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Baker, Lydia [EHD] From: Baker, Lydia Sent: Monday, April 27, 2020 11:43 AM To: Ty Rust Cc: Chad Reed Subject: RE: Return to Compliance Attachments: ownersCA.pdf Hi Ty, I submitted Gary's report to STI for review and here are the comments: "I have looked these over report and I can see that the format is pretty good,the inspector does do a good job if identifying in the report what sections of the SP001 standard each item address. That makes review easier. You can match the comment to the section it is intended to address and make sure they all get addressed. And the report does address many necessary elements and the provided information is favorable." "First how old are the tanks? The tank age is not listed, and while it can be hard to sometimes establish the age of a tank the inspector should make a good faith estimate to help set an age for the unit. If the estimate is approximate then it should be noted as such. But in most cases an approximate age for the tank can be established with the help of the tank owner. The age of the tank should be established at some point in the inspection process The next question I have is: is the tank construction properly identified. I note that the tanks construction are listed as a "double wall" and the supporting documentation suggest they are not. Double wall tanks have a very specific definition in the SP001 standard and in tank construction standards. The tanks identified in this inspection report are single wall tanks set in a weather proof secondary containment vault. In this case the design is a specific design known as a Concrete Exterior ASTs or CE-ASTs. The last thing that is not clear with the report is have the unique attributes of this tank been addressed. The CE-AST is a unique design that can vary between manufacturers. The SP001 standard has inspection procedures specific to CE-ASTs listed in section 7.8 of the standard. As such each manufacturer generally provides specific information as to what should be inspected on the tank in addition to the items listed in SP001. The performance of the manufacturer specific inspections for a CE-AST is required in SP001 section 7.8.1. Because these CE-ASTs are unique to each manufacturer the SP001 standard cannot cover them all. I cannot establish in the inspection reports where the requirements of section 7.8 are addressed You may wish to ask the inspector if the requirements of STI SP001 section 7.8 were included in the report, and were they are addressed in the report. The inspector did identify the CE-ASTs as Convault units, and Convault does include in their product manual, which they make available at their website, inspection supplements that are to be used in conjunction with SP001. I have attached a copy of one of the manuals as an example, and while I think this may be the appropriate document, there can be more than one option, and it is really the responsibility of the inspector to identify what manufacturer specific inspection procedures need to be added to the inspection process when inspecting a CE-AST. The supplement I attached will give you an idea of what the manufacturer has determined should be inspected. The information may be in this report but I cannot establish it" Best Regards, Lydia Baker Registered Environmental Health Specialist i