Comment from Jonathan Primero

There are many economic benefits to the purposed Pipeline Safety: Breakout Tank Inspection Rule. One would be by extending the inspection timelines it will save roughly hundreds of millions of dollars by cutting down on frequent and expensive tank cleanouts. The second would be modernizing the standards of the American Petroleum Institute replacing the outdated mandates with modern engineering. But the benefits don't seem to outweigh the overall cost and risk. If we extend the window up to two decades before an initial internal inspection than there is a high possibility of internal corrosion, pitting, or floor degradation that could potentially go longer without any direct visual and physical confirmation. When it comes to environmental health and safety, public health officials advocate the point that loosening timelines for hazardous liquid and petroleum storage infrastructure can increases the long-term cumulative risk of undetected leaks or structural weakening near sensitive areas. This could lead to major environmental impacts that could cost more than what is being saved in the long run. It only takes one bad pipe to cause a catastrophe similar to the oil spill in the gulf in 2010. What you try to save now may end up costing more in the end. That is why I am opposed to the Pipeline Safety: Breakout Tank Inspection Rule. Very Respectfully, Primero, Jonathan