Mississippi Administrative Code › Title 11 - Mississippi Department of Environmental Quality › Part 5 - Underground Storage Tank Regulations › Chapter 2 - Mississippi Commission on Environmental Quality Underground Storage Tanks Regulations Technical Standards and Corrective Action Requirements for Owners and Operators of Underground Storage Tanks (UST) (Adopted March 22, 1989; Amended August 25, 2011, Last Amended August 23, 2018) › Appendix 11-5-2-280.1 - GUIDELINES FOR THE EVALUATION OF UNDERGROUND STORAGE TANK CATHODIC PROTECTION SYSTEMS › Section 11-5-2-280.1-1 - GENERAL › Section 11-5-2-280.1-1-1.1 - Introduction

Current through June 25, 2024
The purpose of this document is to establish the policy
						of this office regarding the evaluation of cathodic protection systems
						operating on underground storage tank (UST) systems in the State of
						Mississippi. While conducting structure-to-soil potential surveys is the
						primary means of testing cathodic protection systems, other aspects related to
						the evaluation, installation, operation and repair of cathodic protection
						systems are also addressed in this document where necessary.
Evaluation of cathodic protection systems to ensure they
						are functioning as intended has proven to be one of the more problematic areas
						that has led to a great deal of confusion and various practices among
						individuals engaged in the field of cathodic protection. Because the applicable
						regulations contain no specific criteria and instead defer to industry
						standards, a large degree of latitude has historically been provided for
						interpretation of what constitutes an acceptable evaluation.
Since there are many factors that can affect cathodic
						protection, there is understandably no standard test method or "cookie-cutter"
						approach that will work at every site that has a cathodic protection system in
						operation. Therefore, the primary intent of this policy is to create a level
						playing field in which everyone engaged in the field of UST system cathodic
						protection in the State of Mississippi understands what is expected. The second
						focus of this policy is to provide that documentation sufficient to reproduce
						the results generated by a cathodic protection tester must be established in
						order to conduct a valid cathodic protection evaluation. To this end, forms
						that must be utilized when evaluating cathodic protection are included in
						Appendix K and L of this document.
It is further necessary to understand that the creation
						of this policy has necessitated a compromise to some degree. Every effort has
						been made so as not to place an unduly harsh burden on the tank owners and
						contractors who operate in the State of Mississippi. At the same time, it is
						necessary to be protective of human health and the environment to the degree
						required to achieve the charge of the Mississippi Department of Environmental
						Quality (MDEQ). This document represents the best efforts of the MDEQ to assure
						that cathodic protection systems operate as intended and effectively mitigate
						corrosion while being mindful of the economic constraints that must be
						considered.
Some of the more important points established with this
						guidance document are:
> Access to the soil directly over the structure that
						is being tested must be provided.
> Both "local" and "remote" structure-to-soil
						potentials must be obtained on galvanic systems.
> "Instant off' potentials must be obtained on all
						impressed current systems.
> Continuity/isolation must be established whenever a
						cathodic protection survey is conducted.
> Under certain conditions a "corrosion expert" must
						evaluate the cathodic protection survey.
> A person must meet certain minimum qualifications in
						order to conduct an effective evaluation.
Simply conducting a structure-to-soil potential survey
						does not adequately evaluate a cathodic protection system. Other considerations
						that may need to be addressed are outlined in the text of this document and
						include: continuity measurements; evaluation of rectifier operation; current
						distribution among an impressed current anode ground bed; consideration of
						voltage drops; assurance of wiring integrity; continuity bonds; as built
						drawings and others.
This policy is not intended to replace any statute or
						regulatory requirement concerning the installation, repair, operation or
						testing of cathodic protection systems. Rather, it is intended to state the
						interpretation of the MDEQ with regard to the implementation of those rules and
						regulations applicable to UST cathodic protection systems.