DERR-2025-000751

Formal External Inspection Report for
Aboveground Storage Tanks (ASTs)

Compass Minerals Mine Facility
765 North 10500 West
Ogden, Utah 84404

RMEC PJ24E-4988

December 6, 2024

Prepared For:
Compass Minerals
765 North 10500 West
Ogden, Utah 84404

Tanks T190, T156, & T155 (from the east)
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DOCUMENT CONTROL
FORMAL EXTERNAL INSPECTION REPORT FOR ABOVEGROUND STORAGE TANKS
COMPASS MINERALS – FUEL ISLAND ASTs (OGDEN, UTAH)
PROJECT NUMBER: PJ24E-4988
PREPARED FOR:
Compass Minerals
765 North 10500 West
Ogden, Utah 84404

ATT: Holly Hurst
PREPARED BY:
RMEC Environmental, Inc.
476 W. 325 South
Bountiful, Utah 84010

t: [phone]
e: [e-mail]
AUTHOR(S):
Paul Flanagan
Environmental Scientist
(STI AST Inspector #AST-6730)
RMEC Environmental, Inc.

11/26/2024
Signature Date

REVIEWER(S):
Cody Paul
Environmental Project Manager/
Certified AST Inspector
(STI AST Inspector #AST-11220)
RMEC Environmental, Inc.

12/6/2024
Signature Date

REVISION HISTORY:
Revision Number Date Issued Reason/Comments:
00 December 6, 2024 INITIAL ISSUE

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APPENDICES
APPENDIX A – Physical Inspection Details
APPENDIX B – UT Testing Forms
APPENDIX C – Physical Inspection Findings Spreadsheet(s)
APPENDIX D – Photo Log
TABLE OF CONTENTS
1.0 INTRODUCTION ............................................................................................................................. 1
2.0 INSPECTION PROCEDURES, METHODS, AND MATERIALS ............................................. 2
2.1 Tank Shell Integrity Testing ........................................................................................................ 2
2.2 Physical Inspection ...................................................................................................................... 2
2.3 Records Review ........................................................................................................................... 3
3.0 GENERAL SITE AND TANK DESCRIPTIONS .......................................................................... 4
3.1 Tank Categorization .................................................................................................................... 4
4.0 INTEGRITY TESTING RESULTS ................................................................................................ 6
5.0 PHYSICAL INSPECTION RESULTS ........................................................................................... 7
6.0 SUITABILITY FOR CONTINUED SERVICE ............................................................................. 8
7.0 INSPECTION AND RECORDKEEPING REQUIREMENTS .................................................. 10
8.0 DEVIATIONS AND RESTRICTING CONDITIONS ................................................................ 10
9.0 LIMITATIONS AND EXCLUSIONS OF WARRANTY ........................................................... 10
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1.0 INTRODUCTION
RMEC Environmental, Inc. (RMEC) was contracted by Compass Minerals to conduct a Formal External
Inspection (FEI) of the aboveground storage tanks (ASTs) listed below in Table 1, which are located at the
Compass Minerals Mine facility in Ogden, Utah.
Table 1: Basic Description of the Subject ASTs
AST Name/
Description
Nominal Capacity
(gallons) Contents Shape & Orientation
T155 6,000 Red Diesel #2 Horizontal, Cylindrical
T156 10,000 Red Diesel #2 Horizontal, Cylindrical
T190 10,000 Unleaded Gasoline Horizontal, Cylindrical
Additional Details
All three ASTs are situated on concrete housekeeping pads in a bulk fuel storage area located between
two separate fuel dispensing islands. The ASTs supply fuel to mine trucks and various other site-
specific vehicles as they perform their daily operations.
AST Contents Classifications
Unleaded Gasoline is considered to be a Class IB Flammable Liquid for the purposes of this FEI.
Diesel fuel is considered to be a Class II Combustible Liquid.
RMEC Certified AST Inspector, Paul Flanagan, conducted this work. Mr. Flanagan is a Certified AST
Inspector with the Steel Tank Institute (STI) (Inspector #AST-6730). The FEI fieldwork was completed on
October 24, 2024.
The purpose of this report is to summarize the FEI findings and recommendations, including a
determination regarding “suitability for continued service.”

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2.0 INSPECTION PROCEDURES, METHODS, AND MATERIALS
The July 2002 revision of the U.S. Environmental Protection Agency's (EPA's) Spill Prevention Control
and Countermeasure (SPCC) Act set forth new inspection requirements that apply to certain ASTs. Under
40 CFR 112.8(c)(6), applicable facilities must have appropriately qualified personnel test or inspect each
aboveground container on a regular schedule in accordance with industry standards. The revised SPCC
rules specifically reference STI SP001, Standard for the Inspection of Aboveground Storage Tanks, as one
of the industry standards for conducting AST inspections.
This inspection was performed in accordance with the “Formal External Inspection (FEI) Guidelines”
outlined in the 7th Edition (February 2024) of the STI SP001 standard.
Application of the STI SP001 standard for a given AST includes two main components: (1) an evaluation
of the integrity of accessible tank shells and (2) a physical inspection of the AST and the associated tank
system (i.e., containment areas, piping, appurtenances, and other components). In support of these two
tasks, it is helpful to review all construction, inspection, repair/alteration, and compliance records (if
available) associated with the AST.
2.1 Tank Shell Integrity Testing
In accordance with the STI SP001 FEI Guidelines, RMEC utilized ultrasonic thickness (UT) testing to evaluate
tank shell integrity. UT testing is a non-destructive testing methodology that allows the tank system to remain
in service during the measurements.
UT measurements were taken with an Olympus™ MG2-DL UT corrosion-type/residual thickness gauge
with an Olympus™ D7906-SM transducer and Sonotech™ UT-X glycerin-based couplant. Field
calibrations were performed prior to testing using a mild steel calibration block as a standard reference.
The UT measurements are intended to establish a general rate of shell corrosion on the interior surface of the
tank shells while also potentially identifying areas of flaws, defects, or excessive corrosion. Where possible,
RMEC took external UT measurements around (or along) the accessible low points of the AST—where
water would most likely be present inside the AST and result in corrosion.
The accessible tank shell areas for UT measurements were divided into grids comprised of 1-foot square
sections. RMEC operated the UT gauge in “B-scan” mode, which allows for hundreds of measurements
within each section and helps the inspector to potentially identify areas of acute thickness loss.
In the absence of tank tags or other forms of documentation showing the original AST shell thickness, an
approximate original thickness for the AST is determined by measuring shell thickness in other areas that
are less likely to be reduced by corrosion, such as the upper portions of the tank shell or the tank roof.
2.2 Physical Inspection
The physical inspection involves both a visual and “hands on” evaluation of the overall tank/tank system ,
along with all associated components and appurtenances. The intent is to verify the current condition,
operability, and construction of those components, as well as to determine any applicable code deficiencies
or design flaws in the setup of the tank/tank system. Specialized chemical products and tools are used,
where appropriate, to facilitate these efforts.
Tank/Tank system features that are physically inspected may include, but are not limited to, the following:
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▪ Primary tank shell and coatings
▪ Tank supports and/or pads
▪ Tank foundations and anchors
▪ Tank gauges and alarms
▪ Ports and other tank openings
▪ Normal and emergency vents
▪ Secondary containment structure
▪ Release prevention barriers
▪ Spill control and overfill protection
systems
▪ Piping and valves
▪ Drains and fittings
▪ Electrical equipment and gauges
▪ Bonding and grounding systems
▪ Stairways, ladders, and platforms
▪ Emergency equipment
RMEC references and applies certain regulatory and industry standards as part of the physical inspection.
For tank systems, these primarily include fire codes, but may also include building codes, construction
standards, tank standards, environmental regulations, inspection standards, or other similar standards that
are found to be applicable.
Based on the location and onsite AST uses, the following fire codes were primarily referenced as part of
the physical inspection for this FEI:
• National Fire Protection Association (NFPA) 30: Flammable and Combustible Liquids Code (2021
edition)
• National Fire Protection Association (NFPA) 30A: Code for Motor Fuel Dispensing Facilities and
Repair Garages (2021 edition)
• International Fire Code (IFC) (2021 edition)
It should be noted that the local or state-level fire marshal is designated as the authority having jurisdiction
(AHJ) over the site and is the only person allowed to make changes or amendments to these requirements.
2.3 Records Review
Records associated with the tank/tank system, including drawings, construction plans, inspection checklists,
former inspection reports, repair/alteration records, purchase orders, site procedures/plans, and other similar
documents were requested for review. Any records that were provided are summarized in Table 2.
Table 2: Summary of Records Reviewed
Record Name/Type Details Provided
Spill Prevention, Control, and
Countermeasure (SPCC) Plan
RMEC was provided with an SPCC that various oil storage
containers and other systems present at the facility. However, the
SPCC had no specific information regarding the three subject
ASTs.

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Fuel Island (Ogden, Utah) – ASTs

