11 Miss. Code. R. § 5-2-280.1-4-4.1 - Qualifications

In order to test cathodic protection systems in the State of Mississippi, an individual must meet certain minimum qualifications. It is the intent of the MDEQ that those individuals who meet the minimum qualifications perform testing in a manner that is consistent with the policies of this guidance document. Should an individual who meets the minimum qualifications as described below not possess the knowledge and expertise needed to properly evaluate a cathodic protection system, that individual should not attempt to undertake such an evaluation.

While it is not necessary to be an "expert" to test cathodic protection systems in most cases, it should be recognized that the proper evaluation of the two types of cathodic protection systems may require differing levels of expertise. Impressed current systems are inherently more involved and require a higher level of understanding than galvanic systems. In addition, certain circumstances and conditions may exist that would preclude an individual from making an effective evaluation of a cathodic protection system without the assistance of someone who is more qualified.

Because the testing of impressed current systems is inherently more complicated, someone who is only minimally qualified as a "tester" should recognize that he may or may not be able to properly evaluate all such systems. Galvanic cathodic protection systems that are operating as designed are normally straightforward and a lesser degree of expertise is needed to properly evaluate such systems. However, troubleshooting and/or repair of such systems may require someone who has a higher level of expertise than a person who is only minimally qualified as a tester.

Scenarios that require an expert to either conduct or evaluate the cathodic protection survey are listed in Section 7.2 of this document. It should be recognized that there might be other circumstances that require an expert although they may not be specifically listed. A listing of those individuals who meet the qualifications of an expert (certified as either as a "corrosion specialist" or a "cathodic protection specialist") can be found at the web site of NACE International (www.nace.org).

Listed below are the minimum qualifications necessary to test cathodic protection:

> Anyone who meets the definition of "cathodic protection tester" as found in 40 CFR 280.10 is recognized as qualified to test cathodic protection.

> Anyone who holds a certification from NACE International which that organization recognizes at a minimum as qualifying that person as a cathodic protection tester.

> Anyone who is certified by the MDEQ as a UST installer is recognized as being able to test cathodic protection systems provided they are familiar with the concepts involved and abide by the requirements contained within this guidance document. If a UST installer does not understand the basic concepts related to the testing, maintenance and operation of cathodic protection systems, that person should not attempt to evaluate such systems.

Should it be determined that a MDEQ certified UST installer is conducting evaluations of UST cathodic protection systems in a manner that is not consistent with the intent of the MDEQ policy, they may be subject to penalty and/or revocation of their UST installer certification upon a determination of good cause by the Mississippi Commission on Environmental Quality.

Notes

11 Miss. Code. R. § 5-2-280.1-4-4.1