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regular schedule of integrity testing in accordance with §§112.8(c)(6) and <br /> 112.12(c)(6), and applies ONLY to the three (3) ConVaultTanks. The methodology <br /> for testing these two tanks is as follows: <br /> Opening the secondary containment inspection port, a hydrocarbon sensor is <br /> inserted into the secondary to ascertain whether or not any product is present, <br /> which could indicate a leak in the primary vessel. (No leaks detected in either <br /> tank). Hydrocarbon device is OMNTEC BOA. <br /> A visual inspection is then undertaken into the secondary containment, with a <br /> photograph as a record of the secondary containment area, to verify that no <br /> hydrocarbon product is in the secondary containment area. <br /> As is normal with technology, other or newer devices may be utilized for either or <br /> both Hydrocarbon detection or steel thickness measurements. This section is not <br /> designed to limit the determination of measuring devices applied for testing <br /> purposes. <br /> These tanks undergo the same inspection protocol for visual & hydrocarbon <br /> sensor detection for product in secondary containment area; a steel thickness <br /> measurement to assure that the steel thickness would maintain a level in <br /> accordance with UL142 steel thickness construction standards as is the industry <br /> standard is not practicable for a concrete clad tank. This protocol is in <br /> accordance with 40 CFR 112.8(c)(6) EPA guidelines for tank testing and is <br /> adopted herein for testing purposes in this SPCC Plan <br /> After inspections and tank integrity testing, the overall condition of the tanks is <br /> acceptable although ongoing corrosion protection should be conducted; <br /> moreover, the frequency of periodic integrity for all seven ASTs is established as <br /> 5 years from the most-recent periodic integrity test (tentatively scheduled for <br /> April 13, 2025). <br /> STI-SP0O1 <br /> The US EPA has accepted the STI-SP001 as an industry standard for inspection- <br /> testing of ASTs such as the two fuel tanks. The three ConVault tanks in the yard <br /> currently have manual monitoring to locate leaks, if any, in the secondary <br /> containment of each Fuel Tank. Additionally, these tanks are raised and have <br /> Continuous Release Detection Monitoring via visual inspections beneath the <br /> tanks. As such, these tanks are not scheduled to be "tested" under SP001 <br /> protocols until 5 years after their installation, in accordance with the STI-SP001 <br /> Inspection requirements. The STI-SP001 inspection/test was not chosen for this <br /> particular inspection under this SPCC Plan. As such, the schedule for testing <br /> may not be in accordance with STI-SP001. <br /> Inspection methods as articulated in STI SP001 inspection and testing methods <br /> 60 <br />