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3.0 GENERAL SITE AND TANK DESCRIPTIONS
Table 3 provides general details about the facility and the location of the subject ASTs.
Table 3: Facility and AST Location Details
Facility Details
The Compass Minerals Mine is located along the northeast shore of the Great Salt Lake, west of
Ogden, Utah. The site is an active mine collecting salt, magnesium and other minerals from the Great
Salt Lake.
The facility has multiple bulk storage containers and tanks; however, RMEC was only tasked with
inspecting the three fuel island tanks located north of the administrative and storage buildings. All
ASTs listed below were included in this FEI.
AST Name/
Description Tank Area Location within the Tank Area
T155 Main Fuel Island Storage Area Northernmost Tank
T156 Main Fuel Island Storage Area Center Tank (South Diesel Tank)
T190 Main Fuel Island Storage Area Southernmost Tank
Additional Details
The subject ASTs are located in a fuel storage tank area at the north end of the main property. Each
AST is set upon individual concrete housekeeping pads, which are themselves set upon native soils. A
basic, black plastic liner is also present under the concrete pads.
The ASTs are supplied via a fill station with spill buckets to the southwest. Fuel is pumped by the
delivery trucks. Dispense piping passes between the tanks and enters an underground vault where the
piping splits and delivers fuel to two separate fuel dispensing islands (Southwest and North).
3.1 Tank Categorization
Under the STI SP001 standard, all ASTs are categorized into one of three categories, which are based on
the inherent risk of tank failure. A “Category 1” AST has the least degree of risk; a “Category 3” AST has
the most degree of risk.
Tank categorization is primarily determined by whether the tank/tank system has the following:
1) a spill control method
2) a continuous release detection method (CRDM)
Spill control is most commonly achieved by providing secondary containment, either through inherent
design or with diking. CRDM is typically achieved through placement of the AST on an impermeable liner
or surface where releases of products would accumulate (or be directed away from the AST) and be visible
for detection by site personnel.
Generally, a Category 1 AST has spill control and CRDM; a Category 2 AST has spill control but no
CRDM, and a Category 3 AST has no spill control (regardless of CRDM).
Spill control and CRDM may also be present as part of an AST’s construction and fabrication standard.
Prior to initiating the inspection, RMEC attempts to determine the applicable construction standard for the
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AST. If no construction standard is apparent or it cannot be easily determined, then the Underwriters
Laboratory (UL) 142 standard—Steel Aboveground Tanks for Flammable and Combustible Liquids—is
applied for purposes of completing the inspection.
Table 4 includes a summary of the applicable construction/fabrication standard (including construction
date) for the subject ASTs and the intended STI SP001 tank category based on the presence or absence of
spill control and CRDM.
Table 4: AST Fabrication Standard and STI SP001 Categorization
AST Name/
Description
AST Fabrication
Standard
Spill Control
Details CRDM Details
Applicable
AST
Category1
T155 UL 142 (applied) Double-Wall Elevated AST 1
T156 UL 142 (applied) Double-Wall Elevated AST 1
T190 UL 2085 Double-Wall Elevated AST 1
Additional Details
Both of the diesel tanks (T155 & T156) have basic tank tags indicating they were constructed to an
unspecified UL standard. Because the tags are severely corroded and weathered, the exact fabrication
standards and manufacturing dates could not be determined. However, RMEC was able to verify that
they are steel double-walled ASTs.
T190 is equipped with a basic tank tag indicating it was constructed by a subsidiary of Modern
Welding Company in 2008 to a UL 2085 standard.
1 Based on tank configurations presented in Table A2.2 of the STI SP001 standard
Regarding the criteria that impacted the AST categorization determinations listed in Table 4, please refer
to the field observations presented in Appendix C.
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4.0 INTEGRITY TESTING RESULTS
Table 5 summarizes some of the important details and results from the UT measurements. A UT Tank
Testing Field Form was completed for each AST (they are available in Appendix B for review) and shows
the average and minimum thickness readings for each square-foot grid that was measured.
Table 5: Summary of UT Testing Results
AST Name/
Description
Original
Thickness1
(inches)
How Original Thickness
Determined
Current
Min.
Thickness1,2
(inches)
% Max.
Thickness
Loss
T155 0.200 Estimated From “Spot
Check” Readings 0.137 31.5%
T156 0.200 Estimated From “Spot
Check” Readings 0.139 30.5%
T190 0.250 Estimated From “Spot
Check” Readings 0.202 19.2%
1 UT readings were performed in “Thru-Coat” mode, which records and automatically compensates for paint thickness.
2 Current Minimum Thickness is the thinnest individual reading found throughout the course of integrity testing.
Each UT Field Form also includes corrosion projections based on the current minimum thickness reading.
Corrosion rates were calculated using the minimum thickness readings compared to the AST’s known or
estimated age in years.
It should be noted that the corrosion projections shown on the UT Field Form are conservative estimates
based on UT measurements only from the day of inspection. Actual corrosion rates can accelerate
depending on environmental conditions, the presence of water, and equipment maintenance, among many
other factors.
A detailed discussion of the UT results and a determination regarding suitability for continued service is
provided in Section 6.0.

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5.0 PHYSICAL INSPECTION RESULTS
As discussed in Section 2.0, the FEI involves a thorough inspection of many tank/tank system features.
General guidelines for the various inspection categories are provided in Appendix A. RMEC has also
prepared a Physical Inspection Findings Worksheet (attached in Appendix C) that presents the findings,
observations, deficiencies, and recommendations for each inspection category. Where applicable, photos
for each finding are noted on the worksheet and a Photo Log for all site photos is provided in Appendix D.
Table 6 lists a summary of the physical inspection categories or sub-categories that were found to be either:
(1) out of compliance with regulatory requirements or (2) found to have critical deficiencies (refer to
Section 6.0 for additional details).
Table 6: Physical Inspection Findings, by Category
Inspection Date(s)
October 24, 2024
AST Name/
Description Inspection Category Type of Deficiency1
T155, T156,
and T190
(collectively)
SPCC Plan The site’s SPCC does not include any information regarding
the subject ASTs.
Bonding System No permanent bonding system exists for fuel transfers.
Markings/Labeling All piping must be adequately labeled with contents and
direction of flow.
Fire Safety Valves Fire safety valves are required.
Atmospheric Venting Vents sizes must meet or exceed the size of supply lines
Overfill Protection Install high level alarm and automatic shutoff functions that
activate at 90% and 95%, respectively.
Emergency Response
Equipment
An emergency shut off function is no present at the
southwest fuel island.
1 Critical deficiencies, if present, are noted in red.

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6.0 SUITABILITY FOR CONTINUED SERVICE
Section 10.0 of the STI SP001 Standard states the following:
“Evaluation for suitability for continued service is a result of Formal External and/or Internal
Inspections performed by a Certified Inspector. This section of the STI standard identifies certain
conditions and recommended actions to be taken by the owner as a result of these inspections.”
Specific critical conditions that factor into the determination of whether a given AST is suitable for
continued service include, but are not limited to, the following:
▪ Significant shell thickness loss, degradation, or corrosion-related damage
▪ Noted evidence of microbial-induced corrosion (MIC) inside the AST
▪ Significant AST damage (known or suspected) requiring repairs
▪ Visible signs of leaks that cannot be resolved without removing the AST from service
▪ Lack of adequate emergency relief venting
▪ Damaged or non-compliant electrical systems that may create an imminent ignition source
Ultimately, the above-listed critical conditions indicate substantial changes from the original physical
condition of the tank/tank system and, therefore, need immediate attention.
Regarding the integrity testing discussed in Section 4.0, the need to take a given AST out of service to be
repaired or replaced is dependent on the extent of damage and the respective tank category. Generally,
repairs or replacement are required when the following corrosion levels have been determined:
▪ Category 3 ASTs – 75% of original thickness at any point
▪ Category 2 ASTs – 75% of original thickness in >3 square inches of any 1-foot square section, or
50% of original thickness at any point
▪ Category 1 ASTs – 50% of original thickness in >3 square inches of any 1-foot square section, or
25% of original thickness at any point
When the above-listed critical corrosion intervals have not yet been reached for a given AST, RMEC uses
the current calculated corrosion rate to estimate when (in number of years) they are expected to be reached.
Those projections are presented on the applicable UT Tank Testing Field Form in Appendix B.
Per the STI SP001 standard, all ASTs should be inspected at regular intervals. At a minimum, periodic
(e.g., monthly and annual) basic inspections are required to be conducted by the owner’s inspector, which
is defined as “the owner or owner’s designee … [that is] knowledgeable about storage facility operations,
the type of AST and its associated components, the spill control system for the facility, and characteristics
of the liquid stored. Owner’s inspectors must also be familiar with pumping, piping, and valve operations
of the AST.”
In addition to the periodic inspections described above, all ASTs should be formally reinspected by a
certified inspector at designated intervals. This reinspection interval is based on the findings from the FEI
(with special consideration for any corrosion determined during integrity testing), the AST capacity, and
the respective tank category. The maximum reinspection intervals are listed in Table 5.5 of the STI SP001
standard. Category 3 ASTs, for example, have a maximum reinspection interval of 10 years; Category 1
ASTs have a maximum interval of 20 years.
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If the FEI discovers any significant adverse conditions—whether through integrity testing or the physical
inspection—the certified inspector may determine that a shorter reinspection interval is required. Further,
in situations where an AST is repaired to correct an adverse condition, the STI SP001 standard requires a
formal reinspection within 5 years (and every 5 years thereafter until the adverse condition has proven to
be fully corrected or stabilized).
Given the information presented above, and with consideration for the integrity testing results and physical
inspection findings (see Sections 4.0 and 5.0), Table 7 lists RMEC’s determination of the suitability for
continued service for the inspected ASTs. The recommended next formal reinspection year is also provided.
Table 7: Suitability for Continued Service Determination and Reinspection Intervals
AST Name/
Description
Suitable for
Continued Service?
Repairs
Required?1 Next Formal Inspection2
T155 YES No
As a Category 1 AST getting periodic (e.g.,
monthly and annual) inspections, and based on
the current corrosion rates observed, the next
recommended FEI would be in 2039.
T156 YES No
As a Category 1 AST getting periodic (e.g.,
monthly and annual) inspections, and based on
the current corrosion rates observed, the next
recommended FEI would be in 2039.
T190 YES No
As a Category 1 AST getting periodic (e.g.,
monthly and annual) inspections, and based on
the current corrosion rates observed, the next
recommended FEI would be in 2044.
1 Repairs might be required if any critical deficiencies described in this section have been observed or assumed.
2 Based on Table 5.5 of the STI SP001 standard or the certified inspector’s professional judgement.
Please note that any AST determined to be suitable for continued services assumes that periodic inspections
(discussed previously) will be conducted, as required, by the owner’s inspector.
Further, regarding any other compliance deficiencies or recommendations presented in the Physical
Inspection Findings Worksheet (see Appendix C), RMEC encourages the owner/operator to properly
address those items to ensure safe and compliant operation of each AST.
However, it should be noted that the ultimate determination for what findings and recommendations should
be acted upon is the responsibility of the tank owner/operator. Environmental pollution risks, liabilities,
operational impacts, compliance with listed standards, and other recommendations provided in this report,
should all be given serious consideration by the owner/operator in making determinations regarding the
operation and management of a given AST and its system.
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7.0 INSPECTION AND RECORDKEEPING REQUIREMENTS
Per STI SP001 and best management practices, the following records should be maintained and retained by
the owner/operator for at least the listed interval:
Record Minimum Retention Time
All AST modification and repair records Life of the AST system
Monthly inspection checklists 36 months (3 years)
Annual inspection checklists 36 months (3 years)
Certified formal inspection reports Life of the AST system
8.0 DEVIATIONS AND RESTRICTING CONDITIONS
RMEC is not liable for any deviations or restricting conditions encountered in the performance of this
inspection.
Unless indicated in this report, there were no aspects of the STI FEI standard that were either not applicable
to the scope and purpose of this inspection or were not performed due to restricting conditions at the time
of the inspection.
9.0 LIMITATIONS AND EXCLUSIONS OF WARRANTY
Please note that these inspection services were performed in accordance with the STI SP001 FEI standard,
using practices consistent with standards acceptable within the industry at this time, and at a level of
diligence typically exercised by STI SP001 inspectors performing similar services. In performing these
services on a time and materials basis, RMEC tries to establish a balance between the competing goals of
limiting investigative and reporting costs and time while reducing the uncertainty about unknown
conditions that may be associated with a given AST. Because the findings of the inspection were derived
from a limited scope of work, the findings from the inspection should not be construed as a guarantee that
all conditions of any inspected AST and associated components, equipment, and/or buildings have been
evaluated.
This report presents RMEC’s professional opinion and judgment, which are dependent upon information
obtained from site personnel at the subject facility during the performance of these services. RMEC will
assume no responsibility for omissions or errors resulting from inaccurate information or data provided by
sources outside of RMEC, including omissions or errors in information from the AST owner(s) and their
employees or other representatives. Activities or events that transpire after this inspection that result in
adverse environmental, construction, and/or engineering impacts should not be construed as relevant to this
study. RMEC expressly disclaims any responsibility or obligation to report the findings of this inspection
to any third party, including but not limited to: the owner(s) of the inspected AST(s), any current or
prospective operator(s) or purchaser(s), or any federal, state, or local governmental agency or other
authority or entity having jurisdiction over the AST(s). RMEC will make no warranty or guarantee of any
kind, expressed or implied, regarding the findings, conclusions, or recommendations contained in the final
report.

