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testing and inspections when developing the inspection and/or testing program,the inspection program can deviate from a portion of a standard when another approach would be more appropriate or cost effective,based on site specific factors.The SPCC Plan must document the environmentally equivalent alternative,the reason for deviating from the rule requirement,and describe the alternative method in detail,including how it is environmentally equivalent.143 The PE should document in the Plan what industry standard applies,how the hybrid inspection program deviates from the applicable industry standard,and how the inspection program meets the minimal recommended elements described in Section 7.5.3. Violation#726-Plan failed to adenuately describe overfill prevention methods for each container. Response submitted stated The mobile refueler is not defined as a bulk storage container. When not in use(parked)it will be located or positioned to prevent discharges as described in 112.7(b)The containment method for the mobile refueler has been identified on SPCC plan. Northwest Pipe Company hereby commits to park the mobile refueler under the awning—25U west of SW Corner of employee parking lot.Overfill protection in accordance with 40 CFR 112.8(c)(8)(iv)to avoid discharges are in use at this facility.The SPCC plan was amended to include discussion of overfill protection procedures followed during transfer operations involving all APSA regulated tanks. Observations/comments: See comments for Violation#711 on why the mobile refueler is a bulk storage container and needs to comply with regulations of bulk storage containers, 40 CFR 112.8 with the exemption of sized secondary containment. Following are the regulations from which the decision not to close the violations was made 40 CFR 4112.81c)(8) (8) Engineer or update each container installation in accordance with good engineering practice to avoid discharges.You must provide at least one of the following devices: (i) High liquid level alarms with an audible or visual signal at a constantly attended operation or surveillance station. In smaller facilities an audible air vent may suffice. (ii) High liquid level pump cutoff devices set to stop flow at a predetermined container content level. (iii) Direct audible or code signal communication between the container gauger and the pumping station. (iv)A fast response system for determining the liquid level of each bulk storage container such as digital computers,telepulse,or direct vision gauges. If you use this alternative, a person must be present to monitor gauges and the overall filling of bulk storage containers. (v)You must regularly test liquid level sensing devices to ensure proper operation. Feel free to contact me with any questions. FREE classes presented by NES Inc. are available to all San Joaquin County Hazardous Waste, Underground Storage Tank, and Aboveground Petroleum Storage Facility Business Owners and Operators. List and schedule of classes can be found here. Thankyou, 4