58 BAKERSFIELD, iCA, 93389 October 22i X005 w _..„~„m~~~., ~~, ..,~.~ .~~.~,.~~~„~,..~.~~.~,~.~,...~~,.~,~ Steve Underwood Wholesale Fuels O 8~ M doc Page 2 d TABLE OF C01`~f`~ENTS Page 1.0 Monitoring and Maintenance Procedures . 1.1 Monitoring 2 1.2 Maintenance 3 2.0 Trouble Shooting 2.1 .System Operation 4 2.2 Rectifier Diagnostics 7 2.3 Safety Products 9 3.0 How Cathodic Protection Works 3.1 Basic Principles of Corrosion 10 3.2 Cathodic Protection Principles 11 3.3 What Can Cathodic Protection Do and 1~T~t Do? 11 3.4 How Do You Tell If A Cathodic Protection System is Working? 12 3.5 Why and How Should Records Be Kept' 15 3.6 Inspections of Structure 15 4.0 Instructions, Potential Measurement 4.1 Instructions, Anode Output Measurement 16 4.2 Test Equipment 16 4.3 Commissioning Survey Operational Data 18 4.4 Potential Survey Data Sheets 19 2 Steve Underwood -Wholesale Fuels O 8~AM doc ~~ ~ ~ ~~ ,..~-.,.~,..~..~~.. ~. Page 3 OPERATING AND MAINTENANCE MANUAL GALVANIC ANODE AND IMPRESSED CURRENT CATHODIC PROTECTIOP~ SYSTEMS The cathodic protection system for the six underground service tanks consists of an impressed current system. Maintenance of the impressed current system consists mostly of rectifier monitoring, troubleshooting, and repair. The information Contained in this manual concerns itself with impressed current systems. Proper maintenance is essential for the operation of the cathodic protection system. The complete or partial failure of a cathodic protection system is not usually accompanied by any visible signs. Very often the only means of detection is noting the change in structure-to-soil potential through the -use of electrical instruments. If there is a failure on a cathodic protection system, the relatively slow process of corrosion resumes, resulting in eventual large repair/replacement expense to the owner. Therefore, it is important to properly maintain all cathodic protection systems. In addition to the change in structure-to-soil potentials as mentioned above, several other indications of failure may be detected. Changes in rectifier output in impressed current type systems may indicate problems. If the system is totally inoperative, a drop in power consumption will be indicated on the monthly power bill. Maintenance and operation of cathodic protection systems does not require a thorough knowledge of corrosion theory; however, knowledge of fhe basic principles of corrosion will be useful in understanding how cathodic protection works. ~JVith this understanding, measurements made during field surveys will become meaningful and th+e measurement techniques can be more Steve~Underwood -Wholesale Fuels O 8~ ~M.doc ~~ ~~~~~~ ~ ~ ~~~~~~~~~~~~~~~~~~ ~~~~~~~~ Page 4 readily adapted to unusual situations. An introduction to corrosion and cathodic protection theory, and the significance of structure potentials is provided in Section 3.0 of this manual. 1.0 Monitoring and Maintenance Procedures For the purpose of this Operating and Maintenance 1~vlanual, monitoring refers to routine inspection on a monthly basis by Wholesale Fuels persoiii~el. Maintenance is the more detailed testing and adjustment of the system which should be perl`ermed by qualified Corrosion Control Personnel. 1.1 Monitoring The following procedure should be followed during rifonthly monitoring of your impressed current cathodic protection systems: • Read the rectifier voltage and current output (see rectifier data sheet, section 4.3). Rectifier output and structure potential readings shall be considered acceptable when they are within +/- 20% as compared to the respective values recorded at the time of the last annual survey. The data for the System is listed in the post installation Survey report field- data (Sec. 4.3 of this manual). Because normal system adjustments may be made during annual maintenance surveys, the most recent survey data should be referenced when evaluating the monthly maintenance readings. If the readings are acceptable, then no further field work is required. If the readings are not acceptable, then the trouble shooting procedure outlined it1 Section 2.0 should be followed. 1.2 Maintenance d teve Underwood Wholesale FuelsryO 8~ M.docv~ ~ ~ ~~ Page~5 'The following procedures should be followed during the annual cathodic protection resurveys of both types of cathodic protection systems: 1. Examine each rectifier for physical damage from: vandalism, wind; clogged ventilation, lightning, exposure or overheating. 2. Read and record DC voltage, DC amperage and tap setting on rectifier maintenance sheets. If there are significant changes in output when compared with records of previous visits, further investigation is warranted. 3. Turn the rectifier off. Feel the diodes for uneven heating. If all the diodes are not at the same temperature, employ the tratil~le shooting procedures described in Section 2.0 4. While rectifier is still off, check the bolted electrical connections for heat and looseness. 5. Calculate rectifier efficiency: Percent Efficiency = DC Power/AC Powtr x 100 DC Power = DC Volts x 17~C Amperes AC Power = AC Volts x AC Amperes Once the rectifier unit has been inspected and ready then proceed with the potential survey for both systems. Record structure-to-soil potentials at the following locations: 1. At all test stations. 2. At vent and product piping to monitor ele~tt`cal isolation status. Anode current should be measured at each wire shunt in each system type. Anode shunts are typically located at an anode junction box at the rectifier and at, the anode test station on the galvanic anode system. All data should lie recorded on a cathodic protection survey data sheet. If the test data does not conform to the established criteria for cathodic protection, institute the trouble shooting procedures: Typical survey data sheets are found in Section 4.4 of this manual. s Steve Underwood%- Wholesale Fuels~O & M.doc .e~~.,rt~ ~~...W..~ ~ - ._. N ~ Page 6 2.0 Trouble Shooting When impressed current systems are operating improperly, several considerations should be explored prior to testing rectifier components and circuits~~ 1. Past Data - DC output of rectifier Structure-to-soil potentials Electrical isolation Checks 2. New Construction - Cable breaks Inadvertent electrical shorts to foreign structures 3. Installation of new foreign cathodic protectitrn systems. 4. Extensive use of DC in area. 5. Recent storms. 2.1 Svstem OneraHon Many rectifier problems are obvious to the experienced technician and do not require elaborate inspection procedures. The obvious should never be ignored. The majority of rectifier failures occur from: blown fuses, loose connections, defective meters or open DC cables. These can generally be detected by a simple visual inspection of the tYrlit. 1. No DC voltage and/or current. A. Blown DC fuse: If this fuse fails, a DC vriltage will be observed on the rectifier meter but no current. (1) If apparently due to steady overload; reduce the output slightly. (2) If the fuse blows repeatedly, even ~.vith the output reduced, a short circuit may exist, caused by a defective rectifier component or underground short. Determine whether the short is infernal or external to the rectifier. With the rectifier off, disconnect the ane of the DC output cables from the rectifier and re-energize the rectifier: If the fuse still blows, the short is .,.,.~.,...~~.~~.. .w...,~..~.~-~.~.~, .~.. Steve Underwood -Wholesale Fuels O 8~ M doc _ r„ ,.H_ V_ a ~_ ~ ,,,~~„ ~w „~ xy„~ ~~~wr_wx, ,~, ~~-,~,. TMPage 7, ~- internal to the rectifier. In that case, isolate the component by the procedure outlined in the following section. (3) If the fuse blows occasionally for rio apparent reason, the cause maybe: (a) Temporary overload due to seasonal changes in anode bed resistance. (b) Surges of AC voltage. (c) Intermittent shorts in rectifier' components. (d) Intermittent shorts in ground bed circuit. B. Blown AC fuse: if this fuse fails, neither +/oltage nor current will be observed in the DC circuit. Check the fuse with a light or AC voltmeter. Replace if necessary. Do not overlook the possibility that service to the rectifier maybe interrupted. C. Loose connections: check all connections, fine and coarse transformer tap adjustments and diode connections. D. Defective meters: (1) DC voltmeter -.if a current output is indicated on the DC ammeter, but no voltage is observed, place a portable voltmeter across the DC terminals. If no voltage is indicated on the portable meter, check to be sure the ammeter is not frozen by turning the unit off If a voltage is recorded, check for an open in the voltmeter circuit. This can usually be done by removing the voltmeter and visually inspecting the circuit. If no defect is observed, replace the voltmeter. (2) DC ammeter - if a voltage is indicated on the DC