APPENDIX A
GENERAL PHYSICAL INSPECTION GUIDELINES

Documentation/Recordkeeping
According to STI SP001, periodic inspections (i.e., monthly and annual) are to be completed by a
responsible site employee that is knowledgeable about the facility operations, the type of AST and its
associated components, and characteristics of the liquid(s) stored. These inspections are intended to
manage the condition of the AST system, as well as identify signs of existing or pending system failures.
Templates for both monthly and annual inspections—which are based on the inspections developed by
STI—are available from RMEC, upon request.
In addition to this, site owners are required to maintain any records of repairs, tests, or modifications.
Other relevant documents, including SPCC plans, engineering drawings, tank specification sheets, and
product inventory records were also requested to assist with the inspection.
Fabrication Standards
It is important to verify that the AST is being used in a manner that is consistent with its intended design.
ASTs used for storage of petroleum and oils are generally manufactured to an applicable industry standard
and a first step in the inspection process is to verify the appropriate tank fabrication standard. Tank tags
will typically provide this information along with other details such as manufacturer, construction date,
dimensions, tank capacity, and shell thickness, along with other pertinent information. The fabrication
standard will be used as a baseline for the physical inspection and any fabrication discrepancies and/or
signs of modifications or repairs to the tank structures must be noted in the inspection process.
Tank Location/Siting
Specific fire code requirements apply to the location of tanks in relationship to property lines, public rights-
of-way, and adjacent tanks, containment walls, buildings, and structures. These requirements are generally
based on the tank capacity and classification of the substances being stored.
Tank Foundations and Supports
Foundations and supports are inspected to determine their condition and whether they meet minimum
structural and fire code requirements. Other considerations, such as anchoring of the tank, may also be
required for areas subject to natural disasters, flooding, or conditions that may affect the stability of the
tank.
Secondary Containment
Secondary containment is typically designed to provide containment for the entire capacity of the largest
single AST; for open-top dikes, it also should include sufficient freeboard to contain precipitation (usually
10%) while allowing for the displacement volume of other structures or ASTs within the containment.
Secondary containment systems are inspected for appropriate design, breaches, evidence of deterioration
or disrepair, general condition, containment volume/capacity, and drainage capability.
Grounding, Bonding, and Cathodic Protection
Grounding and bonding of ASTs and their associated product piping and dispensing systems are designed
to reduce the risk of explosion due to electrical ignition sources such as static discharge or lightning strikes.
Cathodic protection systems are generally required when any part of the tank system is in contact with

soils. The inspection includes an evaluation of the design, operability, and general condition of the
grounding, bonding, and cathodic protection systems for the AST.
Tank Heads, Shells, and Coatings
The integrity and general condition of the AST shells/heads is one of the most critical components of the
tank system. In addition to non-destructive testing (NDT), the primary tank shells, along with the tank pads,
plates, welds, and coatings, are inspected for indications of exterior corrosion, buckling, and/or distortion
from stress or impact, cracking, spalling, pinholes, and mechanical damage.
The inspection also includes determining whether water is present inside the AST. Water in the AST
indicates that the system is not sealed and/or venting properly and can lead to accelerated deterioration of
the tank shell.
Tank Openings
All manways, ports, and other openings on the tank are inspected and diagrammed. Openings with flanged
connections are checked to ensure that they are properly bolted and free of visible signs of leaks or product
weeping. Other connections are inspected to verify that they are sufficiently sealed to prevent intrusion of
moisture, debris, or other foreign objects.
Product Piping and Valve Systems
The inspection includes a visual assessment of all product piping, fittings, valves, and connections and
whether they were designed properly and compatible for the materials being handled. Piping
configurations are also evaluated for points where product siphons could occur and locations where
product expansion could result in pipe ruptures. Valves are checked for operability, location, and use in
conformance with regulatory requirement. Both piping components and valves are inspected for material
compatibility and visible signs of stress or leakage such as severe corrosion or poor connections.
Tank Dispensing and Loading Systems
The inspection includes an evaluation of the connection points and any associated product pumping systems
that are used to transfer product into and out of the subject ASTs. Also noted are the dispensing/loading
procedures and equipment used to distribute product.
Atmospheric/Normal Venting
The purpose of the atmospheric, or “normal,” vent is to allow the tank to breathe under normal conditions
such as filling, draining, and temperature/pressure changes. The inspection includes an evaluation of the
design, operability, and general condition of the atmospheric venting components.
Emergency Venting
Emergency vents are used to prevent an AST from becoming over-pressurized during abnormal conditions,
such as a fire or blockage of the normal/atmospheric vent. Emergency vents are generally designed to
actuate and allow rapid venting of the AST when a predetermined internal tank pressure is reached. The
inspection includes an evaluation of the design, operability, and general condition of the emergency vents
and associated components.

The required emergency venting capacity for an AST is calculated by determining the “wetted” area, which
is the area of the tank that would likely be exposed to a fire. Once the wetted area is calculated, Table
22.7.3.2 of the NFPA 30 standard is used to calculate the required emergency relief venting value.
Level Gauge and Overfill Protection
Overfill protection systems are measures that are used to prevent overfilling the tank during product
reloading operations. Depending on the site, a combination of administrative procedures, high-level
alarms, and/or high-level shut-off devices are used to provide overfill protection.
Electrical Equipment
Electrical wiring and electrical components within the secondary containment system and around product
dispensing and tank loading operations are inspected to ensure that they are in good condition and do not
present an electrical hazard during normal operation of the tanks.
Emergency Response Equipment
Certain emergency response equipment or devices may be required by the fire code, including emergency
shut-off devices or firefighting measures (e.g., extinguishers). The inspection includes identifying and
diagramming the location of any such equipment and/or systems in place to respond to emergency
situations or initiate response activities.
Site Security
The inspection identifies what security measures or equipment are in use to prevent tampering, damage,
release of materials, or other issues associated with unauthorized access to the tanks and tank systems.
Life Safety Codes and Other Issues
Other applicable life safety code and regulatory requirements, including those specified by the
Occupational Safety and Health Administration (OSHA) and U.S. Environmental Protection Agency (EPA),
are evaluated in the inspection process.

