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systems; (iv) Culverting,gutters, or other drainage systems (v) Weirs, booms,or other barriers (vi Spill diversion ponds; (vii) Retention ponds; or (viii) Sorbent materials. The second is found in section 112.8 Construct all bulk storage tank installations (except mobile refuelers and other non-transportation-related tank trucks) so that you provide a secondary means of containment for the entire capacity of the largest single container and sufficient freeboard to contain precipitation.You must ensure that diked areas are sufficiently impervious to contain discharged oil. Dikes, containment curbs, and pits are commonly employed for this purpose. You may also use an alternative system consisting of a drainage trench enclosure that must be arranged so that any discharge will terminate and be safely confined in a facility catchment basin or holding pond. Violation tt 710 I've scanned in section 5 where it shows that we have been checking monthly. I spoke to Gary and said that this describes how we check to satisfy what is being checked for monthly. This violation was for not having an industry standard referenced in the SPCC plan.This standard would need to be certified and approved by the Professional Engineer. I have attached discussion on industry standards that are found in EPA guidance document. Here is a link for the typical standard used for your types of tanks,this is only an example,the Professional Engineer needs to certify in the SPCC plan what the standard is and determine,according to the standard, the appropriate qualifications for personnel performing tests and inspections,the frequency and type of testing and inspections,which take into account container size,configuration,and design.The link can be found here. Depending on what standard is chosen for the facility the inspection forms being used may not be adequate. Some standards have their own inspection checklists for monthly and/or yearly inspections. I have included sample inspection checklists of a standard,as an example. The adequacy of the inspection forms cannot be determined until an engineer certifies a standard. Here is the regulation: Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs.You must determine, in accordance with industry standards,the appropriate quarrlications for personnel performing tests and inspections,the frequency and type of testing and inspections,which take into account container size,configuration, and design (such as containers that are: shop-built, field-erected, skid-mounted, elevated, equipped with a liner,double-walled,or partially buried). Examples of these integrity tests include, but are not limited to:visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing,or other systems of non-destructive testing.You must keep comparison records and you must also inspect the container's supports and foundations. In addition,you must frequently inspect the outside of the container for signs of deterioration,discharges,or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices satisfy the recordkeeping requirements of this paragraph. Violation tt 711 I've scanned in the pages showing that we are actively checking once a month and Gary will be coming at the end of this month or the beginning of next to test again for the tank tests. This violation has been closed. I wanted to mention that, as stated above, the Inspection frequency and chekllsts may change depending on which standard is selected. Currently the SPCC plan does not required any sort of tank tests.This 2