{"operation":"document","citation":"PI-20-0014","title":"Chemoil — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2025-07-21","effective_on":null,"summary":"PI-20-0014 response to Chemoil concerning 195.553.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-20-0014.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-20-0014.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-20-0014","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/76156/chemoil-pi-20-0014-01-10-2022-part-195553.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety Administration January 10, 2022\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMr. Matthew Williamson\nManatt, Phelps, and Phillips, LLP\n695 Town Center Drive, 14th Floor\nCosta Mesa, CA 92626\nDear Mr. Williamson:\nIn an October 23, 2020, letter to the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), you, on behalf of Chemoil Terminals Corporation and its affiliates (Chemoil),\nrequested an interpretation of 49 Code of Federal Regulations (CFR) Part 195. Specifically,\nChemoil requests an interpretation pertaining to the definition of the term “buried” in 49 CFR\n§ 195.553, and confirmation that certain breakout tanks located at Chemoil’s storage facility in\nCarson, California are not considered “buried” and, therefore, do not require cathodic protection\n(CP) pursuant to 49 CFR § 195.563(a).\nIn the letter, Chemoil states that it has five breakout tanks constructed between 2002 and 2008,\neach with a 4-inch fiber mesh concrete pad, 80 mil high density polyethylene (HDPE) liner\n(sloped to provide drainage to monitoring wells), and a sealed ring wall. Chemoil also states that\neach tank design considered corrosion control in accordance with API Recommended Practice\n(RP) 651 and API Standard 653.1 Chemoil asserts that because these tanks are not in contact\nwith the soil, they do not meet the definition of “buried” under § 195.553 and, therefore, do not\nrequire CP under § 195.563(a).\nSection 195.563(a) of the Federal Pipeline Safety Regulations requires each buried or submerged\npipeline that is constructed, relocated, replaced, or otherwise changed after the applicable date in\n§ 195.401(c) to have CP. The term “pipeline” expressly includes breakout tanks under § 195.2.\nSection 195.553 defines “buried” as “covered or in contact with the soil.” Accordingly, only\nbreakout tanks in contact with soil would be required to have CP under the regulations. Section\n195.583(a) of the regulations requires that each onshore pipeline that is exposed to the\natmosphere must be inspected for evidence of atmospheric corrosion at least once every three\nyears. If a breakout tank is not in contact with soil, operators must consider whether the tank is\n1 PHMSA notes that the designs submitted with this interpretation request may not be in compliance with\nAPI RP 651, 3rd edition, 2007, where Section 6 – Methods of Cathodic Protection for Corrosion Control and\nSection 7 – Design of Cathodic Protection Systems, states that no cathodic protection systems are effective in\nprotecting a HDPE liner if the HDPE liner does not completely and effectively protect the interface areas. API RP\n651 allows for usage of HDPE liners when the liners eliminate contact with soil and do not allow moisture to reach\nthe external bottom of the tank. API RP 651 describes a continuous concrete pad in Section 5.3.3.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nexposed to the atmosphere and, if so, comply with subpart H of Part 195 to monitor and\nremediate atmospheric corrosion.