APPENDIX B
UT TESTING FORMS

N/A
GRID AVE. MIN. GRID AVE. MIN. GRID AVE. MIN. ID AVE. MIN.
A1 0.185 0.152 B1 0.188 0.159
A2 0.181 0.169 B2 0.182 0.156
A3 0.183 0.157 B3 0.181 0.155
A4 0.180 0.161 B4 0.178 0.153
A5 0.182 0.152
B5 0.179 0.163
A6 0.178 0.159
B6 0.180 0.162
A7 0.191 0.155
B7 0.180 0.152
A8 0.188 0.160 B8 0.179 0.148
A9 0.183 0.151
B9 0.185 0.144
A10 0.185 0.154
B10 0.191 0.166 Corroded 0.212 0.138
A11 0.182 0.159
B11 0.184 0.168 Corroded 0.223 0.150
A12 0.191 0.162
B12 0.187 0.160 Corroded 0.185 0.152
A13 0.180 0.168
B13 0.183 0.144 South 0.199 0.163
A14 0.177 0.160
B14 0.188 0.158
A15 0.176 0.137 B15 0.182 0.160
A16 0.188 0.148
B16 0.175 0.161
A17 0.183 0.166 B17 0.179 0.150
A18 0.185 0.163 B18 0.183 0.152
A19 0.185 0.159
B19 0.182 0.156
A20 0.182 0.171
B20 0.180 0.160
A21 0.180 0.169
B21 0.182 0.169
A22 0.184 0.159
B22 0.186 0.158
A23 0.174 0.158
B23 0.180 0.150
A24 0.178 0.155
B24 0.176 0.149
A25 0.185 0.166
B25 0.193 0.155
A26 0.186 0.163
B26 0.191 0.152
16 years
0.200 inches
-3 9 22
CALIBRATION NOTES:Instrument calibration performed at beginning and end of the testing. All calibration tests were within 0.002 inch tolerance.
ULTRASONIC THICKNESS (UT) TANK TESTING FIELD FORM
FACILITY NAME:Compass Minerals FACILITY ADDRESS:765 North 10500 West, Ogden, Utah 84404
INSPECTOR:Paul Flanagan INSPECTION DATE:10/24/2024
INSTRUMENTATION
UT GAUGE TYPE:OLYMPUS NDT MG2DL TRANSDUCER:OLYMPUS D7906-SM (B-scan)
TANK SPECIFICATIONS
TANK ID:T155 MANUFACTURER:Unknown LISTED CAPACITY:10,000 Gallons
MFG DATE:2008 (Site Installation Date Estimate)LISTED SHELL THICK.:N/A
TANK HEIGHT: TANK DIAMETER:97"TANK LENGTH:322"
LOWEST THICKNESS
READING (inches):0.137
TANK ORIENTATION:Horizontal, Cylindrical CALC. CAPACITY:10,300 Gallons
UT MEASUREMENTS
SAMPLE LOCATION
NOTES:
Sample grid locations started with "A1" and proceeded along the accessible underside in a linear fashion from east to west along the
south side; all "B" grid locations ran along the north side from east to west.
Unpainted Low Spots
Upper Tank Sides
SHELL THICKNESS SUMMARY
AVERAGE MINIMUM
THICKNESS (inches):0.158
MAX. THICKNESS
LOSS (inches):0.063
MAX. THICKNESS
LOSS (%):31.5%
RED = Lowest measured point KNOWN/PRESUMED AGE OF TANK:
0.0500
# Years until reached: # Years until reached: # Years until reached:
"AVE"/"MIN" = Average or minimum reading for the 1-foot grid segment LISTED/DETERMINED ORIG. SHELL THICKNESS:
CORROSION RATE AND PROJECTIONS
Current Corrosion
Rate
(inches per year):
0.0039
75% of Orig. Shell
Thickness (inches):0.15 50% of Orig. Shell
Thickness (inches):0.1000 25% of Orig. Shell
Thickness (inches):
RMEC ENVIRONMENTAL, INC. 476 WEST 325 SOUTH, BOUNTIFUL, UT 84010
N/A
GRID AVE. MIN. GRID AVE. MIN. GRID AVE. MIN. ID AVE. MIN.
A1 0.186 0.160 B1 0.181 0.158
A2 0.188 0.170 B2 0.190 0.164
A3 0.194 0.168 B3 0.178 0.169
A4 0.173 0.148 B4 0.176 0.156
A5 0.199 0.181
B5 0.188 0.168
A6 0.201 0.172
B6 0.188 0.183
A7 0.179 0.153
B7 0.182 0.153
A8 0.182 0.166 B8 0.192 0.159
A9 0.191 0.152
B9 0.177 0.161
A10 0.185 0.177
B10 0.169 0.139 Corroded 0.175 0.140
A11 0.183 0.164
B11 0.183 0.162 Corroded 0.176 0.149
A12 0.180 0.177
B12 0.179 0.157 South 0.202 0.158
A13 0.180 0.172
B13 0.175 0.159 North 0.200 0.189
A14 0.194 0.158
B14 0.184 0.166
A15 0.179 0.170
B15 0.189 0.153
A16 0.190 0.163
B16 0.180 0.174
A17 0.173 0.140 B17 0.187 0.179
A18 0.187 0.148 B18 0.175 0.155
A19 0.188 0.152
B19 0.184 0.165
A20 0.183 0.169
B20 0.175 0.160
A21 0.195 0.187
B21 0.179 0.160
A22 0.186 0.175
B22 0.186 0.174
A23 0.189 0.168
B23 0.181 0.158
A24 0.192 0.171
B24 0.184 0.168
A25 0.188 0.166
B25 0.177 0.166
A26 0.186 0.153
B26 0.176 0.170
16 years
0.200 inches
-3 10 23
CALIBRATION NOTES:Instrument calibration performed at beginning and end of the testing. All calibration tests were within 0.002 inch tolerance.
ULTRASONIC THICKNESS (UT) TANK TESTING FIELD FORM
FACILITY NAME:Compass Minerals FACILITY ADDRESS:765 North 10500 West, Ogden, Utah 84404
INSPECTOR:Paul Flanagan INSPECTION DATE:10/24/2024
INSTRUMENTATION
UT GAUGE TYPE:OLYMPUS NDT MG2DL TRANSDUCER:OLYMPUS D7906-SM (B-scan)
TANK SPECIFICATIONS
TANK ID:T156 MANUFACTURER:Unknown LISTED CAPACITY:10,000 Gallons
MFG DATE:2008 (Site Installation Date Estimate)LISTED SHELL THICK.:N/A
TANK HEIGHT: TANK DIAMETER:97"TANK LENGTH:322"
LOWEST THICKNESS
READING (inches):0.139
TANK ORIENTATION:Horizontal, Cylindrical CALC. CAPACITY:10,300 Gallons
UT MEASUREMENTS
SAMPLE LOCATION
NOTES:
Sample grid locations started with "A1" and proceeded along the accessible underside in a linear fashion from east to west along the
south side; all "B" grid locations ran along the north side from east to west.
Unpainted Low Spots
Upper Tank Sides
SHELL THICKNESS SUMMARY
AVERAGE MINIMUM
THICKNESS (inches):0.164
MAX. THICKNESS
LOSS (inches):0.061
MAX. THICKNESS
LOSS (%):30.5%
RED = Lowest measured point KNOWN/PRESUMED AGE OF TANK:
0.0500
# Years until reached: # Years until reached: # Years until reached:
"AVE"/"MIN" = Average or minimum reading for the 1-foot grid segment LISTED/DETERMINED ORIG. SHELL THICKNESS:
CORROSION RATE AND PROJECTIONS
Current Corrosion
Rate
(inches per year):
0.0038
75% of Orig. Shell
Thickness (inches):0.15 50% of Orig. Shell
Thickness (inches):0.1000 25% of Orig. Shell
Thickness (inches):
RMEC ENVIRONMENTAL, INC. 476 WEST 325 SOUTH, BOUNTIFUL, UT 84010
N/A
GRID AVE. MIN. GRID AVE. MIN. GRID AVE. MIN. ID AVE. MIN.
A1 0.261 0.222
A2 0.260 0.248
A3 0.268 0.242
A4 0.255 0.247
A5 0.258 0.249
A6 0.271 0.241
A7 0.241 0.238
A8 0.241 0.230
A9 0.240 0.232
A10 0.265 0.255 North 0.262 0.222
A11 0.266 0.243 South 0.253 0.248
A12 0.259 0.202
A13 0.257 0.248
A14 0.250 0.242
A15 0.266 0.236
A16 0.262 0.240
16 years
0.250 inches
52647
CALIBRATION NOTES:Instrument calibration performed at beginning and end of the testing. All calibration tests were within 0.002 inch tolerance.
ULTRASONIC THICKNESS (UT) TANK TESTING FIELD FORM
FACILITY NAME:Compass Minerals FACILITY ADDRESS:765 North 10500 West, Ogden, Utah 84404
INSPECTOR:Paul Flanagan INSPECTION DATE:10/24/2024
INSTRUMENTATION
UT GAUGE TYPE:OLYMPUS NDT MG2DL TRANSDUCER:OLYMPUS D7906-SM (B-scan)
TANK SPECIFICATIONS
TANK ID:T190 MANUFACTURER:Modern Welding Company LISTED CAPACITY:6,000 Gallons
MFG DATE:2008 (Manufacturing Date)LISTED SHELL THICK.:N/A
TANK HEIGHT: TANK DIAMETER:97"TANK LENGTH:322"
LOWEST THICKNESS
READING (inches):0.202
TANK ORIENTATION:Horizontal, Cylindrical CALC. CAPACITY:7,145 Gallons
UT MEASUREMENTS
SAMPLE LOCATION
NOTES:
Sample grid locations started with "A1" and proceeded along the tank's underside in a linear fashion from east to west.
Unpainted Low Spots
Upper Tank Sides
SHELL THICKNESS SUMMARY
AVERAGE MINIMUM
THICKNESS (inches):0.238
MAX. THICKNESS
LOSS (inches):0.048
MAX. THICKNESS
LOSS (%):19.2%
RED = Lowest measured point KNOWN/PRESUMED AGE OF TANK:
0.0625
# Years until reached: # Years until reached: # Years until reached:
"AVE"/"MIN" = Average or minimum reading for the 1-foot grid segment LISTED/DETERMINED ORIG. SHELL THICKNESS:
CORROSION RATE AND PROJECTIONS
Current Corrosion
Rate
(inches per year):
0.0030
75% of Orig. Shell
Thickness (inches):0.1875 50% of Orig. Shell
Thickness (inches):0.1250 25% of Orig. Shell
Thickness (inches):
RMEC ENVIRONMENTAL, INC. 476 WEST 325 SOUTH, BOUNTIFUL, UT 84010

APPENDIX C
PHYSICAL INSPECTION FINDINGS SPREADSHEET(S)

Physical Inspection Findings Worksheet Compass Minerals (Ogden, Utah)
Main Bulk Fuel Storage Area (Tanks T155, T156, & T190)

RMEC Environmental, Inc - 1 - *Identified as Critical Deficiency, Compliance Deficiency, or
Recommended Best Management Practice (BMP)
Inspection
Category Inspection Requirements Applicable Codes &
Regulations Observations
Inspection Determinations Photo
Log
Exhibit
#
Description of Deficiencies &
Recommended Corrective Actions AST ID Status*
Documentation/Recordkeeping
Inspection
Records
Identify past problems and/or
deficiencies through a review of the
facility's inspection records, including
internal periodic (monthly and annual)
inspections and any other inspection
reports, especially those performed by
outside parties or certified inspectors.
40 CFR 112.8(c)(6)
STI SP001 Section 5.0
STI SP001 4.1
STI SP001 Section 6.0
NFPA 30 21.8.6

No inspection records were provided upon
request. However, the subject ASTs are
reportedly included in periodic inspections
along with other bulk storage containers
at the facility.
All existing records related to periodic
inspections or other deficiencies should be
kept for the life of each tank and be made
available for review.
All Recommended
BMP
N/A
Past Repair
and/or
Modification
Records
All AST modifications should be
performed in accordance with
applicable fabrication standards.
Review past repair, alteration, and/or
modification records for the subject
ASTs.
40 CFR 112.12(6)
STI 7.1.3
NFPA 30 21.8
No records indicating past repairs were
provided or encountered; however, there
was no evidence of formal repairs
involving the tank shells.
None N/A N/A N/A
Spill
Prevention,
Control, and
Counter-
measure
(SPCC) Plan
The Clean Water Act requires certain
facilities to develop and implement
SPCC Plans, which shall establish
certain procedures, methods, and
equipment requirements to prevent,
control, and respond to discharges of
oil products. If available, review the
facility SPCC Plan for requirements,
controls, and procedures applicable to
the operations, inspection, and
maintenance of the AST.
40 CFR 112.7
40 CFR 112.8
RMEC was provided with an SPCC for the
Compass Minerals site; however, the SPCC
does not mention or include any
information regarding the three fuel
island tanks (T155, T156 & T190).
Of note, the site is located immediately
east of the Great Salt Lake.
The site must take measures to update
the existing SPCC to include the three
subject ASTs.
All Compliance
Deficiency
N/A
Fabrication Standards
Identification
of Fabrication
Standard
Identify the applicable fabrication
standard for the AST. Tank tags will
typically provide this information along
with other details such as construction
date, dimensions, and volumetric
capacity. It is important to verify that
the AST is being used in a manner that
is consistent with its intended design.
The fabrication standard will be used
as a baseline for the physical inspection
and any fabrication discrepancies
and/or signs of modifications or repairs
to the tank structures must be noted in
the inspection process.
40 CFR 112.8(c)(1)
STI 7.1.5
IFC 5704.2.7
NFPA 30 21.4.2
A basic tank tag identified on the exterior
of T190 identifying it as having been
manufactured by Modern Welding
Company to a UL-2085 construction
standard, which has been applied for the
purposes of this inspection.
For the diesel fuel tanks (T155 & T156),
basic tags on the supports indicated a UL
construction standard; however, RMEC
was unable to determine the specific UL
construction standard. For the purposes of
this inspection, the UL 142 standard was
applied to those ASTs, as noted
throughout this report.
If possible, the site should obtain and
maintain documentation that lists the
specific fabrication standards, if they
exist, for the diesel tanks. Otherwise, all
future inspections will require application
of the UL 142 standard, which may be
more restrictive (depending on the actual
applicable standard).
T155
T156
Recommended
BMP
14
15
22
Physical Inspection Findings Worksheet Compass Minerals (Ogden, Utah)
Main Bulk Fuel Storage Area (Tanks T155, T156, & T190)

