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C") <br /> 0 <br /> ct3 <br /> 0 <br /> 0 <br /> MCDONALD ISLAND UNDERGROUND NATURAL GAS <br /> STORAGE FACILITY <br /> ADDENDUM AND EXPLANATION TO THE EXISTING SPCC PLAN <br /> Part 11 Section 4 INSPECTIONS, TESTS, AND RECORDS (page II-3) discusses the <br /> integrity testing of aboveground containers <br /> O The SPCC Plan states <br /> 4— <br /> V n <br /> U Both periodic integrity testing of applicable permanentlstationary bulk storage <br /> O F containers and periodic integrity and leak testing of associated valves and piping will w <br /> U) be conducted Testing will be performed by qualified personnel Integrity testing, <br /> 70 procedures and schedules have been developed In accordance with accepted <br /> M industry standards Documentation, of inspections and testing, is maintained at the <br /> O facility (Containers excluded from integrity testing Include but are not limited to oil- <br /> (Y filled electrical equipment and operating equipment ) <br /> S= <br /> M The pre- 2002 regulations state <br /> E <br /> (D In §112 7(e)(2)(vl) that tanks are "subject to periodic Integrity testing, using such <br /> U <br /> techniques as hydrostatic testing, visual inspection, or a system of non-destructive shell <br /> :3 thickness testing' <br /> N <br /> z The present SPCC Plan addresses this requirement by means of periodic visual <br /> inspections which meets the requirement of the pre-2002 regulations. These visual <br /> N Inspections are done at least once a month and are documented on Facility Inspection <br /> N Forms which are maintained at the facility Therefore, the testing interval is no more than <br /> monthly which meets the current regulatory requirements <br /> LJ <br /> 06 The revised rule that became effective in January 2010 requires that"the owner or <br /> operator must combine visual inspection with another testing technique such as <br /> hydrostatic testing. radiographic testing, ultrasonic testing, acoustic emissions testing, or <br /> other system of non-destructive shell testing" <br /> Procedures for integrity testing for required tanks, in addition to visual inspections, is <br /> (presently being developed and will be in place when the new regulatory compliance <br /> (requirements are set to take effect. These procedures will include identification of tanks <br /> requiring additional testing, type of testing to be performed and frequency of the testing. <br />