\nChemoil asserts that the entire footprint of each breakout tank is separated from the soil by a\nfiber mesh concrete pad, a HDPE liner, and a reinforced ring wall and sump foundation and,\ntherefore, there is no path for electrical current to travel from the soil to the tank. The designs\nsubmitted with Chemoil’s letter, however, show the tank HDPE liner does not extend past the\nedges of the tank and stops where the concrete pad and reinforced ring wall meet (interface area).\nThe drawings submitted by Chemoil do not show that the HDPE liner goes past this interface to\nensure that the tank is not in contact with soil or that it eliminates moisture from entering the\ninterface area. Actual inspection results provided by Chemoil show that at least one breakout\ntank developed corrosion on the bottom of the tank, indicating moisture was able to permeate\neither the concrete floor, the interface area, or from outside the reinforced ring wall. This\nmoisture penetration created a corrosive environment on the bottom of the breakout tank. Based\non the submission, it is unclear to PHMSA whether the tank is in contact with the soil since it\nappears that there is an electrolytic path to the tank bottom. Please see the footnote below for\napplicable sections of API RP 651.2\nIf Chemoil’s tanks are in fact not in contact with any types of soil, they would not be considered\n“buried” under the regulations. However, if the tanks are not in contact with soil and are\nexposed to the atmosphere, then Chemoil would be required to monitor the tanks for atmospheric\ncorrosion, pursuant to § 195.583. It appears, from the information provided, that there is an\nelectrolytic path to the tank floor bottoms, so the tanks may be in contact with soil by that path,\nor exposed to the atmosphere at the tank bottom interface area, which would require compliance\nwith either §§ 195.563 and 195.565, or § 195.583, respectively.\nAs mentioned above, your inspection results indicate that at least one of the breakout tanks\ndescribed has developed corrosion on the bottom of the tank. PHMSA notes that Chemoil is\nrequired to take corrective actions to remedy the corrosion in accordance with §§ 195.401(b),\n195.573(e) and 195.583(c).\n2 API RP 651, Paragraph 5.3.3.3 gives an operator the following information concerning installing a concrete pad\nunder an aboveground storage tank:\nDue to numerous complex factors that can affect the corrosion of a tank bottom underside in the presence of\nconcrete, prediction of the propensity of corrosion in this case is extremely difficult. Thus, care should be observed\nwith tanks on concrete pads since cathodic protection most likely will not help reduce any corrosion that might\noccur.\nAlso, API RP 651, Paragraph 5.3.3.2 states that “[i]n situations where water may condense on the tank bottom or\nwater is retained above the concrete pad, accelerated corrosion may occur.”The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\n3\nPHMSA provides written clarifications of the Federal Pipeline Safety Regulations (49 CFR Parts\n190-199) in the form of interpretation letters. These letters reflect the agency's current\napplication of the regulations to the specific facts presented by the person requesting the\nclarification. Interpretations do not create legally enforceable rights or obligations and are only\nprovided to help the public understand how to comply with the regulations.\nIf we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.