voltmeter, but no current is observed, insert an ammeter in the DC circuit. Turn the unit off and disconnect the positive DC cable: connect the positive terminal of the ammeter to the rectifier lug and the negative terminal to the anode cable. Turn the unit on and observe the meter. If current flow is indicated, check the ammeter circuit for loose or ripen connections. If no defects are Steve Underwood -Wholesale Fuels O & M doc~~ ~~~~~~~~~~~ ~ ~~~~~~- ~ Page 8 observed, replace the ammeter. E. Opens in ground bed cables: one of the metre common problems which develop with impressed current systems is a break in the anode circuit. Detection of an open in either the positive or negative leg is relatively simple. Monthly data on rectifier current and voltage outputs is used to determine if the bed has slowly deteriorated or if the cables have been severed. In most cases where a faulty DC lead is encountered, the voltage output will 1~e near the level last recorded, but the current output will be slight, if any. The steps taken to determine which lead is open and the method to locate the break arc as follows: (1) Open in negative cable - if the break is suspected in the negative connection, attach a test lead fram the structure to the negative DC terminal of the rectifier. If the negative cable is in fact open, the test lead will complete the circuit and current flow will be observed. Examine the route of the negative cable to determine if any digging has recently occurred in the area. If the location of the break is not obvious, use a cable locator to locate the open. Do nt~C discount a broken connection to the structure. (2) Open in positive cable - a break in the ground bed circuit most commonly occurs in the positive leg. This is due to the fact that any break in the insulation which exposes bare copier will result in current discharge to ground at that point. A complete severance of the cable will shortly follow. If the .open occurs before the first anode, the entire ground bed will be lost. It should be noted, lirtwever, that breaks may occur at any point within the circuit. If only a portion of the anode string is disconnected, the anode bed resistance will increase appreciably. _ To determine if the positive leg is in fact open, install a temporary anode bed and connect to the positive terminal of the rectifier. If current flows in the Steve Underwood -Wholesale Fuels~O & M.doc ~ ~~~~~~~~~ ~ ~ ~~~~~~~ ~~~~~~~~~~~~~~~~~~~~~ Page 9 temporary circuit, disconnect and use a cable locator to pinpoint the break. Disconnected anodes within a vertical column cannot normally be serviced. Therefore, identifying the exact location of such a failure is meaningless. It maybe feasible to maintain effective corrosion mitigation despite one or more lost anodes b~ increasing rectifier output voltage. However, several factors must be considered, and parameters of ground bed operation are beyond the scope of this manual. A qualified consultant should be retained before modifications are implemented. 2. If the DC voltage is only about half what it should be (use circuit resistance as calculated from previous rectifier readings) when the current output is at the maximum, the trouble maybe: A. Open circuits in one or more of the diodes resulting in half-wave rather than full- wave rectification. This can be determined by using the diode troubleshooting techniques described in the next section. B. Rectifier connected for 240 VAC while 120'VAC is being supplied. 2.2 Rectifier Diagnostics When the rectifier unit is not functioning properly, systerriatically isolate the components. until the defective part is located. The procedure to follow is: 1. Check the line voltage by placing the leads from an AC voltmeter or circuit tester across the line side of the circuit breaker. 2. Check across the load side of the circuit breaker. The voltage should be the same as at the line side. 3. Check the rectifier input tap for loose connections and to verify adjustment for the proper AC voltage. 4. Check the secondary transformer windings with an AC voltmeter or circuit tester. If AC voltage is applied to primary windings, but none is present at the secondary, Steve Underwood Wholesale Fuels O & M doc ~~~-~~~~~-~ ~ ~ ~~-~ ~~~~~~~~ Page 10 ~ listen for an audible hum from the transformer. A. If no tone is detected, measure the resistance of the primary winding with an ohm-meter (be sure to turn the unit off). The resistance should be within the range from one to ten ohms. B. If a tone is detected, the resistance of the secondary winding should be measured. If either resistance was quite high, the winding is essentially an open circuit and the transformer most be replaced. Make sure that the high resistance is in the winding and not al connection lug. The entire secondary winding mad be measured between highest coarse tap and the highest fine tap. If the circuit breaker trips, indicating a short circuit, the transformer may be isolated from the DC circuit by removing the secondary tap adjustment terminals. If the circuit breaker continues to trip, inspect for visible shorts between the transformer leads. If it holds, the short is not in the transformer but in the DC circuit. 5. Check the AC voltage supplied to the rectifier diodes. This voltage should be the same as measured at the secondary transformer winding. If AC is present at the secondary winding, but not at the diode terminals, check the leads from the transformer to the diodes. Replace any defective lead. 6. If AC is applied to the diodes, use an ohm-meter to determine the diode resistance. Disconnect each diode and measure both forward and reverse. resistance with an ohm-meter. The forward resistance should Ire negligible and the reverse resistance infinite. If either measurement does not concur, replace the diode. If the AC circuit breaker trips, isolate the diode from the DC circuit. If the breaker continues to trip, the diode is defective and trust be replaced. 7. If the circuit breaker does not trip when the diode is removed but does when the diode is connected, there is probably a short in the external DC circuit. This may 10 Steve Underwood ~-Wholesale Fuels O & M doc ~ ~~~~~ ~~ ~~ ~~ ~ ~ Page 11~ be verified by removing the anode and structure leads, one at a time. 8. If DC is present at the diode, but not at t1~e rectifier output terminals, check for loose connections or open leads between these points. This may be done by measuring the DC voltage between the c~Yc~de output negative and each point in question on the positive circuit leg. The procedure is reversed to troubleshoot connections in the negative circuit leg. 9. If DC voltage is present at the rectifier output terminals, but no current is flowing, there is an open in one of the external DC leads. 10. Faulty meters may cause the rectifier tv appear defective when it is actually functioning properly. The meters may be +c~tecked with portable meters known to be accurate. 11. A faulty lightning arrestor in this rectifier (AC or DC) may be isolated by removing it from the circuit. The rectifier +uvill operate with either or both lighting arrestors removed. END OF TROUBLE SHOOTIl'~1G SECTION 2.3 Safetv Procedures Because cathodic protection systems operate at voltages well below the shock hazard level as defined by OSHA 2207 Subpart K 1926.405(K), no special precautions during monitoring or maintenance procedures are required. If the unit has been installed correctly with regard for AC power grounding, then no significant risk of shock hazard resulting from unit damage or malfuiYCtion will be present. 11 Steve Underwood -Wholesale Fuels O 8~ M doc~~ ~~~~~~' ~ ~ ~ ~~~~ ~~ ~Pa a 12~ .,~,,,9,.~.. The AC adjustment taps should be considered hazazdetts. Power should be shut off to the rectifier before adjusting or servicing. As with any electrical device, servicing should not be attempted by unqualified personnel. 3.0 How Cathodic Protection Works 3.1 Basic Principles of Corrosion When a metal corrodes, electrical current is generated. The area where corrosion occurs is called the anode. The current enters the soil or other conductive environment at the anode and flows to the non-corroding area, or cathode. At the same time, an +etlual quantity of electron current flows from the anode to the cathode through the metal. At the cathode the positive and negative current neutralize each other. For corrosion to occur, all ~t~ur parts of this circuit must be_ present: a current generator or anode; a conductive environment such as soil or water; an electron path which must be a metal; and a cathode. There are many reasons why a certain area on a structure may become an anode or a cathode. If two different metals aze present one will become an anode and the other a cathode; this is called galvanic corrosion. Anodes and cathodes can form on a single metal if there is even a slight variation in the environment between different areas on the metal. These can be differences in the amount of air which can reach the metal surface, such as can occur in loosely and tightly packed soil, differences in soil or water properties such ai dissolved salts or acids, or differences in the moisture content of the soil. Small differences in tttetal condition between different areas on the metal can also cause anodes and cathodes to form: These can be differences in surface condition such as abraded and non-abraded, clean and rusty, new and old, or differences in manufacturing conditions such as hot-rolled and cold-rolled or stressed (bent) and unstressed. Even threading of a pipe can cause the threaded areas to become anodic to the unthreaded area of the pipe. 1 Steve Underwood Wholesale Fuels O ~ M.doc .