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A second round of who, what, and whys should also occur for this factor. The <br /> investigation and interviews resulted in the following questions: <br /> • Who designed and installed the initial system? <br /> • Was the initial system adequate to be reinstalled when the generator and fuel <br /> system were reconfigured? <br /> • Who reinstalled the fuel system? <br /> • Was the reinstallation checked by the original manufacturer(s)? <br /> Eaton has provided fuel systems to the quarry for a number of years. It provided and <br /> installed the fuel system utilized in the 2014 primary power generator installation and <br /> continues to provide equipment and services to CSQ. <br /> The initial system was adequate to protect the generator from spilling during transfer <br /> operations. Due to the capacity of the tanks onsite, the site must provide secondary <br /> containment for fuel tanks and transfers. The tanks onsite were and continue to be either <br /> double walled or are kept within containment structures. Fuel transfer areas should also <br /> have secondary containment protection against spills. The system provided by Eaton <br /> addressed the most common spill condition of overfilling by providing a pumped return <br /> system. If the day tank of the prime power generator is overfilled, overfill will be pumped <br /> to flow back into the bulk tank. This requires control of the elevations of the tanks, lines, <br /> and vents. <br /> In the initial 2019 installation outside Portal #4, the elevation of the top of the day tank <br /> vent was at approximately the middle of the bulk tank and was also within the Conex. The <br /> intended plumbing design requires that the top of the vent pipe be higher than the `elbow' <br /> of the return piping into the bulk tank, i.e. above the top of the bulk tank elevation (Figure <br /> I.A.). Figure 24 shows the original 2014 installation of the primary power generators <br /> outside Portal #4. The vent pipe of the day tank can been seen in the middle of the photo <br /> exiting the roof of the Conex. The vent pipe would partially fill until the overflow begins <br /> to flow into the bulk tank via the return flow piping (Figure 1.A.). Both the day tank and <br /> the bulk tank would need to overflow for any of the tank vents to overflow. The design of <br /> the 2014 and 2019 installation does not provide secondary containment for fuel transfers if <br /> the elevations of the tanks, transfer lines, or tank vents are changed. <br /> 34 <br />