\nSincerely,\nJohn A. Gale\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 4>>>\n\nMatthew Williamson\nManatt, Phelps & Phillips, LLP\nDirect Dial: (714) 371-2538\nMWilliamson@manatt.com\nOctober 23, 2020 Client-Matter: 66255-030\nVIA FEDEX\nMr. John A. Gale\nDirector, Office of Standards and Rulemaking\nOffice of Pipeline Safety (PHP-30)\nPipeline and Hazardous Materials Safety Administration\nU.S. Department of Transportation\n1200 New Jersey Avenue, S.E.\nWashington, D.C. 20590-0001\nRe: Request for Written Regulatory Interpretation\nDear Mr. Gale:\nI am writing on behalf of Chemoil Terminals Corporation and its affiliates (“Chemoil”)\nto request a written regulatory interpretation from the Pipeline and Hazardous Materials Safety\nAdministration (“PHMSA”). Specifically, Chemoil is seeking an interpretation pertaining to the\ndefinition of the term “buried” at 49 C.F.R. § 195.553, and confirmation that certain breakout\ntanks located at Chemoil’s storage facility in Carson, California are not “buried” under this\ninterpretation and therefore do not require cathodic protection pursuant to 49 C.F.R. 195.563(a).1\n49 C.F.R. § 195.553 defines the term “buried” to mean “covered or in contact with soil.”\nThe Final Rule establishing this definition stated the following: “The definition of ‘buried’\nreflects the common corrosion control practice of treating any portion of pipe in contact\nwith the soil as if that portion were buried.” Controlling Corrosion on Hazardous Liquid and\nCarbon Dioxide Pipelines, 66 Fed. Reg. 66995 (Dec. 27, 2001) (emphasis added).\nAt issue in this instance are five breakout tanks constructed in 2002 and 2008 with a 4-\ninch fiber mesh concrete pad, 80 mil HDPE liner (sloped to provide drainage to monitoring\nwell), and sealed ring wall. The design of the tanks considered corrosion control in accordance\nwith API Standards 651 and 653. This design was confirmed by William Johns, P.E., who\nreviewed the design of Chemoil’s tanks and concluded the following:\n1 Pursuant to 49 C.F.R. § 195.563(a), cathodic protection is only required for a “buried or submerged pipeline”, and\nthe term “pipeline” expressly includes breakout tanks. See 49 C.F.R. § 195.2.695 Town Center Drive, 14th Floor, Costa Mesa, California 92626 Telephone: 714.371.2500 Fax: 714.371.2550\nAlbany | Boston | Chicago | Los Angeles | New York | Orange County | Palo Alto | Sacramento | San Francisco | Washington, D.C.\n\n<<<PAGE 5>>>\n\nMr. John A. Gale\nOctober 23, 2020\nPage 2\nAt the time of construction of all the subject tanks, there was a\ngeneral trend, particularly in the local California tank storage\nindustry, to provide built-in secondary containment and leak\ndetection into the foundation of new tanks. The Chemoil tanks\nwere likewise constructed with a concrete subfloor and\nimpermeable liner (See attached drawing SK-1 which depicts the\nkey features of the design). . . All the tank foundations are\nbasically the same. Key features include steel reinforced concrete\nringwall and sump foundation, 80 mil HDPE liners, 4\" fiber\nreinforced concrete slab deck, cone down to sump, leak detection\npipe and inspection well, and double wall sump. . . The entire\ntank footprint is separated from the subsoil by the liner, 4\"\ndeck and the Reinforced Ringwall and sump foundation.\nSee Exhibit A, “Engineer’s Opinion Foundation – Cathodic Protection Design\nConformance of Breakout Tanks” (W. Johns, P.E., 2020) (emphasis added).