~ ~~~ ~~~ ~ ~ ~ ,~ Page 13 While these forms of attack have different causes, they all involve the same four parts of the corrosion circuit; an anode, a positive path, a negative patiiy and a cathode. 3.2 Cathodic Protection Principles Cathodic protection uses the principle of corrosion. The four components of the corrosion circuit are present except that instead of having an anode on the metal we want to protect we connect a more active anode to the metal to supply excess negative current. This makes the entire surface of the metal we want to protect act like a cathode. Corrosion principles say that corrosion does not occur at a cathode and we can therefore protect a metal by electrically connecting to it a current source or anode. Cathodic protection is really a farm of corrosion but by understanding the corrosion circuit we can make corrosion an ally. The cathodic protection systems installed on the 6 underground service tanks is of the "impressed current" type, in which the current is not supplied by the anodes, but is supplied by an external direct current source, in this case, rectifiers. The anodes are, however, consumed at a slow rate. As far as the protected metal is concerned, the impressed current system is the same as a sacrificial anode system. However, the current is not beittg generated by corrosion of the anode, and an inactive material such as cast iron can be used An anode is still required so that the current can enter the environment. 3.3 What Can Cathodic Protection Do and Not Do's A cathodic protection system can, in actual practice, protect a buried or submerged structure indefinitely, provided that he cathodic protection systettl is properly designed, operated, and maintained. Maintenance of cathodic protection systems does not require access to the entire structure, so cathodic protection systems on buried storage Tanks can be practically maintained. Cathodic protection is also the only practical method of protecting large buried or submerged structures which were not originally protected or on which the original paint or coating protection has failed. 13 ~~Steve Underwood -Wholesale Fuels O & M doc ~ ~~~~~~~~~~~~ ~ ~~~~~~~~ ~~~~~~~~~~~~~~ ~ ~~~~~~ Page 14 ~ Cathodic protection does have certain limitations. First, the structure must be surrounded by an environment which can conduct the electrical current from the anodes to the structure. In soil the conductivity is primarily due to the presence of moisture, As the amount of moisture and the amount of dissolved salts increase, the soil becomes more conductive. Soil in a salt marsh is an excellent conductor, whereas moist soil such as loam is a good conductor, and dry sand is a poor conductor. Air cannot conduct electrical currents. Therefore, structures cannot be protected above ground or out of water using cathodic protection. It is not simply coincidence that highly conductive environments are also usually highly corrosive. This is because the corrosion cell can act more readily over a longer distance when the conductivity of the environment is high, allowing more current to flow. Another thing that cathodic protection cannot do is to improve the condition of any already corroded structure. Cathodic protection can stop further corrosion, but it cannot "plate back" corroded metal. 3.4 How Do You Tell If A Cathodic Protection Svs~etn Is Working? Because a cathodic protection system is electrical in nature; it is possible to determine whether or not a cathodic protection system is working by taking electrical measurements. Because the soil in which the .structure is buried or the water in which it is submerged is conductive, these measurements are usually performed using the environment as a conductor. The single most important measurement made in cathodic protection field surveys is the potential of the structure. If it is more negative than the environment, it attracts positive charges that cannot leave. If positive charges cannot leave, then corrost~n cannot occur. 14 Steve Underwood Wholesale Fuels O & M doe ~~~ ~ ~ ~ ~ Page 15 ~ Measurements of single potentials cannot be made; ail that can be measured are potential differences. The potential difference between the envirorment and the structure can be measured using a suitable meter. If a metallic probe is used to make contact with the envircrntnent, the potential of the probe would be unknown, so a measurement of the potential difference Between the probe and structure would depend on two variables and would not be meaningful. Itt t~rder to provide a means of contacting the environment, reference electrodes have been devela~ed that have stable and reproducible potentials. By measuring the potential difference between a standard reference electrode and a structure, a value is obtained for the potential of the struciltre which is dependent only on the type of reference electrode and the structure's potential. A portable copper-copper sulfate reference electrode ina~y be used for all routine potential monitoring. The test stations each contain PVC tubes vtvhich extend down closer to the tank surfaces, to measure a more local potential at the tank. Measuring Device: The meter used to measure the potential difference between the reference electrode and the structure is similar to an ordinary volt teeter. However, an ordinary voltmeter cannot be used to measure these potentials because it has tdo low of an internal impedance. Low impedance allows enough current to flow in the, measuritg circuit to affect the measurement. This is primarily because the reference electrode will change potential when appreciable current flows through it. A current of 1 mA in the measuring circuit will affect the potential of the reference electrode to the point that the readings obtained are unreliable. By correctly using a meter specifically designed (10 meg ohms per volt or greater internal impedance) for use in making these potential measurements, the current flowing in the measuring circuit will be kept well below 1 mA. 15 Steve Underwood- Wholesale Fuels O & M doe _~:~,~~,,~.~a~_ ~ ~~ s.ub~.~~.~ ~~ _ ~ ~~ Page 16 Electrical Connections With Structures: In making field measurements of structure potentials, the only requirement is a good electrical connection with the structure. The potential being measured depends primarily on the location of the reference electrode (hence the PVC tube described earlier), not on the place where the connection is made to tiie structure. Each test station contains dual test leads to its corresponding tank, for the purpose of establishing the electrical connection. The rectifier negative terminal should not be used for this purpose with the cathodic protection system on due to measurement error introduced by the resistance of the lead cable. When the portable reference electrode is placed close to t$e structure, the potential measured is that of a local area of the structure near the reference electrode. When the reference electrode is placed far from the structure, the potential measured is close to an "average" potential of the structure. Since there will probably be a difference bet~iVeen the local and average potential readings, it is important that when the potentials are to be compared with potentials taken earlier or later, the portable reference electrode be placed at apprtt~imately the same location each time a potential is measured. Potential Measurements: It is usually desirable to malre potential measurements with the protective current turned "on" and "off'. Whenever the potential is read with the protective current off, this fact should be recorded. When making potential measurements there are several indications that the readings obtained are not accurate; e.g. if the meter always reads exactly the satrie value with the reference electrode in different locations, or if the meter reading slowly fltictl~ates over a range in excess of 10 millivolts. Normal meter behavior is to slowly approach a stable reading. Stable readings should be reached within 10 seconds. 