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Commentary in the Preamble on §112.8(c)(6) also includes a reference to Industry <br />standards, <br />"Industry standards that may assist an owner or operator with integrity testing include: (1) API <br />Standard 653...(3) Steel Tank Institute Standard SP001-00..." <br />■ Environmental Equivalence - Information about this concept that is new in the 2002 <br />SPCC Rule is provided at § 112.7(a)(2), that states, <br />"Comply with all applicable requirements listed in this part. Your Plan may deviate from the <br />requirements in paragraphs (g), (h)(2) and (3), and (i) of this section and the requirements in <br />subparts B and C of this part, except the secondary containment requirements in paragraphs (c) <br />and (h)(1) of this section, and ... where applicable to a specific facility, if you provide equivalent <br />environmental protection by some other means of spill prevention, control, or countermeasure. <br />Where your Plan does not conform to the applicable requirements ... you must state the reasons for <br />nonconformance in your Plan and describe in detail alternate methods and how you will achieve <br />equivalent environmental protection." <br />Professional Engineer's Use of Environmental Equivalence <br />Assembling these key references for the SPCC Rule, a Professional Engineer may use good <br />engineering practices while considering the applicability of industry standards and adapting such <br />standards to specific facilities. The establishment of inspection schedules for tanks that do not <br />strictly fit into the provisions given in a particular industry standard can be problematic. To <br />establish schedules for these situations, a Professional Engineer may recommend an inspection <br />schedule be based on other inspection methods and schedules provided an equivalent <br />environmental protection is achieved. Most Professional Engineers realize that the use of <br />industry standards reduce their liability. <br />Further, in the preparation of the SPCC Plan, a Professional Engineer must be explicit in <br />concerning where deviations from the SPCC Rule are taken, the reasons why this is necessary, <br />and how equivalent environmental protection is provided (see § 112.7(a)(2)). <br />14 <br />