\nChemoil requests an interpretation from PHMSA clarifying that where, as here, the tank\nfootprint is not in contact with soil, such tanks do not meet the definition of “buried” under 49\nC.F.R. § 195.553, and therefore do not require cathodic protection under 49 C.F.R. 195.563(a).\nPlease contact me at (714) 371-2538 or mwilliamson@manatt.com with any questions\nabout this request for written interpretation. We look forward to receiving further guidance on\nthis issue.\nSincerely,\nMatt Williamson\n326969247.2\n\n<<<PAGE 6>>>\n\nExhibit A\n\n<<<PAGE 7>>>\n\nCHEMOIL TERMINALS\nCARSON, CALIFORNIA\n@ CHEMOIL\nC-038292\nExp 331-21\n....\nCIVIL\nPrepared by\nWilliam R. Johns, P.E.\nCalifornia Civil Engineer\nC038292\nUtility Coordinating, Inc.\n(714) 462-8413\nUTILICOOR\nUTILITY COORDINATING, INC\n\n<<<PAGE 8>>>\n\nThis report identifies and clarifies the design features of the tanks. This report also\ndiscusses why the tank designs provide protection against shell bottom corrosion.\nReference Documents\nCited Reference Documents include the following:\nOSFM Notice of Probable Violations dated July 3, 2019\nChemoil Response to OSFM Notice of Probable Violation dated August 30, 2019\nOSCM Issuance of Final Order dated December 13, 2019\nOSFM Decision on Petition for Reconsideration dated April 13, 2020\nOriginal Construction Drawings (Tank & Refinery Services Co. -TARSCO) dated\ncirca 2002 and 2007\n•\nAPI 653 Inspection Report Tank 100006 dated September 20, 2019\nAPI 653 Inspection Report Tank 50006 dated June 25, 2020\n•\nFarwest Letter\nRelevant Codes and Standards\nBased on the construction dates of the subject tanks, the following codes, standards,\nand industrial practices are applicable:\n• 49 CFR Parts 195.563 and 195.565\nAPI 650, Welded Tanks for Oil Storage (10*h and 11\" Editions)\n• API 653, Tank Inspection, Repair, Alteration, and Reconstruction (2nd and 3rd\nEdition)\n• API 651, Cathodic Protection of Aboveground Petroleum Storage Tanks (3rd\nEdition)\nOCFM Violation Claim - EN 19-014 and Discussion\nIn the Final Order (Docket CA-2019013), the OSFM found that Chemoil violated\n49CFR195.563(a) by failing to provide an effective cathodic protection (CP) system to\nprotect the soil side of the tank floor (for the nine (9) breakout tanks) in accordance\nwith 49 CFR Part 195.595.\nAs presented in their letter dated August 30, 2019 and included as an Exhibit in the\n\n<<<PAGE 9>>>\n\n(CP) system because the tank bottoms are not on contact with the soil and the tank\ndesign is such that it should prevent the creation of a corrosion cell.\nTank Construction and Corrosion Protection System\nTank Foundation - At the time of construction of all the subject tanks, there was a\ngeneral trend, particularly in the local California tank storage industry, to provide built-\nin secondary containment and leak detection into the foundation of new tanks. The\nChemoil tanks were likewise constructed with a concrete subfloor and impermeable\nliner (See attached drawing SK-1 which depicts the key features of the design). The\nChemoil foundations were built, accordingly, and they conformed to the requirements\nof API-650 Appendix I (Undertank Leak Detection and Subgrade Protection) and API 651\n5.3. API 651 states \"A properly designed concrete tank cushion constructed on a stable,\nproperly prepared subsoil may be effective in eliminating intrusion of groundwater, soil-\nside corrosion, and the need for cathodic protection\".