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(2) Alternative Requirements to General Secondary Containment. R secondary containment is not provided for qualified oil-filled operational equipment pursuant to paragraph (c)of this section,the owner or operator of a facility with qualified oil-filled operational equipment must: (i) Establish and document the facility procedures for inspections or a monitoring program to detect equipment failure and/or a discharge; and (ii) Unless you have submitted a response plan under§112.20, provide in your Plan the following: (If a response plan under 40 CFR §112.20 has been submitted to the EPA, provide written statement that this has been done) (A)An oil spill contingency plan following the provisions of part 109 of this chapter. (Guidance attached, checklist is not an oil-spilled contingency plan, a link to part 109 can be found here ) (B)A written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful. 40 CFR§112.7(a)(3) (3) Describe in your Plan the physical layout of the facility and include a facility diagram,which must mark the location and contents of each fixed oil storage container and the storage area where mobile or portable containers 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)(1 I)... (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 2