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of the inspection, there were no conditions which would impact on the ability of the tank to maintain its integrity, nor any visible evidence that the small underlying issues presented any articulable danger of increasing in severity or in scope. Both tanks A & B, having been well maintained and that the seal-paint of the overall tank has been effecfibe in preventing any substantial issues in addition to maintaining the overall integrity of the exterior steel shell, that the overall condition of the shells on both tanks has been quite good. There appear to be no issues with any of the tanks' primary vessels, as no signs beyond minor corrosion are present. Any maintenance indicated in this section should be scheduled for this coming year when weather conditions allow. Tank Equipment Piping: These two tanks are manifolded together with a 3-inch overhead pipe which allows for filling both tanks from a single Baker Box connection. Per the inspection report from San Joaquin County,dated March 14, 2019,there was concern that"permanent manifolding"of the tanks would have an impact on the secondary containment provisions, (67 CFR 47122, July 17,2002). An inquiry to this specific concern was made to US EPA in Region 9, San Francisco. The US EPA, individual, in charge of AboveGround Storage Tank regulations contacted Washington D.C. EPA for further clarification. The response from US EPA in Washington.D. C. Headquarters was as follows: the type of configuration in question would NOT be considered as permanently manifolded together. Here is the rationale: The piping, extending over the tops of the tanks would prevent one tank draining out the other tank if it failed, or visa versa. Put another way, if one tank were to split open, it would not cause the other tank to split open or drain out. So, they can be considered separate and distinct tanks. During the inspection of the ASTs and piping, it was - noticed that there was a substantial amount of surface , corrosion on the overhead piping. A closer inspection indicated that the corrosion was only surface corrosion, not ; . affecting the integrity of the steel pipes. It was ,S recommended that's the pipes should immediately have the corrosion removed and the pipes repainted. Owner/Operator immediately undertook this task and the -, pipes were repaired and repainted. At the top rear of the tanks, there are electric pumps from which fuel is carried overhead on 2-inch pipes to the dispensers. These pipes are also manifolded with a junction to one pipe for supply and that one pipe carries product to the dispensers at the fueling island. The pipes were inspected and determined to be in good 4: operating condition, along with the pumps.