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Spill Prevention,Control,and Countermeasures Plan JC Air Academy Page 8 55 gallons(i.e. spill pallet).If exposed to precipitation,an additional 2.86 inches of freeboard must be provided. 1.5 PRACTICABILITY OF SECONDARY CONTAINMENT(40 CFR 112.7(d)) Management has assessed that secondary containment is practicable at this Facility. 1.6 INSPECTION RECORDS [40 CFR 112.7(e)] The Facility has adopted the Steel Tank Institute(STI)standard'to establish steel AST integrity inspection intervals. As such, a tank's category is assessed by the type, configuration, and protection equipment installed. Generally, tanks with spill control (i.e. secondary containment, overfill prevention) and continuous release detection methods (CRDM) such as an elevated tank are Category I tanks (least risk). Those with spill control and without CRDM are considered Category II tanks. Tanks without spill control or CRDM are considered Category III tanks (most risk). A reference of the inspection type required for Facility containers is provided in Table 3, Visual and Non-Destructive Container Shell Inspection Requirements. A Facility AST Inventory is included in Appendix 6. Inspection type and frequency is initially assessed by an AST's category and total capacity. The inspection schedule for Facility containers is provided in Table 4, Visual and Non-Destructive Container Shell Inspections. T-1 requires formal external non-destructive integrity testing by a certified inspector every 20 years.Facility personnel indicated that T-1 was installed in 2020; therefore, not due for external inspection until 2040. prior non-destructive shell inspections by a certified inspector had not been conducted or scheduled at the time of the SPCC Plan update. Records of visual inspections of oil storage containers are to be completed monthly (STI SP001 Monthly Inspection Checklist, STI SP001 Portable Container Monthly Inspection Checklist4) and annually (STI SP001 Annual Inspection Checklist). Records of visual inspections are to be maintained at the Facility for a minimum period of 3 years.Forms are provided in Appendix 7 to record visual observations. Records of inspection should be dated and include the name of the in-house inspector.Visual inspections are to include: • Written documentation and, when appropriate, photo documentation of the external condition of oil containers that meet or exceed a capacity of 55 gallons. Visual inspections are to be used to document observed oil container deterioration associated with metal and rubber components, tank supports and foundation, and on the exterior tank surface for signs of deterioration, leaks or accumulation of oil inside secondary containment structures. The written documentation will also include the action(s) taken to mitigate the deteriorated oil container, i.e., removal of the oil container from service,repair of the oil container, etc. • When present, the visual inspection will also focus on oil container valves, pipes, and appurtenances, the general condition of such items as flange joints, expansion joints, valve bodies and glands,catch pans,and pipeline supports. The visual inspection is to also include checks of the proper locking of oil container valves.If corrosion is found,the in-house inspectors are to undertake additional examination and corrective action, as indicated by the magnitude of the damage. • In-house inspectors are to also inspect water in secondary containment before being discharged. Facility personnel are to promptly correct visible discharges which result in a loss of oil from a 3 Steel Tank Institute, Standard for the Inspection of Aboveground Storage Tanks, SP001, - 6th Edition Inspection Standard, January 2018. a Inspections are to be completed for portable containers onsite for 91 days or more. �it� CONDOR