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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Monday,July 1, 2019 3:09 PM To: 'Martin Jeppeson' Subject: RE: 2019 SPCC PIAN DRAFT- PR0528393 Hi Martin, I think you might be referring to Violation#710-Plan failed to adequately discuss procedures to test or inspect each container for integrity. I do not see in the plan where it states that a licensed structural engineer will be conducting the tank inspections.The department does not set the standards or tank inspection standards,this is reserved for the Professional Engineer that certifies the SPCC plan and for the industry standards which the plan usually references. Once a standard is certified for the tanks by the professional engineer,the standard should be followed,unless there is a detailed discussion on environmental equivalence certification by the professional engineer. Here is what the plan states on the inspection of the tanks: "...Inspections of the tanks include observations of the exterior of the tank for signs of deterioration or spills, observations of the tank foundation and supports for signs of instability, and observations of the vent,fill and discharge pipes for signs of poor connections that could cause a spill. In addition to these monthly inspections,the facility will periodically verify the integrity of each tank in accordance with an industry standard inspection procedure such as STI-SP001-03.The frequency of such testing will be as specified by the selected industry standard procedure." The plan seems to indicate that the STI SP-001 standard will be followed.There are two types of inspection under that particular standard,owner's inspection and formal inspections.The Owners inspections are conducted on a monthly and annual basis,and the person inspecting should be knowledgeable about storage facility operations,the type of AST and its associated components,the spill control system for the facility,and characteristics of the liquid stored. Owners inspectors must also be familiar with pumping,piping,and valve operations of the AST system." Refer section 4.1 of the STI SP-001 standard,6th edition. The standard also has checklists that should be followed for the monthly and annual inspections(attached). The formal inspections or Certified Inspector qualifications are as follows:A Certified Inspector shall be certified by one or more of the following(Additional certifications may be required by individual states or other governing bodies.): 4.2.2.1 American Petroleum Institute(API)Standard 653 Authorized Inspector Certification with STI SP001 Adjunct Certification. 4.2.2.2 Steel Tank Institute(STI) Certified SP001 AST Tank System Inspector. Refer section 4.2 of the STI SP-001 standard,6`h edition.The standard has specific requirements for the inspection reports and inspections. The STI SP-001 standard only allows for these two inspector qualifications.The standard itself is copy righted but you can get a brief recap of it here or you can order the latest version here Following are some guidelines from the SPCC Guidance for regional inspectors. Chapter 7 Inspections, Evaluations,and Testing can be found here and the complete guidance document can be found here • An inspection,evaluation,and testing program that complies with SPCC requirements should specify the procedures,schedule/frequency,types of equipment covered,person(s)conducting the activities, recordkeeping practices,and other elements as outlined in this chapter. • Once the Plan preparer selects an inspection schedule for aboveground containers(based on applicable industry standards),it must be documented in the SPCC Plan and the owner or operator must conduct inspections according to that schedule.The Plan should also include a description of the conditions of the container at the time the Plan was certified that led to the specific inspection schedule identified. Chapter 3,environmental equivalence,can be found here. 1