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size, configuration, and design shall be determined in accordance with industry standards. 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. Comparison records and other records of inspections and tests must be maintained on site. Immediately ensure that the SPCC plan accurately reflects the policies and procedures at the facility and submit proof to the EHD. This is a repeat violation, Class ll. 711 Materials Response: 711 Materials conducts inspections of each aboveground container on a regular schedule and whenever repairs are made. This schedule includes monthly and annual inspections. The SPCC Plan has been updated to reflect this inspection schedule and is included in Attachment 2. The personnel performing these inspections are knowledgeable about storage facility operations, the type of ASTs and associated components present at the facility, spill control systems, and characteristics of the materials stored on site as described in the Steel Tank Institute's SP-001. Item # 712: CFR 112.8(c)(6) Failed to test or inspect each container for integrity based on industry standards. • An industry standard was not chosen for the 300-gallon motor oil tank, 300 gallon used oil tank, 300-gallon hydraulic oil and 55 gallon drums of gear oil. • Page 18 of the SPCC plan states that, "The facility will follow the manufacturer's recommendations for testing and maintenance as described in the Con Vault Owner's Manual." The SPCC plan does not discuss the qualifications of personnel performing tests and inspections, frequency and type of testing and inspections. The inspection schedule in the SPCC plan deviates from the testing and maintenance described in ConVault's Owner's Manual. • The SPCC plan also states on page 18, "The testing program is based on the U.S. EPA letter, dated September 30, 2002, to the Petroleum Marketer's Association of America (PMAA)." This is a deviation from an industry standard and does not include a discussion of environmental equivalence. Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever repairs are made. The qualifications of personnel performing tests and inspections, frequency and type of testing and inspections that take into account container size, configuration, and design shall be determined in accordance with industry standards. 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. Comparison records and other records of inspections and tests must be maintained on site. Immediately ensure that an industry standard is chosen and adequately discussed in the SPCC plan or provide equivalence as allowed by CFR 112.7(a)(2) and submit proof to the EHD. If an owner or operator deviates from applicable industry standards to develop an integrity testing program, then a PE must certify an environmentally equivalent alternative in the SPCC Plan. The Plan must provide the reason for the deviation, describe the alternative approach, and explain how it achieves environmental protection equivalent to the applicable industry standard. This is a Class 11 violation. July 3, 2019 3