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Line item 9710 narratiurJresponse- The PE wet-stamp/certification wall include specific <br /> references to alternative methods for conducting equivalent protocols for <br /> a) Inspections wduch are conducted by the owner/operator on a frequency as stipulated by <br /> the AI-II_ SPC Corp recommends weekly inspections; federallsmt ilocal guidelines <br /> normally require monthly inspections by a qualified employee of the FBO <br /> owner/operator_ <br /> b) Periodic Integrity Tests conducted by SPC Corp were done in accordance with <br /> 4CCFR112 (US EPA) as well as Chapter 7-Regional Inspectors Crude under the "hybrid" <br /> section of the reference_ SPC Corp has encountered numerous events in onsite testing <br /> where STT SP001 created"destructive'testing by irnposing air-pressure audler <br /> vacuuminegative pressure on both primary and secondary containment m both damage to <br /> weld seams due to metal fatigue as wtE as failure to adequately make the test subject. <br /> "leak-tight" during the test----this issue created`false-negative"results which have been <br /> demonstrated to AHA that the altemahve test methods referenced m the Hmal of <br /> the SPCC plan are equivalent and, in fact, more accurate than STI SP0o1_ WeiSPC Corp <br /> do NOT market this conclusion and would prefer to keep any marketplace dissent <br /> between STT and SFC Corp a separate matter_ The PE has wet-stampedlcertified the <br /> periodic integrity testing procedures are equivalent and meet federaPstatellocal <br /> requirements_ <br />