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tanks is being presented as an overfill prevention system. Per SPCCguidance (page 3-11)A procedure for smaller containers that ensures communication between the container gauger and the pumper,is in accordance with §§112.8(c)(8)(iii)and 112.12(c)(8)(iii)and therefore does not require an environmental equivalence determination. Guidance attached) Violation#711 -Failed to perform scheduled tank tests or inspections by appropriately qualified personnel. Response submitted stated Integrity testing was conducted by a certified SP-001 inspector on March 8, 2019.A copy of the test results was forwarded to the EHD on May 7th,2019.Testing/inspections for all qualified tanks per industrial standards are addressed in the SPCC Plan. Observations/comments:The SPCC plan and other sections of the SPCC plan state that the mobile refueler is not defined as a bulk storage container.This goes against SPCC regulations and EPA guidance/interpretation. Under SPCC regulations the mobile refueler is a bulk storage container under certain conditions and is only exempt from the requirement of having sized secondary containment. Per a description of how the mobile refueler is used,it meets the definition of a mobile refueler under SPCC regulations and would be considered a bulk storage container. Furthermore the 10,000 gallon tank is the only tank that has an industry standard referenced and it does not follow the STI SP-001 standard,the standard requires an annual inspection by facility personnel, in addition to monthly inspections.The STI SP-001 checklists have been attached. More information on the standard can be obtained here this is not based of the most recent edition of the standard and is only a brief overview. The other bulk storage tanks need an industry standard referenced or an environmental equivalence claim made. Furthermore,the submitted SP-001 certified inspection report classified the 10,000 gallon tank as a Category 2 under STI standards.A 10,000 gallon tank classified as a category 2 does not qualify for a 20 year inspection cycle,and per the standard would require additional testing.The formal inspection frequency of 5 years has been selected by the certified inspector. Category 2 tanks between 5,001 gallons and 30,000 gallons with a formal inspection schedule of 5 years will also require a leak test every 10 years by owner or owner's designee per STI guidelines. Following are the regulations from which the decision not to close the violations was made. 40 CFR definition Mobile refuelermeans a bulk storage container onboard a vehicle or towed,that is designed or used solely to store and transport fuel for transfer into or from an aircraft, motor vehicle, locomotive,vessel,ground service equipment, or other oil storage container. (EPA question and answer on the subject can be found here) 40 CFR 4112.8(c)(6) (6) 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 (such as containers that are: shop-built,field-erected, skid-mounted, elevated, equipped with a liner,double-walled,or partially buried). Examples of these integrity tests include, but are not limited to:visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing,or other systems of non-destructive testing.You must keep comparison records and you must also inspect the container's supports and foundations. In addition,you must frequently inspect the outside of the container for signs of deterioration,discharges,or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices satisfy the recordkeeping requirements of this paragraph. (All tanks should have an industry standard for inspections/testing. Refer to Chapter 7 of the SPCC Guidance for Regional Inspectors, here) Note the following pages in the guidance Page 7-41 and 7-72 of the"SPCC Guidance for Regional Inspectors," "Integrity testing in accordance with industry standards is required for all aboveground bulk storage containers located at onshore facilities (except oil production facilities),unless the facility owner/operator implements an environmentally equivalent method according to§112.7(a)(2)and documents the deviation in the SPCC Plan" Page 7-43 of the"SPCC Guidance for Regional Inspectors," 3