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Standard SP001 meets the intent of this "integrity testing" definition. The standard includes the following provisions as mentioned in this SPCC Rule language: ■ Testing of ASTs for integrity are shown to be on a regular schedule ■ Frequency and type of testing takes into account the container size and design ■ Visual inspection is combined with ultrasonic testing ■ Comparison records are to be kept ■ All tank appurtenances are to be inspected including supports ■ Frequent inspections of the AST exterior are required ■ Role of Professional Engineer - The owner or operator of an applicable facility must prepare the SPCC Plan in accordance with good engineering practices and the plan must be reviewed and certified by a licensed Professional Engineer (see §112.3(d)). The Professional Engineer is to use both good engineering practice and consideration of applicable industry standards to establish the procedures for required inspections and testing. (see §112.3(d)(1)(iii) and §I12.7(e)). Industry Standards - The SPCC Final Rule issued in 2002 includes a "Section by Section Analysis" commonly called the Preamble to the Rule. This analysis includes a summary of all public comments and responses to the comments. The comments on § 112.1(e) includes a reference to Industry standards, "Under this Rule, a facility is required to at least consider the use of all relevant measures, including the use of industry standards, as a way to implement those measures. The requirement comes in the language of revised § 112.3(d)(1)(iii) requiring the PE to attest that `the Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of this part.' A facility should use industry standards whenever possible in preparing and implementing its SPCC Plan, and should discuss their use in Plans." 13