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Cesar Ruvalcaba [EH] From: Cesar Ruvalcaba [EH] Sent: Wednesday, December 19, 2018 9:57 AM To: 'Cameron J. McGovern' Subject: FW:ASPA/SPCC inspection report - 1000 Roth Rd, French Camp - PRO523352 Mr. McGovern, After review of the submitted return to compliance certification. Item #301 will require a copy of the PE certified amendment to be submitted since the change is a technical amendment. comments for item #602— Section 15.6 appears to address the regulatory requirements for 40 CFR 112.8(c)(6). Part of the regulatory requirement of 40 CFR 112.8(c)(6) is to "Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs. You must determine, in accordance with industry standards, the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections,which take into account container size, configuration, and design..." The discussion states that that the facility is following provisions of 40 CFR 112.8(c)(6)for oil storage tanks, based on good engineering practices and measures implemented by the facility.The discussion does not address tests or inspections for integrity that are in accordance with an industry standard.There are several construction standards that are listed which are not the same as test or inspection standards.This deviates from the requirements of 112.8(c)(6) which the discussion states are being followed.The description of the tanks listed in the discussion, being elevated, allowing inspection of the entire tank surface, and interstitial space inspections are not referenced to any industry standard.The inspection procedure of elevated tanks allowing inspection of all sides, including the bottom, or the tank being installed on an impervious surface which also allows for bottom inspection by means of rapid leak detection is not referenced to an industry standard. The discussion goes on to mention that the tank's physical configuration, combined with periodic inspections, ensures that any small leak that could develop will be detected before it can become significant. Periodic visual inspection provides an appropriate and effective means of assessing the condition of the tank and its suitability for continued service.There is no industry standard referenced to support this. The discussion does mention that facility personnel perform periodic inspections, as described in Section 8.0, and in accordance with the provisions of the inspection checklist. Section 8.0 of the plan seems to address 40 (CFR) 112.7(e)which in part states to Conduct inspections and tests required by this part in accordance with written procedures that you or the certifying engineer develop for the facility. In this discussion it goes on to state that UPRR personnel perform a documented inspection of aboveground storage tanks (ASTs) on a quarterly basis. As you stated in your response section 8.3, Deviation from Industry Standard, allows for the deviation from the monthly inspection frequency recommended by STI SP-001 and was certified by the Professional Engineer.The issue is that the deviation certified by the professional engineer is for the monthly and annual (which are conducted quarterly) inspections.Assuming that the industry standard is the mentioned STI-SP001,for section 112.(c)(6),there is a requirement under the industry standard that tanks over 5000 gallons require an inspection by a certified STI-SP001 every 5 or 20 years, depending on what the Professional Engineer certifies.There is no mention for