Comment from Daniel Fleck
Daniel FleckOpposeIndividual
Summary: The commenter argues that the proposed 20-year initial and 25-year reinspection intervals for breakout tanks are too frequent for tanks equipped with release prevention barriers and leak detection. They suggest extending these intervals to 30 years to align with API 653 standards and to reflect the reduced environmental risk associated with such containment systems.
"When establishing an internal inspection interval, PHMSA proposes a maximum timeline of 20 years for performing an initial inspection and a maximum reinspection interval of 25 years."
My comment is that the maximum interval should be extended to 30 years for tanks with a release prevention barrier and leak detection. An under tank containment and leak detection greatly reduces environmental risk and potential release quantity that ordinary dike secondary containment does not provide. Tanks with an RPB are very unlikely to have effects to groundwater or off property if there is a bottom leak. 30 years is established in API 653 6.4.2.1.2 for initial inspections and it would be appropriate to keep this duration for subsequent intervals for consistency.