\nThe drawings for the subject tanks were reviewed for conformity to API standards and\nfor applicability to incorporate additional CP measures. The findings are as follow:\nAll the tank foundations are basically the same. Key features include steel reinforced\nconcrete ringwall and sump foundation, 80 mil HDPE liners, 4\" fiber reinforced concrete\nslab deck, cone down to sump, leak detection pipe and inspection well, and double wall\nsump.\nDetails for the subgrade foundation are not provided, however, since there is no\nindication of tank subsidence, it can be concluded that the foundation preparation was\nappropriate. The 80 mil liner was installed on a sand protection bed and details show\nproper connection to the preconstructed ringwall and sump foundation.\nThe 4\" thick fibermesh concrete mat was placed on top of the HDPE Liner using 3,000\npsi concrete. Fibermesh is a fiberglass reinforcement that is mixed into the concrete and\nprovided tensile strength for the concrete that prevents (temperature and shrinkage)\ncracking. The entire tank footprint is separated from the subsoil by the liner, 4\" deck\nand the Reinforced Ringwall and sump foundation. There is no path for water or\nelectrical current to travel from the soil to the tank To prevent the introduction of\nwater with possible soil particulates from entering the space between the impermeable\n\n<<<PAGE 10>>>\n\npreventing the tank bottom from becoming an anode. Following the guidance of API\n651, the foundation designs had no additional CP systems. Additionally, API 651 states\nthat \"cathodic protection most likely will not help reduce any corrosion that might\noccur\", therefore, installation of post-construction retrofit CP systems are not practical\nfor \"Continuous Concrete Cushion\" foundations.\nSecondary Containment/Leak Detection -The tank foundations are designed to prevent\nthe escape of product into the ground and provide indication of a leak in the primary\nfloor of the tank. The secondary containment barrier is a combination of the concrete\nslab and impermeable liner. The concrete layer is designed to contain and direct a leak\nfrom the tank to the double bottomed sump. The concrete has grooves leading to the\nsump. From the sump, a leak detection pipe flows down to a monitoring well outside of\nthe tank shell. The well can be monitored for liquid or vapors to determine the\npresence or absence of leaked product.\nPresent Tank Condition and Cathodic System Improvements\nPresent Tank Condition -Two of the tanks, 100006 and 50006 have had recent API 653\nOpen Tank Inspections performed. The findings of the reports by DJA Inspection\nindicate the corrosion of the tank bottoms after 17 years and 12 years of service. The\nresults are useful for identifying maintenance shortcomings and successes.\nTank 100006 Findings and Results - The bottom of Tank 100006 had significant pitting\nand bottom side corrosion. Based on the foundation design, the corrosion was beyond\nexpectations. Further investigation indicated that the Tank dike area was often used\nfor stormwater containment thereby allowing water to rise above the tank\nringwall/chime. This practice allowed muddy water to fill the gap between the\nconcrete slab and the tank bottom resulting in limited electrolysis.\nAs prevention to this corrosion, the following policy changes are required.\n• Install and maintain a flexible sealant between the tank chime and the concrete\nringwall\n• Do not allow storm water to exceed the height of the ringwall at any time.