RMEC Environmental, Inc - 2 - *Identified as Critical Deficiency, Compliance Deficiency, or
Recommended Best Management Practice (BMP)
Inspection
Category Inspection Requirements Applicable Codes &
Regulations Observations
Inspection Determinations Photo
Log
Exhibit
#
Description of Deficiencies &
Recommended Corrective Actions AST ID Status*
Tank Location/Siting
Location /
Siting
Using applicable fire codes, evaluate
the location and drainage pathways of
the AST in relationship to the property
lines, adjacent structures, and other
ASTs and/or hazardous materials
storage areas.
IFC 5704.2.9.6
NFPA 30 22.4.1
NFPA 30 28.4.1
NFPA 30 Table-22.4.1.1
NFPA 30 Table-22.4.2.1
NFPA 30A 4.2.2
NFPA 30A 4.3.2.4
RMEC used the referenced standards for
making determinations about tank siting.
All ASTs appeared to meet the minimum
shell-to-shell spacing requirements based
on their contents and diameters. All ASTs
also met required setback distances from
adjacent structures, dispensing devices,
property lines, public roadways, and
hazardous materials storage.
None N/A N/A N/A
Tank Foundation and Supports
Tank Stability
and
Foundation
Inspect and describe the foundations
and vicinity of the AST for evidence of
settlement. The foundation(s) should
be even and there should not be any
areas of washout where vegetation can
grow or dust can accumulate against
the shells or baseplates of the AST.
NFPA 30 22.5 Each AST is set upon a concrete
housekeeping pad that was noted to be in
good condition and mostly even/level. The
underside of each tank was noted to have
some dust/mud accumulation, especially
on tanks T155 and T156 where most of
the underside is inaccessible.
Some vegetation was also noted to be
present surrounding the tanks.
The site should take measures to remove
the sediment buildup on the bases of the
tanks which would help preserve the life
of those tanks.
Where present, all vegetation in the tank
area should also be removed.
All Recommended
BMP
1
2
15
16
Anchors,
Bolts, or
Straps
The AST should be securely anchored
or otherwise secured to foundations to
prevent shifting or settlement in the
case of a catastrophic event.
NFPA 30 22.5.1.3
NFPA 30 22.5.2.5
NFPA 30 22.14
None of the tanks are bolted or otherwise
secured to their supports or pads, which
would typically be prudent for areas that
may be prone to flooding or earthquakes.
According to FEMA, Compass Minerals is
located in an area that has a high
likelihood of liquefaction in the event of
an earthquake and a high likelihood of
flooding. If a viable means exists, the site
should consider anchoring the tanks.
All Recommended
BMP
16
Drainage Drainage should be away from the AST
foundation. The vicinity of the AST and
secondary containment system (if
applicable) should be checked for signs
of drainage towards the tank, as well
as erosion under the secondary
containment system and/or AST.
IFC 5704.2.10
STI SP001 7.1.6

The ground surface around the ASTs
slopes away from the ASTs, providing
adequate means of drainage in the event
of a failure.
None N/A N/A 1
2
3
Physical Inspection Findings Worksheet Compass Minerals (Ogden, Utah)
Main Bulk Fuel Storage Area (Tanks T155, T156, & T190)

RMEC Environmental, Inc - 3 - *Identified as Critical Deficiency, Compliance Deficiency, or
Recommended Best Management Practice (BMP)
Inspection
Category Inspection Requirements Applicable Codes &
Regulations Observations
Inspection Determinations Photo
Log
Exhibit
#
Description of Deficiencies &
Recommended Corrective Actions AST ID Status*
Cracking or
Spalling
Cracks or spalling can be indicators of
structural weaknesses on the
structures supporting the AST. These
surfaces, which include housekeeping
pads or reinforced tank supports,
should be thoroughly inspected for
indications of spalling, cracking, or
other signs of deterioration.
NFPA 30 22.5.2.1
STI SP001 7.1.7
No indications of structural weaknesses to
AST foundations or supports were noted.
None N/A N/A N/A
Corrosion The AST foundation and supports are
considered an integral part of the tank
and should not have any distortions or
evidence of corrosion. Any coatings
should also be in good condition and
free of significant corrosion.
STI SP001 7.1.6
NFPA 30 21.4.5
NFPA 30A 4.3.8
Minor corrosion was noted on the rail
supports for T155 and T156.
The site should continue to monitor the
condition of the tank rail supports and
ensure that their corrosion does not
continue to accelerate.
T155
T156
Recommended
BMP
16
Secondary Containment
Containment
Capacity
Secondary containment dikes are
designed to provide containment for
the entire capacity of the largest single
AST; for outdoor open-top dikes, it also
should include sufficient freeboard to
contain precipitation (usually 10%)
while allowing for the displacement
volume of other structures or ASTs
inside the containment. Take
measurements of the internal
dimensions and calculate capacity.
40 CFR 112.8(c)(2)
IFC 5704.2.10
NFPA 30 21.7.1
NFPA 30 22.11
NFPA 30A 4.3.2.8
Each AST is double-walled and has
inherent secondary containment.
Of note, while each AST has a concrete
housekeeping pad and underlying black
liner, those systems do not extend out
very far beyond the tanks, so there is no
actual spill containment diking for any
catastrophic failures or other releases.
So long as the primary shell of each AST
remains intact, then secondary
containment is achieved and no additional
actions are required.
N/A N/A 2
3
5
21
Containment
Structure
Inspect the secondary containment
structure and pads for any potential
breach points (unsealed penetrations,
holes, etc.) or deterioration, including
cracking or spalling concrete and
settlement. The containment must be
impervious to liquids, made of non-
combustible materials, and all internal
structures must have a minimum 2-
hour fire rating.
STI SP001 7.1.8
IFC 5004.2.1
NFPA 30 22.5.2.2
NFPA 30 22.11.2.4

A physical inspection of the outer shells of
each tank revealed multiple locations of
localized corrosion where the steel was
beginning to delaminate. However,
ultrasonic thickness testing found no
locations where the overall corrosion was
significant enough to merit immediate
concern.
None N/A N/A 7
11
12
13
Physical Inspection Findings Worksheet Compass Minerals (Ogden, Utah)
Main Bulk Fuel Storage Area (Tanks T155, T156, & T190)

RMEC Environmental, Inc - 4 - *Identified as Critical Deficiency, Compliance Deficiency, or
Recommended Best Management Practice (BMP)
Inspection
Category Inspection Requirements Applicable Codes &
Regulations Observations
Inspection Determinations Photo
Log
Exhibit
#
Description of Deficiencies &
Recommended Corrective Actions AST ID Status*
Leak
Detection and
Water
Intrusion
An approved monitoring method shall
be provided to detect hazardous
materials in the secondary
containment system. The monitoring
method is allowed to be a visual
inspection of the primary or secondary
containment, or other documented
means. If present, leak detection
equipment, such as liquid sensors and
site gauges, must be removed, cleaned,
and checked for proper operation.
40 CFR 112.7(c)
STI SP001 7.1.9.3
UL 2085 8.6
The ASTs were all equipped with an
interstitial monitoring port as well as an
interstitial leak detector. Each AST’s
interstitial monitoring port was operable;
however, the ports did not provide enough
visibility to observe the condition of the
interstitial spaces, especially where
absorbent materials filled that space.
Notably, the digital readout for T190
indicated that there was a “Leak
Detected” in the interstitial space on
10/21/2024 at 11:35 AM (several days
before this inspection). Site personnel
were not aware that the leak detection
alert had occurred.
The site must investigate whether the leak
detection equipment on each AST is
accurate, including for T190 where a leak
may have recently occurred.
RMEC also recommends that the site
implement better controls to ensure that
system alarms or alerts are promptly
identified and addressed. As necessary,
this may include an adjustment to existing
procedures.
All Recommended
BMP
5
6
32
Containment
Conditions
In accordance with STI & applicable fire
codes, the containment should be
inspected for the presence of trash,
debris, and other foreign objects. No
combustible or flammable materials
shall be stored in the vicinity of the
AST. For vertical tanks, the secondary
containment should allow water
accumulation to drain away from the
tank shell.
40 CFR 112.8(c)(10)
29 CFR 1910.22(a)(2)
STI SP001 7.1.8.2
IFC 5704.4.6
IFC 3404.4.2.3

Not applicable with the secondary
containment being part of the inherent
design of east AST.
In the area surrounding the ASTs, there
were a few plants and weeds, but no
trash, debris, or other flammable or
combustible materials were noted.
None N/A N/A 5
6
Access &
Egress
In accordance with applicable fire
codes, secondary containment must
have OSHA-compliant access and
egress. Pathways should be kept clear,
and structures must have a minimum
2-hour fire rating.
OSHA 1926.1053
UL 142 35.1
Not applicable with the secondary
containment being part of the inherent
design of east AST.
None N/A N/A N/A
Drainage
Systems
Secondary containment drainpipes and
valves must be inspected and tested
for operability and be accessible during
a fire. Also, per EPA requirements,
secondary containment bypass/drain
valves must be sealed except for when
actively draining.
40 CFR 112.8(c)(2)(i)
NFPA 30 22.11.2.7.1
The interstitial spaces for T155 and T156
have a drain port under the west
headwalls. Minor weeping was noted
around the drain plug of T155, but no
staining was present on the ground
below.
T190 is not equipped with any drain port
or valve.
None N/A N/A 1
Physical Inspection Findings Worksheet Compass Minerals (Ogden, Utah)
Main Bulk Fuel Storage Area (Tanks T155, T156, & T190)

