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4109 Zeering Rd., Denair, CA 95316 <br /> http://www.convault.com,john@convault.com <br /> 800-222-7099,209-632-7571 <br /> FAX 209-632-4711 <br /> Date: August 19,2002 <br /> TO WHOM IT MAY CONCERN <br /> Subject: Integrity Testing of Convault Tanks <br /> Convault shop fabricated aboveground storage tanks have 4 to 6 inch high legs, <br /> which make them visible from the bottom and all sides. Furthermore,Convault tanks <br /> have secondary containment with leak detection capability and are expected to be <br /> checked and inspected on regular basis.The probability of any fuel discharge from <br /> Convault tank due to primary tank failure is highly minimal as any discharge will be <br /> detected in the leak detector tube and the fuel will be contained in the integral secondary <br /> containment. <br /> In view of the above,Convault does not recommend an integrity test on its tanks <br /> when preparing,updating or revising the SPCC plans. Convault recommends an integrity <br /> test on its tank only if there is a substantial reason to carry out such a test.Typical reasons <br /> would include the detection of fuel in the secondary containment,the tank surviving a <br /> catastrophic event such as a fire or a heavy vehicle impact,or the Authority Having <br /> Jurisdiction(such as a fire marshal)specifically requiring an integrity test. If testing is <br /> required,please refer to Convault owner manual testing protocol. <br /> Should you have any questions,please contact the undersigned. <br /> Very Truly Yours, <br /> John Ekhtiar <br /> Vice President, Engineering <br /> SPCC Testing Requkements.doc <br />