1b Steve Underwood Wholesale Fuels O 8~ M doc w ~ ~M ~ 'Page 17 Typical Potential Measurements: In most environments, steel structures which are being cathodically protected have typical potentials. Unprotected steel structures also have typical potentials, although the unprotected structure potentials vary much more than the protected structure potentials. A potential between -300 and -500 mV vs copper sulfate is typical of unprotected corroding steel structures. A potential betweetr -800 and -850 mV vs copper sulfate is typical of a structure completely protected. If-the potential is more negative than -1100 mV then the structure may be overprotected. If the structure is overprotected, as much, or in some cases even more damage maybe occurring than if the stntcture were unprotected. 3.5 Why and How Should Records Be KeAt? One of the first indicators of malfunction of a cathodic protection system is a sudden change in operating conditions such as structure potential or rectifier output. Only by keeping good records of operating conditions can these changes be discovered promptly. The date, location, and value of all structure potential readings should be recorded. Any maintenance performed, such as anode replacement or repair of faulty connections should be recorded to identify trouble spots where possible system modification maybe required. 3.6 Inspections of Structure If sections of the pipelines are removed during maintenance inspections or other repairs, then the effectiveness of the protection system can be determined by inspecting the structure. Gross corrosion is, of course, indicative of system failure. The presence of deposits on the structure should not be confused with corrosion. Calcareous deposits are formed on cathodically protected surfaces. These deposits are often significantly lighter in color than normal rust and may even be white. Only by removing the surface deposits and inspecting the underlying surface can a valid assessment, of the cathodic protection of the pipelines be nisde. '17 Steve Underwood -Wholesale Fuels O 8~ M doc ~u~ w~.. ;.A~ ~~ Page 18~~ 4.0 Instructions, Potential Measurement Using a suitable multimeter or voltmeter, select a scale far voltage measurements up to two volts. Connect the negative meter lead to a portable reference ele+~trode. Connect the positive meter lead to a test lead in a test station. Ensure that ametal-to-metal connection is obtained. Read and record the meter display and date obtained as potential (voltage) with respect to the reference electrode location. Do not immerse the reference electrode terminal without the use of a special submersible adapter.. On dry soil, the soil should be moist or moistened with tap water at the cell contact point. The meter should be a digital display type with input impedantWe of 10 meg ohms, minimum. If an analog multimeter is used, the test lead connections must be reversed from the description above. The reading obtained is then recorded as negative potential (-v) with respect to copper- copper sulfate. 4.1 Instructions, Anode Output Measurement Using a suitable multimeter or voltmeter, select a scale for voltage measurements up to 50 millivolts. Connect the meter leads across each anode skint at the junction boxes. The reading in millivolts times 100 equals' milliamperes (.01 ohm shtitit). 4.2 Test Eauipment The following list of equipment is a minimum requirement for the maintenance and operation of the cathodic protection system. Many specialized instruments whose use is outside the scope of 1 Steve Underwood -Wholesale Fuels ~O 8~ M doc ~~ ~ ~ ~ Page 19 ~ this manual but which are required for design, installation and troubleshooting of cathodic protection systems are not included in this list. A qualified corrosion engineer should be consulted regarding purchase of specific cathodic protection test and maintenance equipment. 1. Meter for Structure-to-Environment Potentials Meter Specifications: Input impedance......10 meg ohms/volt, minimum Range ................0 to 2 volt DC, minimum The functions of this meter are a minimum requirement. Many meters, cathodic protection instruments, and other high input impe~arice voltmeters may be used. 2. Reference Electrodes a. CuCuSO4 electrode, stud type for buried of submerged structure use. b. Reagent grade copper sulfate crystals and deionized water for replenishing reference cell antimony (mix to obtain a saturated solution). A one-piece instrument which combines a potential motet and reference cell in one unit is also available. This can be used for pdrtable cathodic protection potential measurements. 3. Lead Wires 6-foot test wires with clips - no. 16 or no. 18 stranded copper with rubber insulation. 500-foot test wires on suitable reels with clips - rin. 16 or no. 18 stranded copper with rubber insulation. 'I Steve Underwood -Wholesale Fuels Rectifer monthlyylnspy-form xls` ~~~~~F'y~~~~ ~~~'µa'~~'~ ~~' Page 1 Wholesale Fuels Monthly f~ectifier Data Sheet Altech Corrosion Control S~w`vice 1-661-319-4760 Please keep sheet in rect~~ier door panel HOUR RN E1'ER (IF READING DATE VOLTAGE CURRENT (AMPS) APpLICIIBLE) INITIAL COMMENTS Steve Underwood Wholesale Fuels Rectifier monthly Insp form xl~ - Page 2 Steve Underwood -Wholesale Fuels Site Photos.doc~~~~tt~~ ~N~~~~~~~~~~~~~~~~~tl~~ Page 1~ ~~- ~ sr _i , y y ~ . r> ~p~1~FUE~S ~~ ~ . '~~~sr r. rn~ r ~ f ~: I :~ e..:tits:.' ~.xac.~. .. ..f1.av~s.a:;,>7S`5~~•-~ ~.~ ;~ --s--_ _ ~~Steve Underwood -Wholesale Fuels Site Sce4ch.doc~~~ ~~~~~~~~~~~ ~~ ~~~~~~~~ Page 1 Alte~~ Corrosion Control CORROSION SPECIALISTS SINCE~1993 5101 Diamond Oaks Ave Bakersfield, Ca. 93306 PH 1-661-319-4760 October 15, 2005 Wholesale Fuels 2200 E. Brundage Ln. Bakersfield, CA Attention Mr. Doug Young Subject: Cathodic Protection Survey Dear Sir: A cathodic Protection Survey was performed on October 15, ~t705 on the Wholesale Fuels Facility located at 2200 E. Brundage Ln. The system layout is as follows: the rectifier is mounted on the Borth wall of the store stockroom. The anode bed is located at an undetermined location on the store property. TNo tank structure leads come into the rectifier from a northerly direction; the tanks and pump units are located just Korth of the store building. In order to obtain valid cathodic protection data the reference electrode (half cell) was placed in the dirt area located on the eastside of the warehouse next to the chain link fence. The cathodic protection tests were performed with an interruptoP placed in the DC circuit at intervals of 6 seconds on and 3 seconds off. The results are tabulated in the succeedir9g pages. The tank meets the requirements for cathodic Protection under the Code of Federal Regulations, 40 CFR Part 280. The cathodic protection levels of protection were taken with regards to the following NACE Standards: • RP0169-92 Standard recommended practice: Control of Corrosion on Underground or Submerged Metallic Piping Systems. • RP 0285-85 Standard recommended practice: Control of External Corrosion on Metallic Buried, Partially Buried, or Submerged Liquid Storage Systems. • STI R892-91 Recommended practice for Corrosion Protection of Underground Piping Networks Associated with Liquid Storage and Dispensing Systems. • American Petroleum Institute (API) Recommended Prentice 1632, Cathodic Protection of Underground Petroleum Storage Tanks and Piping Systems. Steve Underwood -Wholesale Fuels Site Scetch.doc ~,,.. ~~~ a.~ ~~~ ~ ~. Page 2 4 While the Environmental Protection Agency (EPA) and local rejUlations mandate testing to be conducted on three-year intervals to determine the effectiveness of the installed systems, experience and good engineering practice dictate that an assessment on this type of system be mi~de on an annual basis. This, coupled with the required monthly inspections by the W holesale Fuels personnel, will assure the continued effective operation of the installed corrosion control systems. The annual inspection of the cathodic protection systems sho~fld consist of structure-to-soil potential measurements, current output of the anode bed, and a summary report to include field data and recommendations as required. Wholesale Fuels personnel are required to record the rectifier vt;`Itage and current meter outputs on a bi-monthly basis using the form presented herein. Notifying qualified persdrtnel immediately should the readings vary +/- 20%frorn our initial test data noted in this report is highly recommended. Altech appreciates the opportunity to have assisted you in this dtfort, please call us at 661-319-4760 with questions regarding any part of this report. Respectfully, AI Perez Project Manager/ Engineering N.A.C.E. Cathodic Protection Tester #23 N.A.C.E. Certificated Corrosion Technologist #3811 N.A.C.E. Intermediate Coating Inspector Training I, II, III, #20'0 Steve Underwood -Wholesale Fuels Site Scetch doc ~. ~ Page 3~ CATHODIC PROTECTION S~'if`~TEM INSPECTION UNDERGROUND STCJ~~AGE TANKS CORROSION PROTECTION MONITORING FORM Altech CorrosiomContrclSen~i~e tt 1 19-4-64 Facility Information Print or T g , Facility Name Wholesale Fuels Facility ldenfification Number = -_ _ _ Street Address 2200 E. Brunda a Ln. NumbeY of Tanks Six City Bakersfield. CA Tank Type Steel State CA Zip Vent Material Steel Type bf Corrosion Protection (Galvanic or Impressed Current) Name/Address of Testing Company For Impressed Current Systems Only Altech Corrosion Control Service Rectifier Serial Number 98059 P.O.Box 11658 Voltage 50V Current 12A , Bakersfield. CA. 93389-1658 Conclusion Svstem functioning orooerly Phone Number 661-319-4760 Comments Person Conducting Test AI Perez Date of Test October 15.2005 Steve Underwood Wholesalef Fuels-Site Scetch.doc~~~~ M~,,...