RMEC Environmental, Inc - 5 - *Identified as Critical Deficiency, Compliance Deficiency, or
Recommended Best Management Practice (BMP)
Inspection
Category Inspection Requirements Applicable Codes &
Regulations Observations
Inspection Determinations Photo
Log
Exhibit
#
Description of Deficiencies &
Recommended Corrective Actions AST ID Status*
Grounding, Bonding and Cathodic Protection
Grounding &
Bonding
Systems
Bonding systems are required to
reduce potential static discharges
during bulk transfers between the AST,
piping systems, and delivery vehicles.
All grounding straps, bonding wires,
and connections must be inspected
and found to be adequate, secure, and
in good condition.
STI SP001 7.1.10
IFC 5706.5.1.7
NFPA 30 6.5.4
NFPA 30 28.3.1
UL 2085 12.1

Grounding wires were noted to be present
on each AST.
No bonding wires were noted to be
present at the tank filling location.
A bonding system between the tank
system and the delivery truck should be
used during fuel transfers.
All Compliance
Deficiency
4
15
Cathodic
Protection
The cathodic protection system should
be checked to verify proper operation,
and the visible wiring and junction
boxes should be checked for secure
connections. Record any rectifier
readings using a voltmeter or multi-
meter. Zero voltage reading may
indicate a faulty system or bad
connections.
IFC 5704.2.7.9
IFC 5703.6.5
NFPA 30 27.6.4
(Not applicable because none of the
tank’s systems are in direct contact with
the ground.)
None N/A N/A N/A
Tank Heads, Shells, and Coatings
Tank Shell,
Pads, Plates,
and Welds
A visual inspection of the exterior
shells, tank pads, plates, and welds are
performed in an attempt to identify
external evidence of flaws, repairs,
aftermarket modifications, buckling,
dents, distortion from stress or impact,
cracking, pitting, spalling, pinholes,
and/or mechanical damage.
STI SP001 7.4.1
NFPA 30 21.8
The exterior secondary shells of the ASTs
were inspected, and no significant
mechanical damage, impact-related
damage, repairs, or other flaws were
noted.
All welds were noted to be in fair
condition with some minor corrosion
present. No pinholes or weld failures were
noted.
None N/A N/A 7
11
12
13
Coatings Inspect all visible portions of the shell,
roof, and bottom for evidence of
coating failure. If necessary, perform
discontinuity (holiday) testing.
STI SP001 7.1.12
UL 142 11.1
NFPA 30 21.4.5
NFPA 30A 4.3.8
The white coating on each AST was
generally found to be in good condition
overall. However, there were many areas
with localized corrosion, including
blistering and delamination, resulting in
increased surface corrosion and paint
failure. Based on integrity testing, the AST
shells have not yet been severely
compromised.
Considering the extensive localized
corrosion occurring, the site should
consider re-coating the exteriors of each
AST. Prior to any recoating, the site would
need to address and mitigate the existing
corrosion first so that corrosion does not
continue unabated under the new exterior
coating.
All Recommended
BMP

1
2
5
11
12
13
21
Physical Inspection Findings Worksheet Compass Minerals (Ogden, Utah)
Main Bulk Fuel Storage Area (Tanks T155, T156, & T190)

RMEC Environmental, Inc - 6 - *Identified as Critical Deficiency, Compliance Deficiency, or
Recommended Best Management Practice (BMP)
Inspection
Category Inspection Requirements Applicable Codes &
Regulations Observations
Inspection Determinations Photo
Log
Exhibit
#
Description of Deficiencies &
Recommended Corrective Actions AST ID Status*
Insulation Check insulation for the presence of
moisture buildup or evidence of past
water damage. Pay particular attention
to areas near bottom of the AST where
moisture can wick up from the ground,
get trapped against the shell, and
promote corrosion.
STI SP001 7.6 (Not applicable due to no insulation being
present on the subject ASTs)
None N/A N/A N/A
Internal
Moisture &
Microbial-
Induced
Corrosion
(MIC)
Check for the presence of water inside
the AST with a water-seeking paste.
Not only will the presence of water
promote internal corrosion, but it can
also lead to the formation of MIC,
which can cause localized, accelerated
deterioration of the tank shell.
STI SP001 10.2.1
NFPA 30 21.8
RMEC checked for the presence of water
within each tank using a water-seeking
paste and found that none of the tanks
contained water. However, the digital
readouts from the liquid level gauges
indicated that T156 and T190 had water
present in their primary tanks.
The site should take measures to inspect,
clean, calibrate, and verify the accuracy of
the electronic liquid level gauges so that
the absence or presence of water may
accurately be observed and recorded.
T156
T190
Recommended
BMP

32
Tank Openings
Flanged
Openings
Verify that all manways and other
flanged connections are securely
bolted and free from weeping product
or other indicators of active leaks.
Check to ensure all of the long-bolted
manways for emergency venting are
still properly long-bolted and stamped
or labeled if being used for emergency
venting.
UL 142 Section 9
IFC 5704.2.7.5

T155 and T156 are each equipped with a
topside manway that was bolted shut. No
weeping product or other indicators of
active leaks were observed.
No manways were present on T190.
None N/A N/A 7
11
12
Other
Openings
Other than dedicated tank vents,
ensure that all other pipes or shell
openings are sealed shut to prevent
intrusion of moisture, debris, or other
foreign objects.
IFC 5704.2.7.5
NFPA 30 22.13
NFPA 30A 4.3.6.1
NFPA 30A 4.2.2
UL2085 7.4

All other potential openings (e.g., ports
with liquid level gauges or atmospheric
venting) were properly sealed shut and
had no signs of weeping or leakage.
None N/A N/A 5-10
Product Piping and Valve Systems
Materials &
Construction
All piping and valves should be
compatible for the material being
handled. Piping and valve components
handling flammable and combustible
materials must meet applicable fire
code standards for installation and use.
STI SP001 7.1.8.2
IFC 5703.6.2
IFC 7505.2.3
NFPA 30 27.4
NFPA 30A 5.2.1

All valves and piping connected to the
tanks (or tank systems) were found to be
made of materials compatible with
flammable or combustible liquids.
None N/A N/A 1-3
5
Physical Inspection Findings Worksheet Compass Minerals (Ogden, Utah)
Main Bulk Fuel Storage Area (Tanks T155, T156, & T190)

RMEC Environmental, Inc - 7 - *Identified as Critical Deficiency, Compliance Deficiency, or
Recommended Best Management Practice (BMP)
Inspection
Category Inspection Requirements Applicable Codes &
Regulations Observations
Inspection Determinations Photo
Log
Exhibit
#
Description of Deficiencies &
Recommended Corrective Actions AST ID Status*
Design &
Configuration
Piping and valve systems should be
designed to reasonably prevent leaks
in the system. Inspect and note pipe
and valve connections, joints,
penetrations, and/or bends in
comparison with the fire code
standards. Also make note of where
siphoning or product expansion could
occur.
ASME B31
IFC 5703.6
NFPA 30 27.5
NFPA 30 27.6
NFPA 30A 4.3.2.8.2
NFPA 30A 5.2

Fuel is distributed from each AST via top-
side ports on the west end. Isolation
valves and solenoid valves are also
present to control flow prior to passing
underground (to the fuel islands).
A rain canopy is present over each
distribution port. A catchment tray is also
present to capture any leaks from either
valve. The trays drain into the distribution
piping.
Other than the overhead rain canopies,
RMEC did not observe a means to prevent
rain, snow, or dust from collecting in the
trays and then entering the distribution
piping.
This setup, while constructed with good
intent, is significantly over-engineered
and is likely introducing water and other
impurities into fuel in the distribution
lines.
If the catchment trays are needed due to
significant product release issues, then the
piping and valves should be repaired or
replaced to prevent such issues.
Otherwise, the catchment trays should be
removed to prevent water intrusion into
the system and the associated corrosion
concerns that are likely to follow.
All Recommended
BMP

18
20
25
26
Markings /
Labeling
All piping should be marked with
contents and direction of flow. Verify
that markings and labeling are in good
condition and accurate.
ANSI/ASME A13.1
NFPA 30 27.10
NFPA 30A 5.2.5

Product supply lines are marked with the
contents; however, none of the
distribution piping is marked with the
contents.
Additionally, direction of flow is not noted
on any of the piping.
ALL piping should be labeled with
corresponding contents (or color-coded)
and direction of flow.
All Compliance
Deficiency
3
17
20
Condition &
Operability
Assessment
All aboveground piping, valves, and
fittings must be thoroughly inspected
for evidence of leaks, mechanical
damage, stress, distortion, and/or
corrosion. All valves, such as
mechanical, solenoid, and isolation
valves, must be tested for proper
operation and function.
STI SP001 7.1.9.1
IFC 5703.6.10
NFPA 30 27.3.2
NFPA 30 27.5
NFPA 30A 5.2

RMEC inspected all aboveground piping,
including all valves and fittings, and did
not observe any evidence of significant
leaks or mechanical damage.
However, the distribution piping is a 2”
line that is housed within a secondary
containment pipe (though they are not in
contact with each other) that is severely
corroded and provides no protection for
the distribution piping.
The visible piping areas were also found to
be corroded in several areas.
All isolation valves were found to be
operable.
Piping, overall, should be repaired and re-
coated, where necessary, to prevent
ongoing deterioration.
The site should also consider removing the
secondary containment pipe from the
aboveground portions of the distribution
lines. This would better allow for visual
monitoring of the condition of the
distribution piping.
All Recommended
BMP
25
27
Physical Inspection Findings Worksheet Compass Minerals (Ogden, Utah)
Main Bulk Fuel Storage Area (Tanks T155, T156, & T190)

RMEC Environmental, Inc - 8 - *Identified as Critical Deficiency, Compliance Deficiency, or
Recommended Best Management Practice (BMP)
Inspection
Category Inspection Requirements Applicable Codes &
Regulations Observations
Inspection Determinations Photo
Log
Exhibit
#
Description of Deficiencies &
Recommended Corrective Actions AST ID Status*
Piping
Supports
Verify suspended pipe runs are secure
and have adequate support. Inspect
piping supports and contact with pipes
for mechanical or vibrational
damage/abrasion or accumulation of
moisture.
STI SP001 7.1.9.1
IFC 5703.6.8
NFPA 30 27.6.1
NFPA 30A 5.2

