Comment submitted by UST Inspector

Recommendation: Add the words “annual” and “semiannual” to the definitions section in 280.12. Significance: Currently, one could argue that annual is once per calendar year instead of once every 12 months. If this is not addressed, a regulated facility could conduct an annual test of their leak detection system in January of 2012 and again in December 2013 (essentially a 23 month gap), while still claiming compliance. Suggested edits to 280.12: Annual means at least once every 12 months. Semiannual means at least once every 24 months.