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z ty ds 3.2.2 Tank and Pipe Procedures 3.2.2.1,Inspections of ASTs The SPCC regulations require visual inspections of ASTs combined with other testing techniques. On May 25, 2004, US EPA submitted a letter to the Petroleum Marketers Association of America (PMAA)that provided facilities with some flexibility for meeting the AST testing requirements by using environmentally equivalent options. The environmental equivalence method below was approved by the US EPA in the following guidance document: SPCC Guidance for Regional Inspectors,Version 1.0, November 28, 2005, Office of Emergency Management, EPA 550-B-05-001. For certain shop-built containers with a shell capacity of 30,000 gallons or under, USEPA considers that visual inspection provides equivalent environmental protection when accompanied by certain additional actions to ensure that the containers are not in contact with the soil. These actions include elevating the container in a manner that decreases corrosion potential and makes all sides of the container, including the bottom,visible during inspection. Determination of environmental equivalence is subject to good engineering practice, including consideration of industry standards, as certified by the Professional Engineer The Facility's ASTs are each designed to not have contact with bare soil and are raised to prevent continuous contact with standing water. In addition,the 20,000-gallon AST is raised or elevated in a manner that allows the facility to perform visual inspections. As a result of this design and the routine inspections, small leaks can be detected before they can cause an offsite discharge of oil. In addition, the Facility monitors the annular space of the ASTS on a periodic basis. The annular space for the 20,000- gallon AST is continuously monitored with an electronic leak detection system. FedEx has agreed to maintain a periodic visual inspection program of the annular spaces for the other three ASTs that do not have electronic leak detection systems. Based on the design of the ASTs and the monitoring methods,the Professional Engineer that stamped/certified this Plan determined that the FedEx Freight facility is eligible to use the environmental equivalence method described above to inspect its ASTs. Therefore, the Facility is not required to perform non-destructive integrity tests of the ASTs every 10 years to meet the SPCC Plan regulation requirements. It should be noted, however,that the used oil tank must have a third-party professional engineer certification and associated tank test every five years since used oil is a hazardous waste in California. Facility personnel frequently observe tanks during operating hours. Formal inspections are conducted by the Facility following the schedule in Table 4. These include observations of the outside of each tankfor signs of deterioration, leaks which might cause a spill, or accumulation of oil inside the annular spaces and containments and diked areas and around the down-grade storm drain catch basins. The personnel also observe the tanks supports and foundations. The inspections and tests are conducted in accordance with written procedures developed by the Facility or by the Professional Engineer that certified the Plan. 11 SANational Pro grams\Projects\Federa]Express12009t33109-009237 West Region SPCCs\Stockton\Stockton CA FedEx Freight SPCC Plan.doc