RMEC found all piping associated with the
ASTs to be properly supported.
None N/A N/A 3
Anti-Siphon &
Backflow
Prevention
Controls
Evaluate all product transfer,
dispensing, loading, and unloading
pipelines for potential siphon and
backflow points, especially on the
outside of containment areas. Loading
lines must be protected with valves to
prevent backflow from the AST system,
if possible.
IFC 5703.6.6
NFPA 30 27.6.6
NFPA 30 22.13.1
NFPA 30A 4.3.6.4
All supply lines had backflow valves.
Distribution lines had isolation valves and
solenoid valves to protect against
potential siphoning issues at the fuel
islands.
None N/A N/A 5
18
19
Isolation /
Fire Safety
Valves &
Other Critical
Valves
Verify that, at a minimum, isolation
valves are present on all distribution
pipelines that are normally closed and
that fire safety valves are used on
distribution pipelines that are normally
open. Verify such valving meets all fire
code requirements and test for proper
operation and function. Any critical
valves, which could be used to drain
the tank contents, must be locked shut
to prevent tampering or vandalism.
IFC 5703.6.6
IFC 5703.6.7
NFPA 30 27.6.6.1
NFPA 30 27.6.7
NFPA 30A 6
While solenoid and isolation valves were
present, none of the ASTs had a fire safety
valve.
RMEC also noted the presence of a shear
valve at the north fuel distribution island;
however, it did not readily snap shut when
tested and it was not located at ground
level.
The southwest fuel distribution island has
three fuel dispensers, but only two of the
dispensers had operable shear valves.
Fire safety valves must be installed on all
ASTs with flammable or combustible
liquids. Fire safety valves enable each AST
to be separated from its supply/
distribution line in the event of a fire.
Additionally, each fuel dispenser must be
equipped with an operable shear valve at
or below ground level so that the
distribution piping may be isolated in the
event of a collision.
All Compliance
Deficiency
18
19
29
31
Piping
Containment
& Impact
Verify that runs of piping outside of
containment are protected from
vehicle impact and have containment if
not protected by valving.
40 CFR 112.8(b)(3)
IFC 5703.6.4
IFC 5703.6.6
NFPA 30A 5.2.2
The fuel supply piping on the east side of
the storage area is almost entirely
exposed and unprotected from vehicular
impact. Distribution piping on the west
side of the storage area is protected by
concrete barriers; all other piping is
underground.
The north fuel island has protective
bollards; however, the dispenser hose
shows evidence of being repeatedly on the
ground (and therefore exposed to
vehicular traffic).
The southwest fuel distribution island has
similar conditions; however, it is entirely
unprotected from vehicle impact.
Bollards or barricading should be installed
to protect all of the supply piping and the
distribution piping associated with the
AST system, including at the dispensing
islands.
Furthermore, all dispenser hoses should
be equipped with hangers or retractable
coils to keep them out of the path of
vehicles.
All Recommended
BMP
1
3
28-30
Physical Inspection Findings Worksheet Compass Minerals (Ogden, Utah)
Main Bulk Fuel Storage Area (Tanks T155, T156, & T190)

RMEC Environmental, Inc - 9 - *Identified as Critical Deficiency, Compliance Deficiency, or
Recommended Best Management Practice (BMP)
Inspection
Category Inspection Requirements Applicable Codes &
Regulations Observations
Inspection Determinations Photo
Log
Exhibit
#
Description of Deficiencies &
Recommended Corrective Actions AST ID Status*
Thermal
Expansion
Relief
As a best management practice,
determine the presence of runs of
piping greater than 50 feet and
whether they require relief valves to
prevent over pressurization due to
thermal expansion.
40 CFR 112.8(d)(4)
IFC 5703.6.6
NFPA 30A 4.3.6.5
NFPA 30A 5.2.6
Each of the fuel distribution islands are
located approximately 50 feet from the
tanks and, as such, have runs of piping
greater than 50 feet. However, most of
that distance is underground and not
exposed to heat.
None All N/A 28-30
Tank Dispensing and Unloading/Systems
Transfer
Connection
Points
Evaluate connection points and any
associated product pumping systems
that are used to transfer product into
and out of the AST. A spill prevention
method, such as spill buckets, boxes, or
valving, should be used to minimize
spills during transfer hose
disconnection.
40 CFR 112.8(c)(10)
UL 2085 10
IFC 5703.4
IFC 5705.2
NFPA 30A 4.3.6.7
NFPA 30A 9.2.2
Fuel is suppled to each AST at the spill
boxes located southeast of the storage
area. The pipes have camlock caps.
Product transfer is accomplished using the
delivery tank truck’s pump.
Distribution relies on a closed system
powered and metered by the fuel
dispensing islands.
None N/A N/A 3
4
28-30
Procedures &
Equipment
Determine whether a written or posted
procedure is present. Also, verify that
the equipment being used is
compatible with the material(s) being
transferred.
40 CFR 112.7(a)(3)(ii)
IFC 5705.2.1
IFC 3404 2.9.7.6.1
A written transfer procedure was present
near the supply line spill boxes.
Also, transfer equipment/materials
appeared to be compatible with the fuel
present onsite.
None N/A N/A 4
Atmospheric/Normal Venting
Atmospheric/
Normal Vent
Design &
Capacity
Measure the diameter and evaluate
the orientation of each atmospheric
vent. Vents should be oriented to
prevent the entrainment of
precipitation and must meet the
applicable AST design standard and/or
governing fire codes.
UL 142 Table 8.2
UL 2085 9.1 & 9.2
NFPA 30 21.4.3
NFPA 30 27.8
NFPA 30A 5.6
Each AST is equipped with a 2”
atmospheric/normal vent port. T155 and
T190 have bi-directional vents with silica
gel absorbent manufactured by Shroeder
Industries. T155 has no vent.
Each AST is supplied by 3” piping.
Atmospheric vent sizes should be equal to
greater than the diameter of supply line
piping; therefore, none of the ASTs are
equipped with the proper atmospheric
vent size.
Atmospheric vent (and pipe) sizes must be
increased to meet the required minimum
size based on tank fabrication standards
(e.g., 2.5” diameter for 10,000-gallon
ASTs) or at least match the current 3”
supply line sizes. Alternatively, the supply
lines could be reduced to 2” in diameter.
All Compliance
Deficiency
2
5
6
Condition &
Operability
Assessment
Vents should be open and screens, if
present, should be clean and free of
occlusions such as residues, dirt, insect
nests, and other debris or foreign
objects. Test each atmospheric/normal
vent for proper operation.
NFPA 30 21.8.6 No obstructions or operability issues were
noted. T155 has a riser pipe for an
atmospheric vent, but no actual vent was
present and the vertical pipe is therefore
open to the elements.
An approved atmospheric vent or a
goosenecked pipe extension should be
added to T155 in order to prevent any
unintended water intrusion.
T155 Recommended
BMP
6
Physical Inspection Findings Worksheet Compass Minerals (Ogden, Utah)
Main Bulk Fuel Storage Area (Tanks T155, T156, & T190)

RMEC Environmental, Inc - 10 - *Identified as Critical Deficiency, Compliance Deficiency, or
Recommended Best Management Practice (BMP)
Inspection
Category Inspection Requirements Applicable Codes &
Regulations Observations
Inspection Determinations Photo
Log
Exhibit
#
Description of Deficiencies &
Recommended Corrective Actions AST ID Status*
Emergency Venting
Emergency
Vent Design
& Capacity
The AST must have emergency relief
venting in the form of construction or a
device(s) that will relieve excessive
internal pressure caused by an
exposure to fire. Measure the diameter
and record the model, make, and
venting capacity of any existing
emergency venting units. Also calculate
the required emergency venting
capacity for the AST. Vents should be
sealed to prevent the entrainment of
precipitation and must meet the
applicable tank design standard and/or
governing fire codes.
UL 142 Table 8.1
UL 2085 9.1 & 9.2
NFPA 30 22.7
NFPA 30 Table 22.7.3.2

Each AST is equipped with an emergency
vent for both the primary tank and
interstitial space.
All were found to be operable, in fair
condition, and compliant with each listed
regulatory standard.
None N/A N/A 8
12
17
23
Condition &
Operability
Assessment
Open each vent to inspect integuments
for corrosion and buildup of residues,
dirt, insect nests, or other debris or
foreign objects. Verify actuation of
venting mechanisms and inspect for
foreign/non-OEM components.
STI SP001 7.1.9.2
NFPA 30 21.8.6
Each emergency vent, when tested for
operability, cleaved pieces of the exterior
coating along with it. This indicates that
operability of the emergency vent has not
been tested since the last time that AST
exterior was recoated.
The site must verify the operability of the
emergency vents during any ongoing
periodic inspections.
All Recommended
BMP
N/A
Physical Inspection Findings Worksheet Compass Minerals (Ogden, Utah)
Main Bulk Fuel Storage Area (Tanks T155, T156, & T190)

RMEC Environmental, Inc - 11 - *Identified as Critical Deficiency, Compliance Deficiency, or
Recommended Best Management Practice (BMP)
Inspection
Category Inspection Requirements Applicable Codes &
Regulations Observations
Inspection Determinations Photo
Log
Exhibit
#
Description of Deficiencies &
Recommended Corrective Actions AST ID Status*
Level Gauge and Overfill Protection
Liquid Level
Gauging
Design &
Operability
Determine if liquid level gauging is
visible to transfer operators and meets
governing fire codes. Verify accuracy of
liquid level gauging systems by
measuring the depth of product in the
AST. Inspect probes, wires, and sensors
for damage or other indicators of wear
or deterioration.
40 CFR 112.8(c)(8)(i)-(iv)
NFPA 30 21.8.6
NFPA 30A 4.3.6.2
NFPA 30A 9.2.5.5

