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14700 W Schulte Rd, Tracy, CA Record ID PR0516327 <br /> 4-14-2016 PHOTO#9 <br /> IN round Storage Ta»ks - 112.8 (c)(4) & (5) <br /> There are no buried or partially buried storage tanks at tills facility. <br /> Ilrtegrity Testing - 112.8 (c)(6) <br /> Facility container inspections comply with the requirements in 40 CFR 112.8(c)(6) and <br /> California Health and Safety Code Sections 25270 to 25270.13. Each oil-filled container is <br /> inspected once a month using an inspection form similar to the one in Appendix D. The <br /> frequency and type of testing consider the container size and design. <br /> 40 CFR 112.8(c)(6) of the SPCC regulations require visual inspections of aboveground <br /> containers on a regular schedule in combination with other testing techniques such as <br /> hydrostatic testing, ultrasonic testing, or another system of non-destructive shell testing. 40 <br /> CFR 112.7(a)(2), as well as EPA guidance in the regulation preamble, Inspector Guidance <br /> Document, and interpretation letters, allow use of an environmentally equivalent method of <br /> meeting the integrity testing requirements. If an environmentally equivalent method is used, <br /> integrity testing is not required. <br /> Based on good engineering practice, and after considering the tank installation and <br /> alternative measures, as well as the requirements of Steel Tank Institute (STI) Standard SP- <br /> 001, the P.E. that stamped/certified this Plan has determined that certain tanks and container <br /> at the Facility are eligible for use of alternate, environmentally equivalent, methods of <br /> assessing tank condition and suitability for continued service. <br /> Due to the number of bulk storage containers at the Facility, the P.E. has grouped them into <br /> categories with similar inspection and integrity testing requirements: <br /> • Category A - Portable containers with all sides visible. For these containers, monthly <br /> external visual inspections provide equivalent environmental protection. <br /> Elena Manzo, REHS Page 9 of 21 <br />