~ 4~s .~~_.,.. ~~~ Page 4 e In the spac e below, sketch the important parts of the facility (tanks, tank mlialn way locations, vents, pump islands, buildings, etc.). Indicate deference ce ll locations where structure-to-soif potential or continuity measU~ements have been made. d En• '~ Reference Cell Location ~ Rectifier o Wholesale ~ Fuels Warehouse Brundage Lane My signature below is affirmation that I have sufficient education and/or ezper•ience to meet the definition of cathodic protection tester in [40 CFR 280.12], I am competent to perform the tests indicated above; that test results on this form are a complete and truthful record of all testing at this location on the date shown, and that I am responsible for all conclusions contained therein. AI Perez .... October15.2005 Name Date Facility Name Wholesale Fuels_ Facility I. D. Number = -_ _ -- 100 MILLIVOLT POLARIZATION DECAY MEASUREM~WTS (FOR IMPRESSED CURRENT SYSTEMS) (Not required if Instant Off Voltage re~ding exceeds 850 millivolts) ................ Contact Points (Take readings wherever Access is available Location of Reference Cell Voltage (Current On) Instant Off Voltia~ge .............. Final Voltage Voltage Decay Comments (Pass, Fail, etc.) TANK 1 s/s of whse-All ............ Clear Cart Diesel ..., A. Fill Pipe 1213mv 64~tnv ............. 1213mv 571mv Pass B. Pump Disp. 878mv 601ttiv ............ 878mv 277mv Pass C. Vent 1132mv 651ttiv ........... 1132mv 481mv Pass ............ TANK 2 Clear Diesel .... A. Fill Pipe 1168mv 64~ttiv ...,,., 1168mv 525mv Pass B. Pump Disp. 877mv 601triv 877mv 276mv Pass Steve Underwood WFiolesale Fuels Site Scetch doc ~ ~ ~ ~ ~~ .,.. Pa a 5~ ~.,9_... C. Vent 1132mv 651itty ... 1132mv 481mv Pass ' ............ TANK 3 .... Clear #2 Diesel ...... A. Fill Pipe 1147mv 648tt1v 1147mv 499mv Pass B. Pump Disp. 878mv 601mv 878mv 277mv Pass C. Vent 1132mv 651tt-v ........ 1132mv 481mv Pass ..., . TANK 4 Unleaded Gas ................ A. Fill Pipe 1131mv 64$mv ....... 1131mv 483mv Pass B. Pump Disp. 878mv 601tt1v ........... 878mv 277mv Pass C. Vent 1132mv 651mv .... 1132mv 481mv Pass .....,. TANK 5 ............. Diesel ........ A. Fill Pipe 1131mv 64i3tnv ........... 1131mv 483mv Pass B. Pump Disp. 878mv 601tt-v ... 878mv 277mv Pass C. Vent 1132mv 651ttiv 1132mv 481mv Pass TANK 6 .... Diesel A. Fill Pipe 1116mv 648ttiv 1116mv 468mv Pass B.-Pump Disp. 878mv 601mv . _...... 878mv 277mv Pass C. vent 1132mv 651tnv 1132mv 481mv Pass My signature below is affirmation that I have sufficient education and/oC experience to meet the definition of cathodic protection tester in [40 CFR 280.12], I am competent to perform the tests indicated above, that test results on this form are a complete and truthful record of all testing at this location on the date showri, and that I am responsible for all conclusions contained therein. Al Perez October 15, 2005 BUSINESS/DEAPRTMENT NAME: ADDRESS: r~omcr r~scmrno~: PRO~ ~~ER: DA~: N~: PROJECT COMPLETION: DATE: r-~ Certified Fee Postmark Return Receipt Fee Hem ,jj (Endorsement Required) c[3 Restricted Delivery Fee rm (Endorsement Required) I'U T°t~/ -- ~------~-----~- [~;~: o BOX 82277 : ............ ~[!? BAKERSFIELD CA 93380 2277 .............. · Complete items 1, 2, and 3. Also complete ,..,d Signature item 4 if Restricted Delivery is desired. · Print your name and address on the reverse-z ssee so that we can return the card to you. B. Received by (Printed Name) I C. Date of Delivery ' Attach this card t° the back °f the mailpiece' or on the front if space permits. D. Is delivery address different from item/l~? [~Yes 1. Article Addressed to: If YES, enter delivery address below: [] No WHOLESALE FUELS P O BOX 82277 3. Service Type [] Certified Mail [] Express Mail BAKERSFIELD CA 93380 2277 [] Registered [] Return Receipt for Merchandise .... .......... [] Insured Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) [] Yes " 7002 0860 0000 1641 5172 PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-0835 December 1, 2002 Wholesale Fuels P O Box 82277 Bakersfield CA 93380 2277 FIRE CHIEF RON FRAZE CERTIFIED MAIL ADMINISTRATIVE SERVICES 2101 'H' Street Bakersfield, CA 93301 VOICE (661) 326-3941 ~^x iOOl)395-1~n~ FINAL REMINDER NOTICE suP.RESS,O. SE.V,CES JANUARY 1, 2003 DEADLINE Bakersfield, CA 93301 vo,cE (66,)~26-394, ~Z Z-CO0 Ty.. ua FAX (661) 395-1349 Dear Tank Owner/Operator: PREVENTION SERVICES ,,,~,s~Es.,~o,.,,~,,,..~,,,:,, You will be receiving this letter on or about December l, 2002. One 1715 Chester Ave. Bakersfield, CA ~m01 month from today, January 1, 2003, your current underground VOICE (661) 326-3979 FAX (661) 326-0576 storage tank(s) will become illegal to operate. Current law would require that your permit be revoked for failure to perform the PUR,,C EDUCATIOn necessary Secondary Containment testing. 1715 Chester Avb. Bakersfield, CA 93301 VOICE (661) 320-3696 FAX (661)326-0576 In reviewing your file, I see that you have received "Reminder Notices" since April of this year. This is your last chance to comply F,RE,NVESTIC~TION with code requirements for Secondary Containment testing prior to 1715 Chester Ave. Bakersfield, CA 9..3,301 January 1, 2003. VOICE (66.1) 326-395'1 FAX (661) 326-0576 Should you have any questions, please feel free to contact me at 661- TRAINING DIVISION 326-3190. 5642 Victor Ave. Bakersfield, CA 93308 VOICE (661) 399-4697 -- -.,Rincerelv, FAX (661) 399-5763 Steve Underwood Fire Inspector/Environmental Code Enforcement Officer Office of Environmental Services SBU/dc WHOLESALE FL IEL.S, INC. TO: ATTN: ~ call ir.,ou experience an~ problems receiving - May 3, 1999 Charles McCan, President Wholesale Fuels, Inc. ~,~ C.,EF 2200 E. Brundage Lane RoN FROZE Bakersfield, CA 93307 ADMINISTRATIVE SERVICES 21o4 'H' street CERTIFIED MAIL Bakersfield, CA 93301 vO,CE (805) 32~-3941 FAX (805)39~-~349 TEMPORARY EXEMPTION NOTICE SUPPRESSION SERVICES CALARP RISK MANAGEMENT PLAN 2101 'H' Street Bakersfield, CA 93301 VOICE (805) 326-3941 FAX (805) 395-1349 Dear Mr. McCan; PREVENTION SERVICES The attached notice from the United States Environmental 1715 Chester Ave. Bakersfield, CA 93301 Protection Agency temporarily exempts propane from the June 21, 1999 VOICE (805) 326-3951 FAX (805) 326-0578 Risk Management Plan submission date. Em.O.ME.Tn. SE.WC~S Our records indicate that your facility now qualifies under this 1715 Chester Ave. - Bakersfield. CA 93301 exem_ption. You will not be required to submit a Risk Management Plan VOICE (805) 326-3979 FAX (805) 326-0576 by June 21, -1~999, nor comply with the additional California Accidental Release Program (CalARP), as of that date. You will, however, still be TR~.lnO DIVISION required to comply with all existing local fire codes and ordinances for the 5642 Victor Ave. Sakersne~d, CA 93308 safe storage and handling of flammable gases, but will not be subject to VOICE (805) 399-4607 FAX (805) 399-5763 further regulation involving thc new CalARP Risk Management Plan until further notice. If you have any questions regarding this exemption, please call me at (661) 326-3979. Sincerely, Howard H. Wines, III Hazardous Materials Specialist Office of Environmental Services HHW/dm attachment - March 29, 1999 Charles McCan, President Wholesale Fuels, Inc. 2200 E. Brundage Lane Bakersfield, CA 93307 CERTIFIED MAIL FIRE CHIEF RON FRAZE 90 DAY NOTICE ~M,.,s~m~ SE.VICES CalARP RISK MANAGEMENT PLAN & 2101 'H' Street Bakersfield, CA 93301 vo,cE (805)326-3941 PREVENTION PROGRAM REQUIRED FOR FAX (~05)395`1~9 SUBMISSION & IMPLEMENTATION PRIOR TO su...~ss,o, s~.vic~s JUNE 21, 1999 2101 'H" Street Bakersfield, CA 93301 VOICE (805) 326-3941 FAX (805) 395-1349 Dear Mr. McCan: PREVENTION SERVICES The intent of this letter is to inform you of the necessary deadlines 1715 Chester Ave. Bakersfield. CA 93301 for complying with the California Accidental Release Program (CalARP) VOICE (805) 326-3951 FAX (805)326-o578 including submission of the required Risk Management Plan and implementation of the appropriate Prevention Program prior to June 21, ENVIRONMENTAL SERVICES 1999. 