Each AST is equipped with a clock-face
liquid level gauge and a digital liquid level
gauge. The digital readout is located
directly north of the ASTs in a control box.
T155 and T190 are also equipped with a
wireless tank gauge (presumably not
needed on T156 because dispensing
occurs in parallel with T155). According to
site personnel, the wireless tank gauge is
monitored by the fuel delivery company
who supplies fuel when the liquid level
dips below a certain threshold. As such,
site personnel do not actively monitor or
maintain inventory of the liquid level in
each AST.
Of note, when comparing the clock face
liquid level gauge with the digital level
gauge, inventory levels differed by no
more than 2”. Site personnel did not have
access to the wireless tank monitor’s
readout, so RMEC was unable to verify its
accuracy.
Each of the ASTs are equipped with 3
different means of verifying liquid levels.
The site should verify that the liquid levels
monitored by the wireless tank gauge is
comparatively accurate with the clock-
face and electronic liquid level gauges.
This should be checked often as part of
the periodic inspections. If a significant
difference in monitoring levels exists, the
site should take measures to inspect and
re-calibrate all associated equipment.
All Recommended
BMP
7
9
10
12
Overfill
Protection
Design &
Operability
Determine if overfill protection
mechanisms meet governing
requirements. Actuate and test audible
and visible notification mechanisms for
high level alarms and auto shutoff
functions. Verify alarms and shutoffs
are set are proper heights in
accordance with governing fire codes.
40 CFR 112.8(c)(8)
IFC 5704.2.7.5.8
NFPA 30 21.7.1
NFPA 30 21.8.6
NFPA 30A 4.3.6.3

The clock-face liquid level gauges on T155
and T156 were noted to have an alarm
indicator and wiring for a high-level
alarm; however, no alarm was present.
The spill box for T190 had the following
hand-written note: “90% - 6’7” shuts off.”
This indicates that an automatic shut-off
device would be employed at 90%
capacity (or a liquid level depth of 6’7”);
however, the tank is supplied by pump
from the truck, and no other notable
overfill equipment exists.
Ultimately, NONE of the ASTs were found
to have functional overfill protection (e.g.,
high-level alarms or automatic shut-off
functions).
Overfill protection – including high level
alarms at 90% capacity and/or automatic
shut-off functions at 95% capacity – must
be installed in order to meet the required
standards.
Administrative procedures can also be
used in the absence of mechanical
controls, but these should be adequate
and specifically included in the site’s SPCC
Plan.
All Compliance
Deficiency
4
9
Physical Inspection Findings Worksheet Compass Minerals (Ogden, Utah)
Main Bulk Fuel Storage Area (Tanks T155, T156, & T190)

RMEC Environmental, Inc - 12 - *Identified as Critical Deficiency, Compliance Deficiency, or
Recommended Best Management Practice (BMP)
Inspection
Category Inspection Requirements Applicable Codes &
Regulations Observations
Inspection Determinations Photo
Log
Exhibit
#
Description of Deficiencies &
Recommended Corrective Actions AST ID Status*
Electrical Equipment
Explosion
Proof Fixtures
Verify that all electrical components,
connectors, and wiring meet the
explosion requirements based on the
classification of the products stored in
the area.
29 CFR 1910.307(c)(2)(i)
NFPA 30 7.3.6
NFPA 30 Table 7.3.3
NFPA 30A 8

All wiring, components, and connectors
for tank components and appurtenances
appeared to meet the minimum
explosion-proof requirements for
flammable liquid storage. RMEC also
noted that all conduits present at the site
were properly supported.
None N/A N/A N/A
General
Condition
Inspect wires, electrical components,
fixtures, and junction boxes for
damaged or uninsulated connections.
IFC 5703.1
NFPA 70 Section 605
NFPA 30A 8
As mentioned above, the clock-face liquid
level gauges on T155 and T156 have a
missing high-level alarm. The wiring to
activate the alarms are disconnected and
exposed, but do not appear to be powered
(which would create an electrical hazard
to address).
None N/A N/A 9
Emergency Response Equipment
Equipment &
Devices
Document the presence and location of
all emergency response equipment and
devices, including emergency shut-off
devices/buttons or firefighting
measures (e.g., extinguishers or
sprinklers).
IFC 906.1
NFPA 30 21.6
NFPA 30A 9.2.5.2

Multiple fire extinguishers were noted in
the vicinity of the ASTs. Spill kits were
noted at the fuel distribution islands. The
north fuel distribution island is also
equipped with an emergency shutoff
button.
The site must install an emergency shutoff
function at the southwest fuel distribution
island.
All Compliance
Deficiency
3
28
29
Site Security
Equipment &
Devices
Document the presence of security
measures or equipment used to
prevent tampering, damage, release of
materials, or unauthorized access to
the AST and its appurtenances. Specific
materials may include fences,
restricted access entrances, locks,
cameras, or other similar features.
IFC 5704.4.2.3
NFPA 30 21.7.2.2
NFPA 30A 4.3.7.1
The site is surrounded by fencing and
gates that are only open during business
hours.
Of note, there is enough employee activity
at the site where any potential
unauthorized individuals should be quickly
noticed and approached.
None N/A N/A N/A
Physical Inspection Findings Worksheet Compass Minerals (Ogden, Utah)
Main Bulk Fuel Storage Area (Tanks T155, T156, & T190)

RMEC Environmental, Inc - 13 - *Identified as Critical Deficiency, Compliance Deficiency, or
Recommended Best Management Practice (BMP)
Inspection
Category Inspection Requirements Applicable Codes &
Regulations Observations
Inspection Determinations Photo
Log
Exhibit
#
Description of Deficiencies &
Recommended Corrective Actions AST ID Status*
Life Safety Codes and Other Issues
Other
Applicable
OSHA
Requirements
Evaluate fall protection, access/egress
structures, hazard communication,
(e.g., postings/placarding), and all
other OSHA-related issues that might
pertain to the routine operation,
maintenance, and inspection of the
AST.
29 CFR 1910.68
29 CFR 1910 Subpart D
NFPA 30A 9.2.5.4
UL 2085 34.1
Each AST was noted to properly display its
contents and proper hazard
communication.
No other obvious OSHA-related issues
were noted to be present.
None N/A N/A 1
2
3
5

APPENDIX D
PHOTO LOG

2024 AST Inspection Compass Minerals (Ogden, Utah)

Photo Log Exhibit #1:
View of fuel island ASTs from
the west. From left to right:
T155, T156, & T190.
Also pictured is the concrete
protective barrier and
signage on each AST
indicating their contents and
hazards.

Photo Log Exhibit #2:
View of the fuel island ASTs
from the east.
The yellow piping is the
supply piping equipped with
backflow valves and isolation
valves.

2024 AST Inspection Compass Minerals (Ogden, Utah)

Photo Log Exhibit #3:
View of the ASTs from the
southeast where the spill box
fill ports are located.

Photo Log Exhibit #4:
View inside the spill boxes.
Also pictured is the posted
transfer procedure.

2024 AST Inspection Compass Minerals (Ogden, Utah)

Photo Log Exhibit #5:
View of T155 from the
northeast.
Also visible is the supply line
along with the interstitial leak
detection port.

Photo Log Exhibit #6:
View of the east roof of T155
with its 2” normal vent, 3” fill
line and port, interstitial
monitoring port and
interstitial leak detector.

2024 AST Inspection Compass Minerals (Ogden, Utah)

Photo Log Exhibit #7:
View of the western roof
portion of T155.
Also visible is the clock-face
liquid level gauge, a bolted
(closed) manway with a
wireless tank monitor, 8”
emergency vent, electronic
level gauge, and manifolded
distribution piping (joined
with piping from T156) and
beneath a rain deflector.

Photo Log Exhibit #8:
View of the 8” emergency
vent on T155.

2024 AST Inspection Compass Minerals (Ogden, Utah)

Photo Log Exhibit #9:
View of the clock-face liquid
level gauge on T155. It is also
equipped with an alarm
indicator.
The exposed wiring appears
to have been intended for a
high-level alarm.

Photo Log Exhibit #10:
View of the wireless tank
monitor on T155.

2024 AST Inspection Compass Minerals (Ogden, Utah)

Photo Log Exhibit #11:
View of the entire top of
T155, looking north.
Also visible is the localized
corrosion occurring on the
AST.

Photo Log Exhibit #12:
View of all three tanks from
the roof of T156.
The localized corrosion is
extensive on each of the ASTs
is visible.

2024 AST Inspection Compass Minerals (Ogden, Utah)

Photo Log Exhibit #13:
View of some localized
corrosion and delamination
on T156.

Photo Log Exhibit #14:
View of the tank tags on
T155, indicating a UL
construction and emergency
venting requirements.
Other information is
included, but much of it has
been rendered illegible.

2024 AST Inspection Compass Minerals (Ogden, Utah)

Photo Log Exhibit #15:
View of the grounding wire
on T155.

Photo Log Exhibit #16:
Example of the tank supports
found on T155 & T156.

2024 AST Inspection Compass Minerals (Ogden, Utah)

Photo Log Exhibit #17:
View of the combined
distribution piping for T155 &
T156.

Photo Log Exhibit #18:
View of the distribution
pump, isolation valve,
solenoid valve, and the spill
catchment tray on T156.

2024 AST Inspection Compass Minerals (Ogden, Utah)

Photo Log Exhibit #19:
Another view of the
distribution pump, isolation
valve and solenoid valve on
T156.

Photo Log Exhibit #20:
View of the spill catchment
tray and drain piping on
T190. The drain goes directly
into the distribution piping.

2024 AST Inspection Compass Minerals (Ogden, Utah)

Photo Log Exhibit #21:
View of T190 from the south.

Photo Log Exhibit #22:
View of the tank tag on T190,
indicating a construction
standard of UL-2085.

2024 AST Inspection Compass Minerals (Ogden, Utah)

Photo Log Exhibit #23:
View of the manway lids for
the primary tank and the
interstitial space on T190.

Photo Log Exhibit #24:
View of absorbent material in
the interstice of T190.

2024 AST Inspection Compass Minerals (Ogden, Utah)

Photo Log Exhibit #25:
View of the distribution
piping of T155 & T156 that
runs through a replaceable
filter before passing
underground.

Photo Log Exhibit #26:
View of the isolation valve
and catchment tray on the
T155 & T156 distribution
lines.

2024 AST Inspection Compass Minerals (Ogden, Utah)

Photo Log Exhibit #27:
View of the underside of the
piping from Exhibit #26.
The exterior piping protector
has corroded to the point
where it no longer provides
any function.

Photo Log Exhibit #28:
View of the southwest fuel
distribution island.

2024 AST Inspection Compass Minerals (Ogden, Utah)

Photo Log Exhibit #29:
Another view of the
southwest fuel distribution
island.

Photo Log Exhibit #30:
View of the north distribution
island.

2024 AST Inspection Compass Minerals (Ogden, Utah)

Photo Log Exhibit #31:
View of the shear valve on
the north distribution island,
elevated over a foot above
ground level.

Photo Log Exhibit #32:
View of the digital readout
located directly north of the
ASTs in a metal control box.