\nTank 50006 Findings and Results - The bottom of Tank 50006 had virtually no bottom\nside corrosion. Based on the foundation design, this was expected\n\n<<<PAGE 11>>>\n\nacceptable standards and industry practices. The foundation designs were in excess of\nthe basic requirements, and the use of the secondary containment/continuous\nconcrete slab were a proactive measure to limit deterioration of the tank bottoms and\nprevent releases. The claim that Chemoil failed to provide an effective cathodic\nprotection (CP) system to protect the soil side of the tank floor (for the nine (9)\nbreakout tanks in accordance with 49CFR195.595 is not valid for continuous concrete\nfoundation tanks with properly designed features. Installation of retrofitted CP\nsystems are not necessary and would be ineffective. It is recommended that Chemoil\nadheres closely with the requirements of API 653 and provide the recommended\nmaintenance policies to prevent future flooding of the tank dike areas and proper\nmaintenance of the ring wall and seal.\nDate\n1/24/20\nEngineer's Signature\nAbout the Engineer\nWilliam Johns is a practicing Engineer in the State of California. He has over 40 years of experience in design, construction,\nand management of Civil projects with an emphasis on petroleum pipelines, tankage, and transportation systems. Mr. Johns\nholds a Bachelor of Science degree from the University of California, Berkeley, and is a licensed Civil Engineer in California.\nMr. Johns has managed tank construction and repair projects for several oil companies throughout the southwest United\nStates. Projects include double bottoms, drain-dry sumps, earthquake (elephant footing) repairs, and construction of 21 new\ntanks at the (KMEP) GATX Terminal. Additional related coursework and certification includes:\nAPI 650 Course\n• API 653 Course and updates\n• TEAM (Formerly Tank Consultants, Inc.) Tank Design and Inspection\n• Numerous ILTA (Independent Liquid Terminals Association) Training Courses\n\n<<<PAGE 12>>>\n\n1'\n-3\"\n88'\n-6\" I.D. (44'\n-3\" I.S. RAD.)\n89'\n-0 3/4\" DIA. BOLT CIRCLE (44'\n-6 3/8\" RAIDUS)\n3 1/4\"\n1'\n-1 3/4\"\n1'\n-1 3/8\"\n3/4\"\n1'\n-0 5/8\"\n1'\n-1 3/4\"\n1'\n-1 3/8\"\n1'\n-0 5/8\"\n3/8\"\n3/4\" MIN.\nCHAMFER\n3\" CLR.\nDET. A\n12\n3/8\nSLOPE DOWN TO CTR.\nTANK BOTTOM\n2\n4\" THK. 3000 PSI\nFIBERMESH\nREINFORCED\nCONCRETE MAT\n(WITH TELL-TALE\nGROOVES)\nCenter Column along wit\nShell holds the entire Roof\nLoad. Load is ultimately\ntransferred to Reinforced\nConcrete Foundation\ninstalled at same time as\nSump\n15\"\nCENTER COLUMN\n3\nwith\nRoof\nly\nDUAL SUMPS\ned\nSEE DRAWING\nB3633-T6-03a\n3/4\"\nas\nDUAL SUMPS\nSEE DRAWING\nB3633-T6-03a\nOUTSIDE/SECONDARY SHELL INSIDE - CONTAINS PRODUCT\n5\nFits Inside of Secondary\n2\n3\n7\n7\n6\n4\n1\n3. SITE PREP, SUB-GRADE, & BACK FILL COMPACTION PER OWNER'S SPEC.\n3'\n-2 1/2\"O.S. RAD.\n3'\n-1\n3'\n-5\" O.S. RAD\n3'\n-1 3/8\" I.S. RAD.\n4. FOUNDATION, BAR BENDING & SPICES PER ACI 318 CODE.\n2'\n-9\"I.S. RAD.\n8\n8\n8\n7\nBITUMASTIC COAT BOTH SUMPS\nON THEIR EXTERNAL SURFACES\nPER NOTE 3.\n7\nBITUMASTIC COAT BOTH SUMPS\n10\nON THEIR EXTERNAL SURFACES\nPER NOTE 3.\n7'\n-4\"Ø\n6'\n-5\" Ø\n6'\n-3 1/2\" Ø\n10\n6'\n-2 3/4\" Ø\n7'\n-4\"Ø\n5'\n-6 3/4\" Ø\n5'\n-6\" Ø\n6'\n-5\" Ø\n4\n6'\n-3 1/2\" Ø\n6'\n-2 3/4\" Ø\n1\n2 3/4\"\n1/4 1/8\n60˚\n-4 5/8\"\n1'\n2 3/4\"\n2\n1/4 1/8\n3\n60˚\n1\n1/4\n1/4\n-3 5/8\"\n1'\n-4 5/8\"\n1'\n1/4\n3/8\"\n-3 1/4\"\n1'\n-3 5/8\"\n1'\n1\"\n5 1/8\"\n3/8\"\n5 1/8\"\n3/8\"\n1/4\n5'\n-6 3/4\" Ø\n5'\n-6\" Ø\n3/8\"\nTACK\nWELD\n-3 1/4\"\n1'\nTACK\nWELD\n9\n7\n1/4\n1/4 1/8\n60˚\nR\n1/4 TYP.\n7\n1/4 1/8\n60˚\n6\n8\n2\n3\nSECONDARY SUMP\nSECONDARY SUMP\n1/4\n1/4\n1\"\n3 1/2\"Ø HOLE FOR\n1/4\n2\n3\" SOCKET COUPLING\n1/4 TYP.