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VIOLATION k3 602 CFR 112 7(a)(2)Plan failed to discuss equivalent environmental protection, if applicable. The Spill Prevention,Control,and Countermeasure(SPCC)failed to discuss alternative environmental protection requirements. The SPCC plan makes a claim that the plan along with its implementation by the facility provides conformance with the requirements under 40 CFR 112. It stales that the plan does not deviate from the requirements of under CFR I I2.7(g), (h)(2),(h)(3)and(i)and 40 CFR 112.8.The plan was found to deviate from section 112.8(c)(6).The SPCC plan does not call for formal inspections to be conducted on the facility tanks and does not cite an industry standard that would allow this. If the SPCC Plan does not conform to the applicable requirements,the reasons for nonconformance must be stated and the alternate methods to achieve equivalent environmental protection must be described in detail in the Plan. Immediately amend the SPCC Plan to include a discussion of equivalent environmental protection. NotePer US EPA guidance,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 allemative approach,and explain how it achieves environmental protection equivalent to the applicable industry standard. This is a Class II violation. Response: Consulting engineers at ATC are working with our staff to address the noted issues. The SPCC Plan will be amended. VIOLATION#4 710 CFR 112 8(c)(6)Plan failed to adequately discuss procedures to test or Inspect each container for integrity_ The SPCC plan did not take into account the s e_configuration,or design of the tank.The SPCC plan does not reference an industry standard for inspections. Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever repairs are made. The qualifications of personnel performing tests and inspections,frequency and type of testing and inspections that take into account container sve,configuration, and design shall be deteominel in accordance with industry standards_ F amples of these integrity tests indutle, but are not limited to visual inspection,hydrostatic testing,radiographic testing,ultrasonic testing,acoustic emissions testing,or other systems of nondestructive testing. Comparison records and other records of inspections and tests must be maintained on site. Immediately conduct the necessary testing and submit a copy of the test results to the EHD,or provide equivalence as allowed by CFR 112 7(a)(2). This is a Class II violation. Response:The SPCC Plan will be amended to address the noted issues, inspections will be conducted and documented as required and consistent with the identified standards.