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Spill Prevention Control and Countermeasure Plan Food Express, Inc. 1250 Madruga Road FOOD EXPRESS, INC. Lathrop, California 95330 May 2020 Page 21 Regardless of size, all containers that store oil must be visually inspected regularly by an Owner's Inspector(OI). An Owner's Inspector is the owner or owner's designee responsible for conducting owner's periodic AST visual inspections. The Owner's Inspector performing these inspections shall be knowledgeable about: • The storage facility's operations, • The characteristics of the stored liquid, • The type of AST and its associated components, and • The spill control system for the facility. Owner's inspector must also be familiar with pumping, piping, and valve operations of the AST system. Visual inspections by Owner's Inspector are designed to detect system malfunctions, equipment deterioration, and operator errors that could lead to oil releases into the environment. Visual inspections include observations of the exterior of tanks for signs of deterioration or spills (leaks), observations of foundations and supports for signs of instability, gauge of secondary containment interstitial space for the existence of liquids, and observations of vents, fills, and dispensers for signs of poor connection or anything that could cause a spill. Visual inspections also include observations of the applicable piping joints, valves, and supports. Records of these visual examinations are maintained in Appendix F. The SPCC Coordinator maintains these documents for at least three years. Although the USEPA conceded ground on smaller containers, it still held that containers over 30,000 gallons in shell capacity should be subject to formal specialized integrity testing and required a certified Professional Engineer (P.E.) determine the type and schedule of inspection and/or testing that was needed to ensure the containers could maintain their integrity. Relatively recently STI performed a review and evaluation of the effectiveness of the SP001 standard' with containers with the following attributes: a.) Store oil, b.) Category 1, c.) Sized b/t 5,001 and 30,000 gallons in capacity. STI determined that regular visual inspections performed by the Owner's Inspector were not effective in detecting threatening leaks in ASTs. Consequently, for ASTs of this type, SP001 mandates Formal Certified Inspections (FCI) be performed by STI SP001 Certified Inspectors (STICI) at intervals no greater than 20 years. Since AST leaks are generally caused about by corrosion and other similar forces that occur over time, it is logical to conclude that new ASTs are the least likely to experience a release. Consequently it is the most logical to apply the maximum 20 year interval to a new AST, unless 7 SP001 AST Inspection Standard,6`h Edition©2018 Steel Tank Institute,January 2018 =AkTc Page 21