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tanks that allow diesel fuels to freely flow from one tank to another tank. The manifold allows one submersible pump to draw diesel fuels from two or more tanks; thus, increasing the storage capacity of diesel fuels. A steel secondary containment was built around the ASTs to capture fuels in the event there is a spill and release. The ASTs are located on a concrete pad near the east side of the Generator Yard. Tanks are filled by an outside vender in tanker trucks with up to 5,000-gallon total capacity. Violation #710 - can be closed once a the engineers certification is received. This change to the plan would be considered a technical amendment. Just as a reminder since the Convault Onsite Integrity Test Procedures it will need to be available to the site and during inspections. The document references the STI SP-001 inspection checklists. I have attached those to this email. Locally developed checklists are acceptable as long as they are substantially equivalent (as applicable). Keep in mind that part of the requirement is to check the interstitial space of the tanks, per regulations and per the STI SP-001, Convault also requires it. During the phone conversation there was a question on when the SPCC plan needed to be certified by the Engineer. As stated on page 1 of the SPCC plan, As required by 40 CFR 112.5, this Plan will be reviewed and amended as necessary whenever there is a change in facility design, construction, operation, or maintenance which materially affects the facility's potential for the discharge of oil into or upon the navigable waters of the United States, or if the provisions provided in the Plan fail in response to an actual release. These amendments shall be implemented as soon as possible, but not later than 6-months after such a change occurs. At a minimum, this Plan will be reviewed, amended and re-certified once every five years, as required by 40 CFR 112.5 (b). Here is what the actual regulation states § 112.5(a) - Amend the SPCC Plan for your facility in accordance with the general requirements in §112.7, and with any specific section of this part applicable to your facility, when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge as described in §112.1(b). Examples of changes that may require amendment of the Plan include, but are not limited to: commissioning or decommissioning containers; replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of piping systems; construction or demolition that might alter secondary containment structures; changes of product or service; or revision of standard operation or maintenance procedures at a facility. An amendment made under this section must be prepared within six months, and implemented as soon as possible, but not later than six months following preparation of the amendment. A later subsection states the following § 112.5(c) - Except as provided in §112.6, have a Professional Engineer certify any technical amendments to your Plan in accordance with §112.3(d). At a minimum, per regulations, the plan needs to be reviewed and evaluated at least once every 5 years, form the date of the last review. If there is an change at the facility or the that falls under the criteria described above then the SPCC plan must be recertified at an earlier time than the 5 years. Although the generators have been at the facility and aren't new tanks that have been added to the facility, they are new to the SPCC plan. The certifying engineer, based on the SPCC plan, initially did not take into account the secondary containment of the operational equipment, or any of the other criteria that must be addressed by regulations for the operational equipment, the manifolded tanks or 2