Comment from International-Matex Tank Terminals LLC
International-Matex Tank Terminals LLCSupportBusiness
Summary: International-Matex Tank Terminals (IMTT), a pipeline and terminal operator, supports the adoption of a risk-based approach for determining inspection intervals for in-service breakout tanks. They also recommend narrowing the definition of "discovery of a condition" to the date a tool vendor delivers a final report to provide a well-defined starting point for remediation timelines.
See attached file(s)