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001, the Professional Engineer that stamped/certified this Plan has determined that ce atn <br />tanks and containers at the Facility are eligible for use of alternate, environmentally <br />equivalent, methods of assessing tank condition and suitability for continued service. <br />Due to the number of bulk storage containers at the Facility, the Professional Engineer <br />grouped them into categories with similar inspection and integrity testing requirements: <br />• Category A - Portable containers with all sides visible. For these containers, monthly <br />external visual inspections provide equivalent environmental protection. <br />• Category B - Single -walled aboveground storage tanks (ASTs) with all sides visible <br />or double -walled tanks with accessible monitoring ports. For these ASTs, monthly <br />external visual inspections provide equivalent environmental protection. <br />• Category C - Single -walled aboveground storage tanks (ASTs) without all sides <br />visible. These ASTs require monthly external visual inspections PLUS a formal <br />external inspection and a leak test every 10 years. <br />• Category D - Hazardous waste AST requires monthly inspections PLUS formal <br />external/internal inspection and leak test every 5 years per California Hazardous <br />Waste Regulations. <br />The following bulk oil containers are in Category A: 55 -gallon drums and totes and the 90 - <br />gallon Vicogen oil container which are portable. <br />The following bulk oil containers are in Category B: two 180 -gallon diesel fuel fire water <br />ASTs, one 24 --gallon diesel fuel fire water AST, and the two Biosol mixing tanks. <br />The following bulk oil containers are in Category C: 1,000 -gallon diesel fuel AST and three <br />emergency generator diesel fuel ASTs (140, 195 and 195 gallons each). <br />The following bulk oil containers are in Category D: the two (2) 1,000 -gallon salvage/used <br />oil ASTs. These tanks are double walled tanks which satisfy the secondary containment <br />requirements for 40 CFR 112.8(c)(2). <br />For each Category A and B container, the container's physical configuration, combined with <br />periodic inspections, ensures that a small leak that could develop in the tank shell will be <br />detected before it can become significant, escape secondary containment, and discharge <br />offsite. This approach provides environmental protection equivalent to the non-destructive <br />shell evaluation component of integrity testing required under 40 CFR 112.8(c)(6) since it <br />provides an appropriate and effective means of assessing the condition of the tank and its <br />suitability for continued use. <br />For Category C and D tanks, periodic inspections will be supplemented with a formal <br />external inspection by a certified inspector and a leak test every 10 years (every 5 years for <br />the hazardous waste salvage/used oil tanks). Leak testing may include pressure testing, <br />vacuum testing, ultrasonic thickness testing, hydrostatic testing, or some other method or <br />combination of methods, as determined by the certified inspector. <br />32 gust 20 i 6 <br />C , <br />