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Suggested Corrective Action: Follow the SP001 standard or another industry standard or provide equivalence. Ensure that this is discussed in the SPCC plan. An alternative would be a hybrid plan which is discussed in the EPA guidance pages 7-46. For#715: CFR 112.8(c)(8)(v) states: (v)You must regularly test liquid level sensing devices to ensure proper operation. While it is true that during the inspection the clock gauge appeared to not be damaged, a visual inspection of the clock gauge is not adequate to determine proper operation. The regulation requires liquid level sensing devices to be tested per good engineering practices. The SP001 standard does have the question in the monthly checklist that addresses this regulation but that is not included in your facility's current inspection form: Is overfill prevention equipment in good working condition?If it is equipped with a mechanical test mechanism,actuate the mechanism to confirm operation. Suggested Corrective Action: Incorporate the above question into your current monthly inspection form (or make your form clear as to what is exactly being inspected/tested) or discuss how liquid level sensing devices will be tested to ensure proper operation in the SPCC plan. If you have any questions please let me know. Best Regards, Lydia Baker Registered Environmental Health Specialist San Joaquin County Environmental Health Department 209-468-8257 Ibaker@sigov.org Please note my email address has changed to Ibaker@sjgov.org From: Burgin, Andy C (Fresno) USA<andy.burgin@lehighhanson.com> Sent: Wednesday, May 22, 2019 10:13 AM To: Baker, Lydia <Ibaker@sjgov.org> Subject: RE: Full Inspection Reports Good Morning Lydia, I think we might be off path here on deviation. Not using SP001 are not a deviation from 40 CFR 118.2 requirements, my position is that any PE developed inspection schedule fits those regulations. For my clarity, your office's opinion that SP001 is an industry standard and therefore not to be deviated from, is that correct? Can you provide code or documented study to back up the industry standard or is it just the county's general opinion? If SP001 is the only inspection form,then why has no local, state, or federal agency passed code to require it's use? I've prepared plans for over 12 years, the industry standard for engineers is a lot more flexible than you might think on this issue.As it is a national program your office would have to prove the industry standard is set nationwide. Engineers use portions of test methods all the time, as the full test method does not fit site specific needs. 3