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You are right in stating that the Federal, state or local codes, regulations or ordinances do not require the Steel Tank Institute's (STI) SP -001 standard. The federal regulations do require an industry standard be used to make the determination of who, when and how the tanks will be inspected, based on the tanks size, configuration and design. It is stated in your reply that the alternative industry standard included was vetted, from reading the sections where the industry standard would be discussed, I fail to see that there is any industry standard that has been selected for the tanks. Again you are correct in pointing out that the engineer can make the determination in the SPCC for applicable industry standard, but again there is no evident industry standard referenced in the SPCC plan. Using the cross reference of where the discussion for the industry standard should be (40 CFR 112.8(c)(6)) it points me to section 5.2 titled Periodic Integrity Testing and Inspection, this states that "Integrity testing and inspection procedures are summarized in Appendix A." In Appendix A, the only reference to inspections was found under "Tank inspection Schedule' This schedule seems to reference different tank categories and types of inspections but does not reference an industry standard. Under the regulations the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections should be determined in accordance with industry standards. The US EPA's guidance on this and examples of industry standards have been attached, see attachment 1. Note that the guidance states that the SPCC plan should clearly identify the standard used to comply with the SPCC requirements. The full guidance document can be viewed here. Also, note that on page 7-13 of the SPCC Guidance for Regional Inspectors states that Testing on a'regular schedule' means testing per industry standards or at a frequency sufficient to prevent discharges. (67 FR 47119, July 17, 2002). The submitted Technical Memorandum does not seem be an industry standard but an explanation of how the monthly inspection checklist is equivalent or better than the monthly inspection checklist provided by the Steel Tank Institute's (STI) SP -001 standard. It appears that the writer of this memo intended for the PE to certify the substitution of the monthly SP -001 inspection checklist with the monthly inspection checklist provided in the SPCC plan "Generally, the substitution of the inspection form is done via an amendment to the SPCC Plan and this memo can be referenced as the reason for substituting'. There is no mention of this in the SPCC plan or the Technical Memorandum is not referenced in the SPCC plan. The Technical Memorandum does not address the annual inspections required by the SP -001 standard or formal inspections required by the SP -001 on certain tanks, I am only using this the SP -001 standard since the memorandum refers to it. I have also included the SP -001 monthly and annual checklists as an attachment. Page 7-43 of the SPCC Guidance for Regional Inspectors states that "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." The guidance document does allow for hybrid plans to be developed but if this is done, per page 7-47 of the guidance document "A PE does not need to provide and certify an environmental equivalence justification for implementing a hybrid inspection program when industry standards do not apply to a container or the container is outside the scope of the standard. However, the PE attests in the Plan certification that required inspections and testing have been established and that the Plan has been prepared in accordance with good engineering practice, including applicable industry standards. The PE should document in the Plan why current industry standards do not apply and how the hybrid inspection program meets the minimal recommended elements described in Section 753." Attachment 2. This is just an observation on the newly amended plan. A review of the plan was not conducted. This maybe an issue during next inspection since it is uncle art hat 40 CFR Part 112.8(c)(6) is followed. Amore thorough review may prove otherwise. Questions that may arise— The regulations calls for integrity testing on each aboveground container • Why are the tanks exempted from integrity testing in the SPCC plan? (according to Appendix A Tank Inspection Table) (integrity testing) The regulations call for a determination on the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections per industry standards. • Why is the 10,000 gallon tank requiring an external inspection every 20 years and not the other tanks? (frequency)