1715 Chester Ave. Bakersfield, CA 93301 VOICE (805) 326-3979 FAX (005) 326,0576 Our records indicate that your facility was previously notified of these requirements by Certified Mail dated June 17, 1998. At this time, TRAINING DIVISION you should have already coordinated with this office on the method of 5642 Victor Ave. Bakersfield, CA 93308 Hazard Review or Process Hazard Analysis to be conducted, the VOICE (805) 399-4697 FAX (805) 399-5763 appropriate Prevention Program level to be implemented and the Management System employed at your facility to oversee all such CalARP requirements. If you have not yet done so, or have any questions regarding the necessary level of coordination between your facility and our office concerning CalARP, please call me immediately at 661-326-3979. Sincerely, Howard H. Wines, III Hazardous Materials Specialist Office of Environmental Services HHW/dm ,O April 20, 1999 Charles McCan President Wholesale Fuels Inc 2200 E Brundage Lane Bakersfield CA 93307 RRE CHI£F CERTIFIED MAIL RON FR~E ADMINISTRATIVE SERVICES 2101 'H' Street Bakersfield, CA 93301 60 DAY NOTICE vo,cE (805)326-3~1 r~x (805)39s-1~9 CALARP RISK MANAGEMENT PLAN & PREVENTION PROGRAM REQUIRED FOR suP.uess,o. SEaVICES 2101 'H' Street SUBMISSION & IMPLEMENTATION PRIOR TO Bakersfield, CA 93301 vo.cE (805)326-3~1 ~Ax (805)395-1~9 JUNE 21, 1999 PREVENTION SERVICES Dear Mr. McCan: 1715 Chester Ave. Bakersfield, CA 93301 VOICE (S0S) 326-3951 FAX (805)326-0576 The intent of this letter is to inform you of the rapidly approaching deadline for complying with the California Accidental Release Program ENVIRONMENTAL SERVICES (CalARP) including submission of the required Risk Management Plan 1715 Chester Ave. Bakemfield, CA 93301 and implementation of the appropriate Prevention Program prior to VOICE (805) 326-3979 FAX (805) 326-0576 June 21, 1999. TRAINING DIVISION Our records indicate that your facility is subject the CalARP 5642 Victor Ave. Bakersfield, CA 93308 requirements. By this time, you should have already completed the VOICE (805) 399-4697 FAX (805) 399-5763 Hazard Review or Process Hazard Analysis, the Off-Site Consequence Analysis, and have entered the necessary data into your Risk Management Plan (RMP) for submission to this office and possibly the United States Environmental Protection Agency (if also subject to federal regulations). If you have not yet done so, or have any questions regarding the necessary level of coordination between your facility and our office concerning CalARP, please call me immediately at 661-326-3979. Sincerely, Howard H. Wines, III Hazardous Materials Specialist Office of Environmental Services D !' December 16, 1998 Charles McCan, President Wholesale Fuels, Inc. 2200' E. Brundage Lane Bakersfield, CA 93307 FIRE CHIEF ~o~ ~ZE RISK MANAGEMENT WORKSHOP FOR INDUSTRY ADMINISTRATTVE SERVICES 2101 'H' Street ~kers~e~d. C~ 93301 JANUARY 7, 1999, 9:00 A.M. VOICE (805) 326-3941 FAX (805)395-1349 OLIVE DRIVE FIRE TRAINING FACILITY SUPPRESSION SERVICES Dear Mr. McCan: 2101 'H' Street Bakersfield, CA 93301 VOICE (805) 326-3941 A workshop conducted by the Governor's Office of Emergency Services FAX (805) 395-1349 regarding the new California Accidental Release Prevention (CalARP) and PREVENTION SERVICES associated Risk Management Plan programs will be held in Bakersfield on 1715 Chester Ave. Thursday, January 7, 1999 at 9:00 a.m. at the Olive Drive Fire Training Facility Bakersfield, CA 93301 VOICE (805) 326-3951 located at 5642 Victor Street. FAX (805) 326-0576 You have been previously notified by this office that your facility is ENVIRONMENTAL SERVICES likely to be subject to the new CalARP requirements, including the 1715 Chester Ave. Bakersfield, CA 93301 implementation of a specified Prevention Program and submission of a Risk VOICE (805) 326-3979 FAX (805) 326-0576 Management Plan on or before June 21, 1999. This workshop should help answer any questions you may have. TRAINING DIVISION 5642 Victor Ave. A letter of invitation, agenda, Request for Comments Letter, and the text Bakersfield, CA 93308 VO/CE (805)399-4697 of the CalARP regulations are enclosed. You may wish to familiarize yourself FAX (805) 399-5763 with the regulations and bring them along to the workshop for your reference. A map of the workshop location and surrounding restaurants is also attached. Please make every effort to attend this important event. Sincerely, Howard H. Wines, III Hazardous Materials Specialist Office of Environmental Services HHW/dm attachment enclosures B A K E R S F I E L 'D FIRE DEPARTMENT June 17,1998 Charles McCan, President I:ll~ CHIEF Wholesale Fuels, Inc. MICHAEL R. KELLY 2200 E. Brundage Lane Bakersfield, Ca 93307 ADMINISTEATIVE SEI~VICES 2101 'H" Street Bake~'fleld, CA 93301 CERTIFIED MAIL (805) 326-394 I FAX (805)395-1349 NOTICE OF RISK MANAGEMENT PLAN (RMP) REQUIRED BY JUNE 21, 1999 SUPPRESSION SEEVICES 2101 'H" Street Bakersfield, CA 93,301 Dear Mr. McCan: (805) 326-3941 FAX (805) 395-1349 Your facility has been identified by [his office as a probable candidate to be subject to the new California Accidental Release Program (CalARP), which will involve among many other ~[:VmnOn S~aCES requirements, the submission ora Risk Management Plan to this office, and also to the United 1715 Chestor Avo. Bakersfield, CA 93,301 States Environmental Protection Agency (USEPA) in many cases, on or before June 21, 1999. (805) 326-3951 lAX (80,5)326-0576 The CalARP regulations are a merging of the federal and state risk management prevention programs for accidental release prevention of several hundred listed flammable or ENVIRONMENTAL SERVICES toxic substances (e.g.: ammonia, chlorine, propane, etc.) which pose the greatest risk of causing 1715 Chester Ave. death, injury, or seriously affecting human health or the environment if accidentally released. Bake~field, CA 93301 (805) 326-3979 FAX (805)326-0576 The rule requires certain facilities to develop and implement an integrated system to identify hazards and manage risks associated with these regulated substances. Since your facility n~Jt~tnG D~SlON appears to be subject to this rule, you will be required to analyze worst-case releases, document a 5642 Victor Street five-year history of serious accidents, coordinate with local emergency responders, develop and Bakersfield, CA 93308 (805) 3994697 implement a prevention program that includes, among other steps, identification of hazards, FAX (805)399-5763 written operating procedures, training, maintenance, and accident investigation. If your employees also respond to accidental releases, you must implement an integrated local emergency response program. An informative digest is enclosed for your reference. The text of the regulations, technical assistance, and other information is available from our office by calling me directly at (805) 326-3979. Sincerely, Howard H. Wines, III Hazardous Materials Specialist Office of Environmental Services HHW/dm enclosure P 024 36& 593 Receipt for. Certified Mail No Insurance Coverage Provided ~~m~ Do ~t use for International Mail (See Reverse) sed 0U L] S MCC Street and No. 2200 E BRUNDAGE LANE P.O., State and ZiP Code BAKERSFIELD CA 93307 Pos,ege $ .3 2. Certified Fee 1 o lO Special Delivery Fee Restricted Delivery Fee .} Return Receipt Showing to Whom & Date Delivered 1.10 ~ Return Receipt Showing to Whom, ¢: Date, and Addressee's Address -3 TOTAL Postage C~ .~ F,~s $ 2.52 &,.~stmark or Date SENDER:' I also wish to receive the · Complete items 1 ~nd/or 2 for additional services. · Complete items 3, anf · b. followin, "vices (for an extra · Print your name and a%,..~s'on the reverse of this form% so that we can fee): ~ ~.'O- return this card to you. /' · Attach this form to the front of the mailpiece, or on the back if space 1. [] Addressee's Address does not permit. · Write "Return Receipt Requested" on the mailpiece below the article number 2. [] Restricted Delivery .~' · The Return Receipt will show to whom the article was delivered end the date Consult postmaster for fee. delivered. 4a. Article Number 3. Article Addressed to: __~P 390 214 400 CHARLES MCCA~ PRESIDENT 4b. Service Type [] Registered' ~ Insured ie 2200 E BRUNDAGE LANE Ex~r- ~-~'~' ~'''1~1~t R e c e i ptu~.~,~ .~ ~-~ for BAKERSFIELD CA 93307 ~~_~O'--n~ if requeste 5. Signature (Addressee) d 6. Sig~(~nt) O~ PS Form 38~ 1, Decem'~er 1991 ~u.S. aPO'.tgg~-,~-?t4 DOMESTIC RETURN RECE[~, P 024 36& 425 Receipt for Certified Mail No Insurance Coverage Provided ~ ~.