Comment submitted by Robert McCrary, Clemson University

Clemson is one of the institutions that had a considerable number of residence heating oil tanks (UST's) that were a part of our SPCC plan. These tanks had been in the ground for a variety of time periods, and when we implemented our leak testing program, we found that a number of them had active leaks. As a result, Clemson has had to remove and remediate a number of sites based on these results. While I realize that these tanks constitute a relatively minor threat in many cases, we discovered that because so little attention had been paid them (in comparison to other tanks), there were a greater number of problems associated with these tanks than any others that we tested. I would ask that SOME process for the testing of these tanks be retained so that these problems are not overlooked.