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referenced or an environmental equivalence claim made. Furthermore,the submitted SP-001 certified inspection report
<br /> classified the 10,000 gallon tank as a Category 2 under STI standards.A 10,000 gallon tank classified as a category 2 does
<br /> not qualify for a 20 year inspection cycle,and per the standard would require additional testing.The formal inspection
<br /> frequency of 5 years has been selected by the certified inspector. Category 2 tanks between 5,001 gallons and 30,000
<br /> gallons with a formal inspection schedule of 5 years will also require a leak test every 10 years by owner or owner's
<br /> designee per STI guidelines. Following are the regulations from which the decision not to close the violations was made.
<br /> 40 CFR definition
<br /> Mobile refuelermeans a bulk storage container onboard a vehicle or towed,that is designed or used solely to store
<br /> and transport fuel for transfer into or from an aircraft, motor vehicle, locomotive,vessel,ground service equipment,
<br /> or other oil storage container.
<br /> (EPA question and answer on the subject can be found here)
<br /> 40 CFR 5112.8(c)(6)
<br /> (6) Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material
<br /> repairs. You must determine, in accordance with industry standards, the appropriate qualifications for personnel
<br /> performing tests and inspections, the frequency and type of testing and inspections,which take into account
<br /> container size,configuration, and design (such as containers that are: shop-built,field-erected, skid-mounted,
<br /> elevated, equipped with a liner,double-walled,or partially buried). Examples of these integrity tests include, but are
<br /> not limited to:visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions
<br /> testing,or other systems of non-destructive testing.You must keep comparison records and you must also inspect
<br /> the container's supports and foundations. In addition,you must frequently inspect the outside of the container for
<br /> signs of deterioration,discharges,or accumulation of oil inside diked areas. Records of inspections and tests kept
<br /> under usual and customary business practices satisfy the recordkeeping requirements of this paragraph. (All tanks
<br /> should have an industry standard for inspections/testing. Refer to Chapter 7 of the SPCC Guidance for Regional
<br /> Inspectors, here)
<br /> Note the following pages in the guidance
<br /> Page 7-41 and 7-72 of the"SPCC Guidance for Regional Inspectors,"
<br /> "Integrity testing in accordance with industry standards is required for all aboveground bulk storage containers located
<br /> at onshore facilities (except oil production facilities),unless the facility owner/operator implements an environmentally
<br /> equivalent method according to§112.7(a)(2)and documents the deviation in the SPCC Plan"
<br /> Page 7-43 of the"SPCC Guidance for Regional Inspectors,"
<br /> If an owner or operator deviates from applicable industry standards to develop an integrity testing program,then a PE
<br /> must certify an environmentally equivalent alternative in the SPCC Plan.The Plan must provide the reason for the
<br /> deviation,describe the alternative approach, and explain how it achieves environmental protection equivalent to the
<br /> applicable industry standard.
<br /> Page 7-45 of the "SPCC Guidance for Regional Inspectors,"
<br /> In any case where the owner or operator of a facility uses an alternative means of meeting the integrity testing
<br /> requirement of§112.8(c)(6)or§112.12(c)(6),the SPCC Plan must provide the reason for the deviation,describe the
<br /> alternative approach,which is most likely to be a site-specific inspection program (i.e.,hybrid inspection program),and
<br /> explain how it achieves equivalent environmental protection(§112.7(a)(2)),while considering good engineering practice
<br /> and industry standards. In cases where industry standards apply to a container,the PE would need to explain how an
<br /> inspection or test that deviates from an applicable industry standard is environmentally equivalent to following
<br /> established industry standards and how it will be implemented in the field.This determination is site-specific and based
<br /> on good engineering practice as determined by the certifying PE.The hybrid inspection program should include the
<br /> recommended minimal elements described in Section 7.5.3 for a PE-developed site-specific integrity testing program.
<br /> Figure 7-4 provides a summary of integrity testing and inspection program documentation for bulk storage containers at
<br /> onshore facilities,by type of SPCC Plan and standard applicability case.
<br /> Page 7-45 of the"SPCC Guidance for Regional Inspectors," It maybe appropriate to deviate from portions of an industry
<br /> standard under certain circumstances.Although the Plan preparer must determine,in accordance with industry
<br /> standards,the appropriate qualifications for personnel performing tests and inspections,and the frequency and type of
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