~ Do not use for International Mail (See Reverse) se~--'~IARLE S MCCAI~ st~°E BRUNDACE LANE : P.O., State arid ZiP Code , BAICERSFTF. LD CA 93307 Pos,ege $ .3 2 Certified Fee 1.10 Special Delivery Fee Restricted Delivery Fee ~ Return Receip, Showi.g 1.10 O) to Whom & Date Delivered Return Receipt Showing to Whom, Date, and Addressee's Address :3 ~ TOTAL Postage ¢' Feea $ 2.52 [ ostmark or Data SENDER: · Complete items 1 ar~J,)r 2 for additional services, ~ also wish to receive the · Complete items 3, ta & b. follow ~ervices (for an extra · Print your name an~ress on the reverse of this form so that we can fee): ~ return this card to you. · Attach this form to the front of the mailpiece, the back if 1 [] Addressee's Address does not permit. · Write "Return Receipt Requested" on the mailpiece below the article number, 2. [] Restricted Delivery o The Return Receipt will show to whom the article was delivered and the date delivered. ' ~' Consult postmaster for fee. ~ 4a, Article Number P 024 368 425 CBARLES DJCCAN PRESIDENT 4b. Service Type NttOLESALE FUELS INC [] Registered [] Insured 2200 E BRIJI~AGE LANE~ ' [~ertified [] COD [] Express Mail [] Return Receipt for Merchandise 7. Date of Delivery 5~S~) ~t~k ~j~/~.'/ 8. Addressee' s Address (Only if requested . 6. Sign~t~ur~ (Agent) ~ PS Form 381 1, December 1991 ~u.s. GPO: 1993--352-714 DOMESTIC RETURN RECEIPT P 024 368 518 ~ Receipt for Certified Mail, I~ In~dr~ce Coverage Provided ,~ Do not use for I~ternetional Msil ~_ _' (See Reverse) ~IIA.,~LES MCCAN PRESIDENT Street and No. 2200 EAST BRUNDAGE lANE P.O., State and ZIP Code BAKERSFIELD CA 93307 Postage $ .32 Ce,ified Fee !. 10 Special Delivery Fee Restricted Delivery Fee  Return Receipt Showing to Whom & Date Delivered 1 o 10 Return Receipt Showing to Whom, Date, and Addressee's Address - TOTAL Postago $ 2.52 {~ & Fees ~ ~ostmark or Date I alsg_wish to receive the Complete items 1 an,,*"~2 for additional services. : Complete items 3, a ' & b. foIlowi~ ,=rvices (for an extra Print your nar~e an~,..~ess on the reverse of this form so that we can fee): ~ '-~ return this card to you. ' Attach this form to the front of the mailpiece, or on the b~.~k ~ space 1. [] Addressee's Address docs not permit. · Write "Re~urn Receipt Requested" on the mailpiece below the article number 2. [] Restricted Delivery .~-=" · The Return Receipt will show to whom the article was delivered and the date delivered. Consult postmaster for fee. 3. Article Addressed to: 4a. Article Number E P 024 368 518 CHARLES MCCAN PRESIDENT 4b. Service Type I~' I~HOLESALE FUELS TNC [] Registered [] Insured 2200 FJkST BRUNDAGE LANE ]~Certified [] COD ._~. BAKERSFIELD CA 93307 [] Express Mail [] Return Receipt for ~~X~~ Merchandise 7. Date of Delivery Signature (Addressee) -~/ ,~ 4 ~t~'~-t~ I 8. Addressee's Address (Only if requested 2n-~5. ~' g~ ~ and fee is paid) 6. S~F~ure/~Agent)/~ V~ 4C~/ I PS Form 8811; d4c~mber 19dl- ~-'"0~0:1993--352-714 DOMESTIC RETURN RECEIPT P 024 368 538 Recei[~t, for Certified Mail" No Insurance Coverage Provided ~Do not use for International .Mail (See Reverse) ~LLES HCCAN PRESIDENT ~ ~°' BRUNDAGE ~ P.O., State end ZIP Code BAKERSFIELD CA 93307 ~ostage $ · 32 Certified Fee 1.10 Special Delivery Fee Restricted Delivery Fee Return Receipt Showing ~O3 to Whom & Date Delivered ]- ,, ]-0 i ~turn Receipt Showing to Whom, ~. ?~m, and Addre~'s Addre~ "'~ TOTAL Postage o~ ! & Feas $ 2.52 ~, Postmark or 0ate O t~ "~ '~plete items 1 and/or 2 for additional services. I alSO wish to receiva tho ~j~plete items 3, and 4a & b. following services {for an extra · I:~int your nsme and addrass on the reverse of this form so that ~e can fee}: return this card to you. · Attach this form to the front of the mailpiece, or on the back if space 1. [] Addressee's Address does not permit. · Write "Return Receipt Requested" on the mailpiece below the article number 2. [] Restricted Delivery · The Return Receipt will show to whom the article was delivered and the date delivered. Consult postmaster for fee. 3. Article Addressed to: 4a. Article Number P 024 368 538 C[]A~ES t'[CCA~ PI~SIDENT E~EtOLESALE FUELS TNC 4b. Service Type 2200 EAST BRUNDAGE LAlqE [] Registered [] Insured BAKERSFIELD CA 93307 [] Certified [] COD [] Express Mail,~" ~'~e..ceipt for 7. Date of~ ~e ~ 5. ~7~natwre (Addressee)~~ 8. Addres.~ A(Ir~ ;quested .~ ..~.~ -(/~/J/., ~ and fee ??.,~ _ _ ~i ~-.~_~gnature (Agent) ~.. ~s-'~fform 3811, December 1991 ~u.S.G~O:~,ga---~-?ta DOMESTIC RETURN RECEIPT C OR R'E C TIO N · N O.rTJ:CE 'You are ne~e~y' requi~ea tolm~ke the following corrections :" . Completion Date for. Corrections: //S'J/~/3;'~"tec~ ' l Date , STATE OF CALl FORNIA GEORGE DEUKMEJIAN, Governor CALIFORNIA REGIONAL WAIER QUALITY CONTROL BOARD-- ~ CENTRAL VALLEY REGION - , ........ ' 27 November 1990 Mr. Charles McCan Wholesale Fuels, Inc. 2200 East Brundage Lane Bakersfield, California 93307 WHOLESALE FUELS, INC. SUMP, KERN COUNTY We have reviewed the Closure Report that was provided to us by Mr. Russell Juncal of WaterWork for the Wholesale Fuels, Inc. sump. Enclosed is a memorandum which contains our comments and a report of an inspection recently conducted at the subject facility. Please note from the memorandum that the closure of the sump appears to be adequate. Should you have any questions concerning this matter, please call Roberta Howe of this office at (209) 488-4393. F.SCOTT NEVlNS Senior Engineer RCH:rch/fmc Enclosure cc: vKern County Environmental Health Department, Bakersfield Mr. Russell W. Juncal, WaterWork, Escalon MEMORANDUi~ CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD - CENTRAL VALLEY REGION 3614 East Ashlan Avenue Phon~: (209) 445-5116 Fresno, CA 93726 Al'SS Phone: 8-421-5116 TO: F. SCOTT NEVINS FROM: ROBERTA C. HOWE Senior Engineer Staff Engineer DATE: 27 November lggo SIGNATURE: SUBJECT: CLOSURE OF THE WHOLESALE FUELS, INC. SUMP, BAKERSFIELD, KERN COUNTY COMMENTS: I have reviewed the 15 January 1990 Closure Report prepared by Mr. Russell Juncal, R.G. {No. 3864) of WaterWork for the Wholesale Fuels, Inc. sump. The closure involved removing the contaminated materials from the sump, spreading the excavated materials on site and grading the spreading area to prevent ponding, and filling the excavation with clean soil brought from off site. We reviewed the post-excavation soils sampling results in November 1989, and indicated that backfilling of the excavation with clean soils could proceed. We recommended that the area above the former sump be graded to prevent ponding and requested that the closure report include documentation of the source of the fill material and the results of chemical analyses of the fill material. The Closure Report indicates the fill was obtained from the Gateway development on Mt. Vernon (across Highway 58 from the site), and includes the results of the chemical analyses of the soil. The analytical results indicate the metals concentrations in the fill material are within the ranges typically found in natural soils. There were no PCBs found in the soil at a detection limit of 0.0002 ug/g. According to the Closure Report, the fill was transported to the sump area and placed in the excavated area in layers approximately 2-feet thick. The lifts were compacted with a rubber-tired loader. Upon completion of the backfill and ~compaction, the area was graded to prevent ponding. The Closure Report also indicates that if settling is noted in the future, the area will be graded as necessary. The information provided in the Closure Report is satisfactory. INSPECTION REPORT: On 16 November 1990, I inspected the Wholesale Fuels, Inc. facility at 2200 E. Brundage Lane, Bakersfield. I was accompanied by Mr. Terry Olgilvie of Wholesale Fuels, Inc. The area formerly occupied by the sump is level with the surrounding area. The soils appeared to be well-compacted, and Mr. Olgilvie stated that a binder had been added to the soils at the surface to reduce dust. I observed no discolored soils at the former sump area. Maintenance of the area appeared to be adequate. HHOLESALE FUELS, INC. SUNP -2- 27 November 1990 CONCLUSIONS: The closure of the Nholesale Fuels, Inc. sump has been completed and appears to be adequate. No further work is necessary at this time. RCH:rch/fmc STATE OF CALl FORNIA GE DEUKMEJIAN, Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD--. CENTRAL VALLEY REGION .... SAN JOAQUIN WATERSHED BRANCH OFFICE: *-~.. 3614 EAST ASHLAN AVENUE PHONE: (209) 445-5116 27 November 1989 ~>'~%"-'x~,~/ Mr. Charles McCan Wh61~sale Fuels~ Inc. 2200 East Brundage Lane Bakersfield, California 93307 WHOLESA[E]FUELS,.