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/y mapistry 2120 University Ave, Berkeley, Caldornia 94704 stjpppn6 Dst I (800)553-7420 Technical Memorandum TO: Whom It May Concern FROM: Ryan Janoch, PE (C78735) - Mapistry SUBJECT: Mapistry SPCC Inspection Forms and SP001 Forms - DRAFT DATE: April 5, 2019 The Spill Prevention Control and Countermeasure (SPCC) Rule requires facilities "test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs" and "conduct inspections and tests required by this part in accordance with written procedures that you or the certifying engineer develop for the facility."' It is up to the facility owner/operator in conjunction with their environmental team, which may include a Professional Engineer (PE), to implement a routine inspection program. An inspection form from the Steel Tank Institute (STI), which is the SP001 Monthly Inspection Checklist ("SP001 checklist"), is used by some facilities. However, many facilities opt for equivalent forms, such as Mapistry's SPCC inspection form, that when used in conjunction with a robust training program on inspection best practices and with the overall SPCC plan, can exceed the SP001 checklist. Generally, the substitution of the inspection form is done via an amendment to the SPCC Plan and this memo can be referenced as the reason for substituting (see below for equivalency explanation). On the SP001 form, Section 1.0 Tank Containment includes questions on the containment structure, primary tank, containment drain valves, and pathways/entry. Mapistry's SPCC inspection form consolidates those items into a single question on Containment Structure and provides context "Is the tank containment free of water, spills, debris, cracks or fire hazards? If applicable, is the valve closed?" Similar sections on the SP001 form have been consolidated for the Tank Condition, Piping Condition, and notes. The inspector then has a streamlined inspection process so they can focus on finding deficiencies and taking corrective actions. In addition, the SP001 form consolidates tanks into a single line at the top, which reduces the likelihood that variability across tanks is properly accounted for during the inspection. In Mapistry, each set of questions is tied to a specific tank/container and linked to the site map, further ensuring naming consistency with tanks located on the map. In addition to the above features, Mapistry's SPCC inspection form tracks corrective actions, including descriptions of necessary corrective action(s), photos and completion notes. This feature combined with the automated emails communicating inspection completion and findings to an environmental team 140 CFR Part 112.8(c)(6) 40 CFR 112.7(e)