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"weekly" inspections rather than monthly lowers the caliber/quality of onsite fuel- <br /> management. Moreover, we provided blank forms to initiate this practice---final thought: the <br /> northern boundary of the property borders a navigable waterway as does the southern boundary. We <br /> were attempting to implement the strictest measure of compliance as a result <br /> The frequency of inspections/testing should be based on the selected industry standard.That is the <br /> requirement of the regulations and of the guidance documents.The second paragraph of Chapter 7 of <br /> the Regional Inspectors Guide of the US EPA states Activities may involve one or more of the following: <br /> an external visual inspection of containers, piping, valves, appurtenances, foundations, and supports; a <br /> non-destructive testing(examination) to evaluate integrity of certain containers; and additional <br /> evaluations, as needed,to assess the equipment's fitness for continued service.The type of inspection <br /> program and its scope will depend on site-specific conditions and the application of good engineering <br /> practices, adherence to applicable industry standards and/or manufacturer's requirements. An inspection, <br /> evaluation, and testing program that complies with SPCC requirements should specify the procedures, <br /> schedule/frequency,types of equipment covered,persons) conducting the activities,recordkeeping <br /> practices, and other elements as outlined in this chapter. <br /> This is also found in chapter 7 <br /> The SPCC rule is a performance-based regulation. Since each facility may present unique characteristics <br /> and methods may evolve as new technologies are developed, the rule does not prescribe a specific <br /> frequency or method to perform the required inspections,evaluations, and tests. Instead,it relies on the <br /> use of good engineering practice,based on the professional judgment of the PE(for a PE-certified SPCC <br /> Plan), which includes consideration of applicable industry standards. <br /> Among all the information is a list of industry standards that may be typical for tanks. It is up to the <br /> engineer to certify a standard for the facility based on the type of tanks. If the standard won't be <br /> adhered to, an environmental equivalence (EE) discussion will be needed.The requirements for the EE <br /> are in regulation. If the engineer feels that stricter testing/inspection schedule is needed that is <br /> acceptable, if this is the case I would recommend addressing the reasons in the SPCC plan.A stricter <br /> inspection schedule than that prescribed by the standards is usually a cause of concern with the tanks <br /> from an inspection point of view. For example STI SP-001 had 3 categories for the tanks.An inspection <br /> scheduled that deviates from the category 1 scheduled of 20 years and instead calls for a 5 year formal <br /> inspection may be because the tanks are category 3 tanks and would require additional testing or that <br /> the tanks may be in such a state that a stricter testing schedule is called for. If this is addressed in the <br /> plan,the facility and anybody else reading the plan will be able to answer questions as to why there is <br /> a need for more frequent inspections. <br /> FREE classes presented by NES Inc. are available to all San Joaquin County Hazardous Waste, Underground Storage Tank, <br /> and Aboveground Petroleum Storage Facility Business Owners and Operators. List and schedule of classes can be found <br /> here. <br /> Thankyou, <br /> Cesar Ruvalcaba <br /> 2 <br />