¥~NC~SUMP~ KERN COUNTY We have evaluated the post-excavation soil sampling results that were provided to us by Mr. Russell Juncal of WaterWork for the Wholesale Fuels, Inc., sump. Enclosed is a memorandum with our comments and recommendations. Please note that the excavation may be filled with clean soils. Upon completion of backfilling the excavation, and compaction of the fill material, the area over the sump should be graded to prevent ponding. In addition, our review of the Closure Plan for the sump requested that documentation regarding the source of the fill dirt and the results of chemical analysis of the fill dirt be included in the closure report. Prior to 15 January 1990, please provide us with a report of the sump closure. Should you have any questions, please telephone Roberta Howe of this office at (209) 488-4393. F.SCOTT NEVINS Senior Engineer RCH:rch:bro Enclosure cc: Kern County Health Department, Bakersfield Mr. Russell W. Ouncal, WaterWork, Escalon Memorandum CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD eCENTRAL VALLEY REGION 3614 E. Ashlan SAN JOAQUIN WATERSHED BRANCH Telephone: (209) 445-5116 Fresno, CA 93726-6905 State Lease Line: 421-5116 TO: F. Scott Nevins FROM: Roberta C. Howe Senior Engineer Staff Engineer DATE: 27 November 1989 SIGNATURE: ~ C. ~ SUBJECT: POST-EXCAVATION SAMPLING RESULTS FOR THE WHOLESALE FUELS, INC. SUMP, KERN COUNTY COMMENTS I have reviewed the post-excavation sampling results for the Wholesale Fuels, Inc. sump in Bakersfield, California. The information was submitted by Mr. Russell W. Juncal, R.G. (No. 3864, expiration date 6/30/g0) of WaterWork. INTRODUCTION Wholesale Fuels, Inc. is a petroleum jobber facility operating at 2200 E. Brundage Lane, Bakersfield, California. As part of the facility's past operations, a sump on the north side of the property was used as a collection area to receive rinse water from external vehicle washing. Rainwater washing oil off drums, storm water runoff, and possible spillage may have also entered the sump. Wholesale Fuels, Inc. was notified by State Water Resources Control Board staff that this surface impoundment might be subject to the Toxic Pits Cleanup Act of 1984 (TPCA). Wholesale Fuels, Inc. demonstrated that the levels of chemicals in the sump were not hazardous. Thus, we concluded that the sump was not subject to the TPCA. However, as the concentrations of some of the chemicals present in the bottom of the sump were higher than Acceptable Drinking Water Levels and were thought to pose a threat to ground water quality, we requested that Wholesale Fuels, Inc. develop a closure plan for the sump. The Closure Plan for the Wholesale Fuels, Inc. sump, prepared by WaterWork, proposed excavating the contaminated soils from the sump, spreading these soils on-site, and backfilling the excavated area with clean soil. According to the WaterWork letter of transmittal for the post-excavation soil sampling results, the material removed from the sump has been spread on-site and has been graded to prevent ponding. WaterWork also requested written authorization to backfill the excavation with clean fill material. POST-EXCAVATION SAMPLING RESULTS -2- 27 November 1989 FOR THE WHOLESALE FUELS, INC. POST-EXCAVATION SAMPLING RESULTS Eight soil samples were taken from the base of the excavation to verify that all contaminated material was removed. These samples were analyzed for PCBs, cyanide, and priority metals by BC Laboratories, a laboratory certified by the State for the analyses that were performed. The soil analyses indicated that there were no PCBs or cyanide found in any of the samples at a detection limit of 1.0 ug/g. The total metals concentrations measured in the sump, and after the removal of contaminated soils from the sump, are shown in Table 1. In 2 of the 8 samples, the detection limits were 5 times higher than the detection limits of the other samples, so a range is given in the table. TABLE Total Total Metals # Times Metals # Times ADWLs (mg/kg) ADWL (mg/kg) ADWL Metal (ma/l) ,(Before) (Before) (After) (After) Antimony 0.146 <6 0 <41 <5.0-<25 ND* Arsenic 0.05 <3 0 <60 2.27-4.49 45-90 Barium 1.0 181 4 181 ND* ND* Beryllium 0.0068 <0 60 <88 <0.5-<2.5 ND* Cadmium 0.01 4 0 400 <0.5-<2.5 ND* Chromium 170 16 5 0.1 15.2-25.8 0.09-0.15 Cobalt -- 4 3 ND* ND* ND* Copper 1.0 52 8 53 5.5-36.8 5.5-36.8 Lead 0.05 103 2060 <2.5-<12.5 124 Mercury 0.002 <0.20 <100 <0.1 <50 Molybdenum -- 4.3 ND* ND* ND* Nickel 0.150 21.5 143 7.03-<12.5 47-<83 Selenium 0.010 <2.0 <200 <0.5 <50 Silver 0.05 <1.0 <20 <0.5-<2.5 ND* Thallium 0.013 <6.0 <460 <5.0-<25 ND* Vanadium -- 30.0 ND* ND* ND* Zinc 5.0 495 99 53.1-78.8 11-16 *ND: Not determined Antimony, beryllium, mercury, selenium, silver, and thallium were not detected in either the sludge or in any of the post-excavation soil samples. The concentrations POST-EXCAVATION SAMPLING RESULTS -3- 27 November 1989 FOR THE WHOLESALE FUELS, INC. of metals that were found in the remaining soils are between 1.4-times and 41-times lower than the metals concentrations originally measured in the sump. As the table indicates, of the metals that were detected, the concentrations that were measured in the soil samples from the base of the excavation are between 0.09 and 124 times the Acceptable Drinking Water Levels. DISCUSSION The sampling results indicate the metals concentrations in the soils below the sump are between 0.09 and 124 times Acceptable Drinking Water Levels. These concentrations are within the ranges typically found in natural soils. Although the distance to ground water at the Wholesale Fuels, Inc. site is estimated to be 80 feet, low levels of metals occur naturally in soils and are present throughout the vadose zone. No soil samples were collected to determine "background" levels of metals in the soils at the subject facility. Nevertheless, metals tend to remain immobile and are not readily leached from soils of neutral (pH of about 7) or higher pH (alkaline). Some metals are not even completely soluble in weak acids. For example, although 103 mg/kg lead was measured in the sludge contained in the Wholesale Fuels, Inc. sump, no soluble lead (< 0.5 mg/1) was detected in the extract (pH of 5.0) from the Waste Extraction Test. The pH of the sludge contained in the sump was 7.0, and the Soil Survey of the Bakersfield Area, California, prepared in 1945 by the Soil Conservation Service and the University of California Agricultural Experiment Station, describes the soils at the Wholesale Fuels Inc. site as belonging to the Pond series, and consisting of Pond fine sandy loam. According to the Soil Survey, the Pond fine sandy loam soil contains large quantities of lime and salts and is micaceous throughout. In the southeastern part of Bakersfield, where the subject facility is located, the soil is also underlain below a depth of 30 inches by a platy layer of semi-hardpan lime accumulation. The layer is not impervious, however. Relatively low concentrations of metals are present in the soils at the base of the excavation, and the alkaline soil conditions at the subject facility are conducive to retaining metals in soil. Thus, it is unlikely that water quality will be affected by the metals in the remaining soils. Further excavation of soils, therefore, does not appear to be necessary to protect water quality. SUMMARY AND RECOMMENDATIONS After reviewing the post-excavation soil analytical results for the Wholesale Fuels, Inc. sump in Kern County, I have developed the following summary and recommendations: 1. The sampling results indicate that there were no PCBs or cyanide found in any of the samples at a detection limit of 1.0 ug/g. POST-EXCAVATION SAMPLING RESULTS -4- 27 November 1989 FOR THE WHOLESALE FUELS, INC. Following excavation, the concentrations of metals found in the remaining soils were between 1.4-times and 41-times lower than the metals concentrations originally measured in the sump, and are between 0.09 and 124 times the Acceptable Drinking Water Levels. Although no "background" soil samples were collected, the concentrations of metals are within the ranges typically found in natural soils. Because relatively low concentrations of metals are present in the soils at the base of the excavation, and the alkaline soil conditions at the subject facility are conducive to retaining metals in soil, it is unlikely that water quality will be affected by the metals in the remaining soils. Further excavation of soils is, therefore, not necessary to protect water quality, and backfilling of the sump with clean fill material should be allowed to proceed. 2. As requested in our review of the Closure Plan for the sump, documentation regarding the source of the clean fill dirt that is to be used to backfill the sump and the results from chemical analysis of the fill dirt need to be included in the final closure report. Upon completion of the backfilling and compaction, the area of the sump should also be graded to conduct storm runoff away from the sump. The grade should be of a sufficient slope to'prevent ponding over the backfilled sump. A review of the grading should be conducted one year after the completion of the backfilling of the sump to check for settling. RCH:rch