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Would you be available for a conference call with Tanknology and myself? If so,what date and time would work best for you? I think Thornton is my only double-walled AST facility and I don't know much about the requirements. Thank you for your time, Joy From: Cesar Ruvalcaba [EH] [mailto:cruvalcabaClbsicehd.com] Sent: Monday, June 11, 2018 4:14 PM To: Joy Kachadorian Subject: RE: open APSA violations -8925 Thornton Rd. Hi Joy, Sorry I forgot to include the updated list of open violation. I have reviewed the return to compliance for 8925 Thornton Rd.There are still some open violations. I have included an updated list of the open violations and below you are the reasons why some of the violations could not be closed. Please address the open violations and return the completed Return To Compliance Certification Form with any statements, documents or photos. Violation 618—Failed to conduct inspections or integrity tests or maintain records for 3 years: Statement received "Weekly and monthly inspections are conducted according to those outlined in the SPCC.Tanks are double-walled and exempt ewe believe) from integrity testing described in STI SPOOL" Page 22 of the SPCC plan, section 5.11.5 states 'All ASTs, supports, and foundations will be visually inspected monthly for integrity.The inspector will look for signs of deterioration, discharges, and accumulation of oil inside the containment area. Records of the inspections will be kept for at least 3 years.Tanks are double walled and do not require integrity tests to be conducted in general conformance with the Standard for Inspection of Aboveground Storage Tanks SP001. The regulation states: Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs. You must determine, In accordance with industry standards, the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections, which take into account container size, configuration, and design such as containers that are: shop-built, field-erected, skidmounted, elevated, equipped with a liner, double-walled, or partially buried). Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing.You must keep comparison records and you must also inspect the container's supports and foundations. In addition, you must frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices satisfy the recordkeeping requirements of this paragraph. The plan fails to determine,in accordance with industry standards,the qualifications for personnel performing tests and inspections,the frequency and type of testing and inspections,which take into account container size,configuration and design. If the SP001 does not apply to these tanks,there will be another industry standard that should qualify.As a side note,reading through the SP001 guidelines,steel double walled tanks are only exempt from UTT readings but are subject to the general requirements of the SP001 formal external inspection guidelines and periodic inspections.You may want to contact the Steel Tank Institute or a licensed SP001 inspector to confirm double walled SP001 3