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Date: August 19, 2002 <br />����■ �■rwv OWN, <br />4109 Zeering Rd., Denair, CA 95316 <br />littp://www.convault.com, john@convault.com <br />800-222-7099,209-632-7571 <br />FAX 209-632-4711 <br />TO WHOM IT MAY CONCERN <br />Subject: Integrity Testing of Convault Tanks <br />RECEIVEL <br />AUG 2 4 2015 <br />ENVIRONMENTAL <br />'-'C70`Une0noT+e1:n1T <br />Convault shop fabricated aboveground storage tanks have 4 to 6 inch high legs, <br />which make them visible from the bottom and all sides. Furthermore, Convault tanks <br />have secondary containment with leak detection capability and are expected to be <br />checked and inspected on regular basis. The probability of any fuel discharge from <br />Convault tank due to primary tank failure is highly minimal as any discharge will be <br />detected in the leak detector tube and the fuel will be contained in the integral secondary <br />containment. <br />In view of the above, Convault does not recommend an integrity test on its tanks <br />when preparing, updating or revising the SPCC plans. Convault recommends an integrity <br />test on its tank only if there is a substantial reason to carry out such a test. Typical reasons <br />would include the detection of fuel in the secondary containment, the tank surviving a <br />catastrophic event such as a fire or a heavy vehicle impact, or the Authority Having <br />Jurisdiction (such as a fire marshal) specifically requiring an integrity test. If testing is <br />required, please refer to Convault owner manual testing protocol. <br />Should you have any questions, please contact the undersigned. <br />Very Truly Yours, <br />John Ekhtiar <br />Vice President, Engineering <br />SPCC Testing Requirements.doc <br />