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If you require that we further discuss the environmental equivalence statement. From the attached EPA document, "The environmental equivalence provision, contained in 112.7(a)(2), allows for deviation from specific requirements of the SPCC rule, as long as the alternative measures provide equivalent environmental protection." Again SP001 is not a specific requirement in the SPCC rule, although setting up an inspection schedule is. We are continuing inspections, therefore we do not need a deviation statement to not use SP001. To further discuss, "equivalent protection" is defined in the attached EPA document as: "In SPCC context, equivalent environmental protection means an equal level of protection of navigable waters and adjoining shoreline from oil pollution." From your office's perspective how does the use of a different form not an equivalent protection to navigable water and adjoining shorelines or more to the point how would any spill from this facility impact these resources? I would kindly request that the County not adapt SP001 as the only form available for monthly and annual inspections as it is not perfect and can still lead to many flaws. SP001 formal external and internal inspections are very good and obviously developed by knowledgeable tank builders, but the monthly and annual checklist leave much to be desired. Creative and new ideas for problem solving should be allowed to be developed and exist to solve specific issues in new ways. Regards, Andy From: Baker, Lydia [mailto:lbaker@sjgov.org] Sent: Wednesday, May 22, 2019 8:57 AM To: Burgin, Andy C (Fresno) USA<andy.burgin@lehighhanson.com> Subject: RE: Full Inspection Reports Could you send me the "deviation statement in Section 1.2."? Thanks, Lydia From: Burgin, Andy C (Fresno) USA<andy.burgin@lehighhanson.com> Sent: Monday, May 20, 2019 3:45 PM To: Baker, Lydia <Ibaker@slgov.org> Cc: Marshall,Terry A (Fresno) USA<Terry.Marshall@lehighhanson.com> Subject: Re: Full Inspection Reports Hello Lydia, Thank you for the inspection photos and reports. We are working on a detailed response, including correction actions statements, as necessary. With that said we do have a few statements/questions. 1) Your statement in the "Overall Inspection Comments:" states "An inspection checklist was provided to the facility operator on the day of inspection. The EHD has written the complete report which replaces the initial checklist." Can you clarify this as no documentation was provided on the day of the inspection. I did digitally sign a document that I believed was the full inspection report. You said that you would email that copy on 5/20/18. I have still not received the signed copy. I would prefer the comments reflected the situation more clearly. 4