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with fewer inspections. While short-term costs may be higher, the long-term total cost of <br />ownership can be much lower due to fewer incidents, environmental cleanup, regulatory citations, <br />new regulations and many other factors. Further, when comparing inspection requirements of <br />underground tanks to aboveground tanks, most tank owner/operators realize that the visual <br />inspection of elevated ASTs is considerably simpler than inspecting an underground tank. <br />The owner of tanks should clearly consider upgrading of tank installations. This should be <br />accomplished by incorporating CRDM and secondary containment to ASTs or moving <br />underground tanks aboveground at the first available opportunity. This will become quite evident <br />when the next scheduled Formal External or Informal Inspection reveals that missing safeguards <br />require an increased inspection frequency or are needed to comply with regulations. <br />Numerous tank types are found in the United States. Although Table 5.5 in SP001 includes many <br />tank types and types of installations, including all types is impossible. For example, inspection <br />methods for plastic tanks are not included in SP001. Therefore, a Professional Engineer <br />assessing tank inspection programs must use professional judgment to adapt this standard to <br />specific industries or facilities. Per paragraph 1.3 of SP001, <br />"The Professional Engineer must use other standards, recommended practices and other equivalent <br />engineering and best practices that exist and provide alternative inspection requirements for tanks defined <br />within the scope of this standard and for tanks outside the scope of this standard." <br />The SP001 Standard is intended for use in many contexts, only one of which is part of an <br />EPA -SPCC Plan. To understand how the SP001 Standard is to be used in the context of an SPCC <br />Plan, a review of the USEPA SPCC Rule is needed. <br />11 <br />