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1728 West Linne Road PR0540694 <br /> November 17, 2020 Program: APSA <br /> PHOTO 1: Fac <br /> ilit usin outdated settlement as a reason to not do inte rit testin . <br /> 15.4 Integrity Testing— 40 CFR 112.8 (c)(6) <br /> As outlined in the settlement agreement between the EPA, API, Petroleum Marketers <br /> Association of America and Marathon Oil Company in February 2004, shop built containers with <br /> shell capacity of 30,000 gallons or less that are elevated in a manner that decreases corrosion <br /> potential and makes all sides visible during visible inspections, do not need to undergo <br /> additional methods of integrity testing to meet the requirement of§ 1112.8(c)(6). <br /> The aboveground storage tanks at this facility are less than 30,000 gallons in capacity, and <br /> elevated above ground decreasing the potential for corrosion and allowing for the tank bottoms <br /> to be visible during inspection. Therefore monthly visual inspections will be conducted in lieu of <br /> the integrity testing requirements. <br /> All piping used for product transfer will be maintained in an aboveground state. Piping at the site <br /> operates a low pressure and is used intermittently for dispensing fuel. Integrity testing of piping <br /> will not be required as it can be visually inspected in its entirety. Table 3A summarizes <br /> inspections and tests performed on bulk storage containers ("EE") indicates that an <br /> environmentally equivalent measure is implemented in place of the inspection/'test discussed in <br /> Section 4 A of this Plan. <br /> Lydia Baker, Sr. REHS Page 1 of 1 <br />