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equipment still needs to comply with all aspects of CFR 112.1 through 112.7 which can be found here. This would include section 112.7(c), general secondary containment, 112.7(a)(3), be included in the facility diagram (which I did not see). These are just a couple of examples of sections within 112.1 through 112.7. 1 have included guidance on generator sets (attached) and on operational equipment, here (pages 4-7 through 4-14) . The full guidance document can be found here. For the manifolded tanks, the certifying engineer should address the that the secondary , the total capacity of manifolded containers is the design capacity standard for the sized secondary containment provisions. The concern here is that the tanks act as a single unit, in the event of a release will the secondary containment system be able to hold the capacity of the combined manifolded tanks? The engineer needs to certify that secondary containment is adequate in this case for the combined totals, not just a single tank. The engineer may have several options, based on the type of tanks. Permanently manifolded tanks are tanks that are designed, installed, or operated in such a manner that the multiple containers function as a single storage unit (67 FR 47122, July 17, 2002). Accordingly, the total capacity of manifolded containers is the design capacity standard for the sized secondary containment provisions (plus freeboard in certain cases). here (page 4-17) The SPCC plan state the following The four 10,000-gallon and one 2,000-gallon ASTs, are constructed of double walled steel encased in a reinforced concrete vault. Fuel piping is above ground. Tank manifolds are connected between 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 2