UST Program - Local Guidance (LG) 145-2

To: Local Agencies and Other Interested Parties

This is an update to the LG 145-1 letter titled Clarification of Corrosion Specialist and Cathodic Protection Tester, which focused on the increasing concerns that under-qualified persons may be taking part in the design, installation, and testing of cathodic protection systems for underground storage tanks (USTs). Since the original LG 145-1 was issued, the National Association of Corrosion Engineers (NACE International), a nationally recognized organization that specializes in corrosion control, has made changes to their certification categories. In particular, they have added two new categories, cathodic protection tester and cathodic protection technician, and have changed some of the requirements for the cathodic protection specialist. Attached is an update to the tables provided in the LG 145-1 letter.

The information below has been prepared on the qualifications of Corrosion Specialist and Cathodic Protection Tester as they are set forth in Section 2611, Chapter 16, Title 23 of the California Code of Regulations (CCR). This information will be helpful to tank owners, local agencies, and other interested parties in determining who is qualified to do this work.

CORROSION SPECIALIST

The State UST regulations require field-installed cathodic protection systems to be designed and certified by a Corrosion Specialist as they are set forth in Section 2635, Chapter 16, Title 23 of the California Code of Regulations (CCR). A Corrosion Specialist (referred to as Corrosion Expert by USEPA) encompasses NACE certified corrosion specialist and cathodic protection specialist as they are defined in Table 1. A Corrosion Specialist, as defined in the UST regulations, must demonstrate adequate education and training to be qualified to engage in the practice of corrosion control on buried metal piping systems and tanks. Proof of qualification includes:

1. accreditation or certification by NACE International as either Corrosion Specialist or Cathodic Protection Specialist. The attached table highlights the areas of training and work experience required to become certified.
2. a state registered professional Corrosion Engineer. No other training or certification is required.
3. state registration as a professional engineer other than a registered Corrosion Engineer with additional certification or licensing that includes education and experience in corrosion control of buried or submerged metal piping systems and tanks. This additional certification or licensing can be achieved by obtaining NACE's Corrosion Specialist or Cathodic Protection Specialist certification.
4. state registration as a professional engineer other than a registered Corrosion Engineer with additional certification or licensing that is equivalent to NACE's Corrosion Specialist or Cathodic Protection Specialist certification.

CATHODIC PROTECTION TESTER

The State regulations require field-installed cathodic protection systems to be tested periodically in accordance with voluntary consensus standards by a Cathodic Protection Tester. In order to qualify as a Cathodic Protection Tester, one must demonstrate an understanding of the principles and measurements of all common types of cathodic protection systems as applied to buried or submerged metal piping and tank systems. A Cathodic Protection Tester does not need to be a registered engineer or NACE certified. However, there are seven categories of NACE certification that meet the minimum requirements for Cathodic Protection Tester education and experience stipulated in Section 2611, Chapter 16, Title 23 of the California Code of Regulations (CCR) CCR. These are:

1. Corrosion Specialist
2. Cathodic Protection Specialist - Level 3 ( Modified )
3. Senior Corrosion Technologist
4. Corrosion Technologist
5. Corrosion Technician (with the stipulation that the technician performs system testing under the direct oversight of one of the above four).
6. Cathodic Protection Tester - Level 1 ( New )
7. Cathodic Protection Technician - Level 2 ( New )

Other equivalent training and certification which meet the education and experience requirements for Cathodic Protection Tester may be available other than through NACE.

NACE CERTIFICATION

All seven NACE certification levels are detailed in Tables 1 & 2. Verification of the certification level of any individual can be obtained from NACE International. Some local agencies may impose requirements more stringent than the State regulations. Owners and operators of USTs and members of the contracting community should confer with their local UST agencies to determine whether there are any differences between local and State requirements.

CONTRACTOR LICENSING

Installation of the cathodic protection system at the job site must be performed by a contractor licensed by the Contractors State License Board. Licensing as described in the SWRCB's LG 48-5 should be followed. In short, General Engineering (A), General Building (B), Plumbing (C-36), or Limited Specialty (C-61/D-40) licenses may qualify.

If you have questions regarding this letter, please contact Dave Holtry at (916) 341-5692. For information on NACE International's accreditation programs, you can contact NACE International at (713) 492-0535.

Sincerely,

[ original signed by David Holtry ]

Elizabeth L. Haven, Manager
Underground Storage Tank Program

Enclosure