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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Wednesday,June 26,2019 3:24 PM To: 'ryan.johnson@ncpa.com' Cc: 'BROOKLYN.SAYLOR@NCPA COM ' Subject: San Joaquin County EHD-APSA/SPCC Deviation from Industry Standard Hi Ryan, I apologize, I may have met you at the NCPA site,when we spoke on the phone I was thinking of the larger facility outside of Lodi,completely forgot about the one inside Lodi. To give you guidance on the deviation from an industry standard,the Professional Engineer does have the authority to make an environmental equivalence claim.This is allowed by CFR 112.7(a)(2),there should be a detailed discussion of this in the SPCC plan under this particular section. In part CFR 112.7(a)(2)states that"you must state the reasons for nonconformance in your Plan and describe in detail alternate methods and how you will achieve equivalent environmental protection. If the Regional Administrator determines that the measures described in your Plan do not provide equivalent environmental protection,he may require that you amend your Plan,following the procedures in § 112.4(d)and (e)."The Regional Administrator refers the US EPA. I am including the link to chapter three of the SPCC Guidance for Regional Inspectors.The full guidance can be found here. Chapter 3,the environmental equivalence chapter gives guidance on how to go about making the environmental equivalence. When deviating from an industry standard,such as API 653,chapter 7 page 7-43 states that"If an owner or operator deviates from applicable industry standards to develop an integrity testing program,then a PE must certify an environmentally equivalent alternative in the SPCC Plan.The Plan must provide the reason for the deviation,describe the alternative approach,and explain how it achieves environmental protection equivalent to the applicable industry standard."Again,this should be a detailed explanation. In this case the internal inspection,as stated on section 6.4 of the API 653 standard,is primarily required to do as follows: a) Ensure that the bottom is not severely corroded and leaking. b) Gather the data necessary for the minimum bottom and shell thickness assessments detailed in Section 4. As applicable, these data shall also take into account external ultrasonic thickness measurements made during in service inspections(see 6.3.3). c) Identify and evaluate any lank bottom settlement. Note that section 6.4.1.2 of the standard states the following 6.4.1.2 All tanks shall have a formal internal inspection conducted at the intervals defined by 6.4.2. The authorized inspector shall supervise or conduct a visual examination and assure the quality and completeness of the nondestructive examination (NDE)results. If the internal inspection is required solely for the purpose of determining the condition and integrity of the tank bottom,the internal inspection may be accomplished with the lank in-service utilizing various ultrasonic robotic thickness measurement and other on-stream inspection methods capable of assessing the thickness of the lank bottom, in combination with methods capable of assessing lank bottom integrity as described in 4.4.1. Electromagnetic methods may be used to supplement the on-stream ultrasonic inspection. If an in-service inspection is selected, the data and information collected shall be sufficient to evaluate the thickness, corrosion rale, and integrity of the tank bottom and establish the internal inspection interval, based on tank bottom thickness, corrosion rate, and integrity, utilizing the methods included in this standard. Chapter 3 of the SPCC guidance also states the following: A PE must review the selection and implementation of environmentally equivalent measures and certify them as being consistent with good engineering practice(§112.3(d)or§112.6(b)(4)).The selection of alternative measures may be 1