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are located.The facility diagram must identify the location of and mark as "exempt"underground tanks that are otherwise exempted from the requirements of this part under§112.1(d)(4).The facility diagram must also include all transfer stations and connecting pipes, including intra-facility gathering lines that are otherwise exempted from the requirements of this part under§112.1(d)(11)... (EPA Guidance Attached) Violation#602-Plan failed to discuss equivalent environmental Protection,if applicable. Response submitted stated that"The SPCC Plan was amended to include a discussion of the documented monthly inspections of the 300 and 500-gallon tanks as equivalent environmental protection.The SPCC now describes how Northwest Pipe Company personnel will perform monthly inspections,documenting the condition of the exterior of the each container for signs of deterioration,discharges,or accumulation of oil inside secondary containment"The SPCC plan states the following on section 6.2.8 Overfill Prevention Systems"The 300-gallon gasoline AST,the 500-gallon oil ASTs are not equipped with overfill prevention systems BUT are under rain cover(awning)and within the concrete containment described above.The emergency generator diesel fuel(belly)tank is also not equipped with an overfill prevention system. Facility personnel are present throughout the filling operations to monitor the product level in these tanks as transfer is occurring..." Observations/comments: It is stated in the return to compliance corrective actions that an environmental equivalence discussion of the documented monthly inspections of the 300 and 500 gallon tanks. The section dealing with environmental equivalence,according to the cross reference(112.7(a)(2)is discussed in section 5.1(page 11)of the SPCC plan states that "unless stated otherwise,this SPCC plan conforms to the general requirements for spill prevention,control,and countermeasure plans required by 40 CFR§112.7." I could not find any other section that dealt with environmental equivalence. If making an environmental equivalence claim,the industry standard that applies to the tanks should be identified and you must state the reasons for nonconformance in your Plan and describe in detail alternate methods and how you will achieve equivalent environmental protection. See violation 711 for guidance on this issue. Furthermore an environmental equivalence cannot make use of existing requirements under SPCC regulations, such as the"frequent inspection of the inspect the outside of the container for signs of deterioration,discharges,or accumulation of oil inside diked areas'which is a requirement under 40 CFR 112.8(c)(6) (see attached guidance) As a note The overfill prevention is to avoid discharges during the filling activities.The SPCC plan does not explain how an awning would prevent a tank from avoiding discharges during the filling activities.The SPCC plan states there is no overfill prevention system in place but it seems like the facility personnel being present to monitor the product level in the tanks is being presented as an overfill prevention system. Per SPCC guidance(page 3-11)A procedure for smaller containers that ensures communication between the container gauger and the pumper,is in accordance with §§112.8(c)(8)(iii)and 112.12(c)(8)(iii)and therefore does not require an environmental equivalence determination. Guidance attached) Violation#711 -Failed to Perform scheduled tank tests or inspections by appropriately Qualified Personnel. Response submitted stated Integrity testing was conducted by a certified SP-001 inspector on March 8, 2019.A copy of the test results was forwarded to the EHD on May 7th,2019.Testing/inspections for all qualified tanks per industrial standards are addressed in the SPCC Plan. Observations/comments:The SPCC plan and other sections of the SPCC plan state that the mobile refueler is not defined as a bulk storage container.This goes against SPCC regulations and EPA guidance/interpretation. Under SPCC regulations the mobile refueler is a bulk storage container under certain conditions and is only exempt from the requirement of having sized secondary containment. Per a description of how the mobile refueler is used,it meets the definition of a mobile refueler under SPCC regulations and would be considered a bulk storage container. Furthermore the 10,000 gallon tank is the only tank that has an industry standard referenced and it does not follow the STI SP-001 standard,the standard requires an annual inspection by facility personnel,in addition to monthly inspections.The STI SP-001 checklists have been attached. More information on the standard can be obtained herethis is not based of the most recent edition of the standard and is only a brief overview. The other bulk storage tanks need an industry standard 2