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to each including the caveat that the most-recent version of APSA has NOT been adopted to-date <br /> although it has been used as a key reference in this Plan. <br /> Line item#706 narrative/response: All parties recognize this long-standing oversight and <br /> corrective action to remove and replace the non-compliant 1000-gallon gasoline AST is <br /> underway. The owner/operator will follow-up with specific details on completion dates for this <br /> matter. <br /> Line item#710 narrative/response: The PE wet-stamp/certification will include specific <br /> references to alternative methods for conducting equivalent protocols for: <br /> a) Inspections which are conducted by the owner/operator on a frequency as stipulated by <br /> the AHJ. SPC Corp recommends weekly inspections; federal/state/local guidelines <br /> normally require monthly inspections by a qualified employee of the FRO <br /> owner/operator. <br /> b) Periodic Integrity Tests conducted by SPC Corp were done in accordance with <br /> 40CFR112 (US EPA) as well as Chapter 7-Regional Inspectors Guide under the"hybrid' <br /> section of the reference. SPC Corp has encountered numerous events in onsite testing <br /> where STI SP001 created"destructive"testing by imposing air-pressure and/or <br /> vacuum/negative pressure on both primary and secondary containment in both damage to <br /> weld seams due to metal fatigue as well as failure to adequately make the test-subject <br /> "leak-tight"during the test-----this issue created "false-negative"results which have been <br /> demonstrated to AHIs that the alternative test methods referenced in the Final DRAFT of <br /> the SPCC plan are equivalent and, in fact, more accurate than STI SP001. We/SPC Corp <br /> do NOT market this conclusion and would prefer to keep any marketplace dissent <br /> between STI and SPC Corp a separate matter. The PE has wet-stamped/cerfifred the <br /> periodic integrity testing procedures are equivalent and meet federal/state/local <br /> requirements. <br /> Line item#726 narrative/response: The Final DRAFT slice plan now addresses this deficiency <br /> and installation of the said O/F devices (UL-listed boxes) on each respective container are m- <br /> process. The owner/operator will stipulate a completion date beyond the Final DRAFT spec plan <br /> certification. <br /> Line item#4010 narrative/response: The Final DRAFT spec plan includes the Substantial Harm <br /> Criteria. Owner/operator will complete Appendix C and maintain said Appendix onsite. <br /> Upon confirmation that the AW has reviewed the Final DRAFT slice plan (which is submitted <br /> with this addendum) and frtal-pagination of each cross-referenced issue has been adequately <br /> included,the PE will wet-stamp/certify the SPCC plan. The owner/operator will then complete <br /> the Return to Compliance Certification form and submit to EHD as well as maintain a copy <br /> onsite. <br />