Comment submitted by Brad Rodgers, FMSM Engineers, Inc.

On Attachment 3.2 of Appendix G to Part 112 (Tier I Qualified Facility SPCC Plan); the table implies that "Container Size and Design Specification" for 1,101 to 5,000 gallon with sized secondary containment requires that the tank be elevated for visual inspection (and not trigger the requirement for non-destructive testing). According to Table 5.5 in STI SP-001 titled, "Table of Inspection Schedules", a Category 1 tank, described in Table 5.2 includes an "AST with secondary containment dike/berm" and ONLY requires Visual Inspection (This tank is not required to be elevated). The table in yor example SPCC plan still illustrates a conflict between "guidance" and what is actually required by the standard.