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Cesar Ruvalcaba [EH] <br />From: <br />Cesar Ruvalcaba [EH] <br />Sent: <br />Friday, April 12, 20192:01 PM <br />To: <br />'Burgin, Andy C (Fresno) USA' <br />Cc: <br />Gothan, John J (Lathrop) USA <br />Subject: <br />RE: Calaveras Materials follow up on items during inspection - PR0516365 <br />Attachments: <br />Attachment 1.pdf, Attachment 2.pdf, SP001 6th ed Rion checklists (7).docx <br />Mr. Burgin, <br />The return to compliance has been received and reviewed. All APSA violations have been closed. <br />Regarding the industry standard, here are my observations with amended SPCC plan. <br />The Mapistry Technical Memorandum partially quotes 40 CFR Part 112.8(c)(6). <br />Here is the full regulation <br />Test or inspect each aboveground <br />container for integrity on a regular <br />schedule and whenever you make material <br />repairs. You must determine, in <br />accordance with industry standards, <br />the appropriate qualifications for personnel <br />performing tests and inspections, <br />the frequency and type of testing <br />and inspections, which take into account <br />container size, configuration, <br />and design (such as containers that <br />are: shop -built, field -erected, skidmounted, <br />elevated, equipped with a <br />liner, double -walled, or partially buried). <br />Examples of these integrity tests <br />include, but are not limited to: visual <br />inspection, hydrostatic testing, radiographic <br />testing, ultrasonic testing, <br />acoustic emissions testing, or other <br />systems of nondestructive testing. <br />You must keep comparison records and <br />you must also inspect the container's <br />supports and foundations. fn addition, <br />you must frequently inspect the outside <br />of the container for signs of deterioration, <br />discharges, or accumulation <br />of oil inside diked areas. Records of inspections <br />and tests kept under usual <br />and customary business practices satisfy <br />the recordkceping requirements of <br />this paragraph. <br />