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If an owner or operator deviates from applicable industry standards to develop an integrity testing program,then a PE must certify an environmentally equivalent alternative in the SPCC Plan.The Plan must provide the reason for the deviation, describe the alternative approach,and explain how it achieves environmental protection equivalent to the applicable industry standard. Page 7-45 of the"SPCC Guidance for Regional Inspectors," In any case where the owner or operator of a facility uses an alternative means of meeting the integrity testing requirement of§112.8(c)(6)or§112.12(c)(6),the SPCC Plan must provide the reason for the deviation, describe the alternative approach,which is most likely to be a site-specific inspection program (i.e., hybrid inspection program), and explain how it achieves equivalent environmental protection(§112.7(a)(2)),while considering good engineering practice and industry standards. In cases where industry standards apply to a container,the PE would need to explain how an inspection or test that deviates from an applicable industry standard is environmentally equivalent to following established industry standards and how it will be implemented in the field.This determination is site-specific and based on good engineering practice as determined by the certifying PE.The hybrid inspection program should include the recommended minimal elements described in Section 7.5.3 for a PE-developed site-specific integrity testing program. Figure 7-4 provides a summary of integrity testing and inspection program documentation for bulk storage containers at onshore facilities,by type of SPCC Plan and standard applicability case. Page 7-45 of the"SPCC Guidance for Regional Inspectors," It maybe appropriate to deviate from portions of an industry standard under certain circumstances.Although the Plan preparer must determine,in accordance with industry standards,the appropriate qualifications for personnel performing tests and inspections,and the frequency and type of 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 adequately 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§312.81c1(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. 4