\n1/4\n1/4\n1/4\n1/4\nFOR 2\" HDPE DRAIN\nPIPE. SEE INSTALLATION\n3 1/2\"Ø HOLE FOR\nDETAILS ON DWG. B3633-T6-03a & b.\n5\n6\n9 7\n8\n5'\n-7 1/2\" Ø\n5\nPRIMARY SUMP\n5'\n-7 1/2\" Ø\n2\n3\" SOCKET COUPLING\nFOR 2\" HDPE DRAIN\nPIPE. SEE INSTALLATION\nPRIMARY SUMP\nDETAILS ON DWG. B3633-T6-03a & b.\nSUMP CONSTRUCTION\nDUAL SUMPS\nSEE DRAWING\nB3633-T6-03a\n3/8\"\n1/4\n3 1/4\"\n1/4\n3/8\"\n4\"\nR 1 1/2\"\n3/8\"\n8\nTYP\n3/16\n6 REQ'D.\nEQ. SPACED ON\n2'\n-10 15/16\" ON ARC\nGRIND ALL\nEDGES & CORNERS\nSMOOTHLY\nSUMP CONSTRUCTION\n1\n2'\n-6\"\n3\" CLR.\n80 MIL HDPE\nMOISTURE BARRIER\n4\" THK. CLEAN SAND\n(IF NEEDED FOR PROPER\nLINER INSTALLATION)\n1\nCOMPACT SUB-GRADE\nPER OWNER'S SPEC\n#4 TIES @ 12\" C.C.\n10 #7 CONT. HOOPS\nTOP AND SIDES\nLEAK DETECTION PIPE\nTO OBSERVATION WELL\nSEE B3633-T6-03b\n2'\n-7\"\n1\n13 #4, A615-60 BARS\nBOTH WAYS\nTYP. TOP & BOTTOM\n(EQUALLY SPACED)\n7 #8 CONT. HOOPS (BOTTOM)\n3\" CLR. 3\" CLR.\n3'\n-9\"\n3\" CLR. TYP.\n83'\n-6\" I.D. (41'\n-9\" INS. RAD.)\n3\" CLR. TYP.\n9'\n-0\" SQUARE\nREVISED DRAW\n03-2\nDATE:______\n-\n_\nSUBMITTAL #_\nLIMITS OF CONCRETE\n91'\n-0\" O.D. (45'\n-6\" O.S. RAD.)\nCHEM\nP.O. NUMB\nIMPERMEABLE LINER LIMITS\nUM\nCONSTRUC\nING - DESTROY ALL PREV\nCONSTRUCTION PHASING\n- DESTROY ALL PREVIOUS ISSU\n2-07\n_____________\n1 COMPLETED SUM\n22-07\nSECONDARY SHE\n______________\n1 COMPLETED SUMP (INSIDE AND\nINPLACE AFTER C\nSECONDARY SHELLS) ARE CAST\nPREPARATION. R\nINPLACE AFTER COMPLETION OF SOIL\nCONSTRUCTED A\nPREPARATION. RING WALL IS\nCONSTRUCTED AT SAME TIME.\n03-2\n________ DATE:______\nPRODUCT ZONE\nFLEXIBLE\nSEALANT\nSECONDARY CONTAINED ZONE\nCUSTOMER IDENTIFICATION\n03-20-07\n________ DATE:_____________\nOIL TERMINALS C\nMB\n2 AFTER COMPLE\nCUSTOMER IDENTIFICATION\nRINGWALL, THE\nBER OIL TERMINALS CORP\nUM\n2 AFTER COMPLETION OF SUMP AND\nJOB N\nINSTALLED ON S\nRINGWALL, THE HDPE LINER IS\nMBER JOB CONSTRUCTION\nNUMBER\nINSTALLED ON SAND BED.\nREINFORCED P\nCONSTRUCTION OF 4\" FIBER\nREINFORCED PAD IS THEN PLACED\n3\n3\nTANK BOTTOM\nTANK BOTTOM AND CENTER COLUMN\nIS CONSTRUCTED ON FINISHED SLAB\nFOUNDATION\nCONCRETE\nSOIL - FOUNDATION INTERFACE\n(SOIL ISOLATED BY HDPE AND CONCRETE)\nDET. A\nFLOOR -RINGWALL SEALANT\n1\nTANK FOUNDATION EVALUATION\nCHEMOIL CARSON\nTERMINAL\n7/6/20\nSCALE __________________ DATE __________\nSCALE\nDRAWING No.\nDR. ______ CH. DR. APP\nWRJ WRJ\n__________\n__________\nSHT. REV.\nSK-01\n\n<<<PAGE 13>>>\n\nadditional (non-breakout) tank at the Chemoil Carson Facility. The Open Tank inspections had\nfull MFE (Magnetic Flux Exclusion) surveys performed on each tank bottom to determine\nmetal loss.\nIn addition to the API 653 inspections of Tanks 100006 and 50006 cited in the Engineer's\nOpinion Report, the following tanks were inspected in accordance with API 653.\n• Tank 20003, July 2020\n• Tank 20002, August 2020\n• Tank 100005, September 2020\n• Tank 50005, October 2020\nDJA Inspection performed the tank inspections and prepared the reports. The bottoms of Tanks\n100005, 50005, 50006, 20003, and 20002 were found to have virtually no bottom side\ncorrosion. Each DJA Inspection reports stated \"The MFE scan found no indications of soil side\ncorrosion\". The results of these additional inspections confirm that the concrete base with an\nimpermeable liner underneath resists underside corrosion and no additional cathodic\nprotection is required.\nWiRQ\nDate\nOctober 22, 2020\nEngineer's Signature\nSATE OF CALFORILIA\nC!V!!.\n10-22-20\nO CHEMOIL\nUTILICOOR\nUTILITY COORDINATING, INC","truncated":false,"body_characters":25100}