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this subdivision shall conduct periodic inspections of the storage tank to ensure compliance with Part 112(commencing with Section 112.1)of Subchapter D of Chapter I of Title 40 of the Code of Federal Regulations. In implementing the spill prevention control and countermeasure plan,an owner or operator specified in this subdivision shall fully comply with the latest version of the regulations contained in Part 112(commencing with Section 112.1)of Subchapter D of Chapter I of Title 40 of the Code of Federal Regulations. If your site does not want to use that standard then the SPCC plan needs to be amended to reflect the current procedures, policies and practices at your facility. You stated that SP001 is not a standard but a test method. Per the EPA SPCC Guidance Document for Regional Inspectors, page 281 (https://secure- web.cisco.com/1x6HADW65vi32C8KiCnJpmf2uslBrVdWsArxtnG- Pk50GcE4mFHAnz1zVIBWHAr3WCgPiriF 43LOCHZKQW4hfRv1i8DvhBFgk3ZiXXJ OBLU09UzZAIQHCt gAbY- k4zw3gFFKYCPDbkWxxtHTiiLRWmEBogecNgpBRuUY5Zk4cFguxtHINMZSbGeMXYaMArX7eaOJphUMIDtlplhb9ibE9 9pxoJ uHwvNJIoTm6H6iiQVhCCx4BE09BePOinceZFEfkS1BoYOQfbGlokB6gXKnfvg4aPICr9Yy3i1TK- z98SYAAF7ZpiE6Mb9cMT8inz17xlr1EWoXz7ZSxVYcYQ/https%3A%2F%2Fwww.epa.gov%2Fsites%2Fproduction%2Ffiles %2F2014-04%2Fdocuments%2Fspcc guidance fulltext 2014.pdf): The necessary qualifications for personnel conducting the inspections are outlined in tank inspection standards such as API 653 and STI SP001. The same guidance document also states on page 300: If the facility owner or operator indicates in the SPCC Plan that he intends to use a standard to comply with a particular rule requirement(e.g., integrity testing),then it is mandatory to implement the relevant portions of the standard(i.e.,those that address integrity testing of the container). You are correct in saying that the SP001 inspection forms can be modified to fit the particular facility. The SP001 inspection checklists state: "This checklist is intended as a model. Locally developed checklists are acceptable as long as they are substantially equivalent(as applicable)." The current monthly form does not appear to be "substantially equivalent"to the SP001 inspection monthly checklist. Question 1 on the monthly checklist is "Is the containment free of excess liquid, debris, cracks, corrosion, erosion,fire hazards and other integrity issues?" This appears to be taken directly from the under SP001 checklist Containment (Diking/Impounding). This inspection question refers to tanks that are single wall and have a containment wall around them. The 10,000 gallon diesel tank at the site was a double wall tank. You also stated during the inspection that the interstitial space is inspected on the yearly inspection form. The SP001 standard monthly form requires that this be checked monthly. The applicable question is: For double-wall tanks or double bottom tanks or CE-ASTs,is interstice free of liquid?Remove the liquid if it is found.If tank product is found, investigate possible leak. In the email from Tuesday you asked the question, "For my clarity,your office's opinion that SP001 is an industry standard and therefore not to be deviated from, is that correct?" This is not correct. SP001 is an industry standard and if an owner or operator wants to deviate 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. You also asked, "Can you provide code or documented study to back up the industry standard or is it just the county's general opinion? Here is the code section that requires an industry standard: 112.8(c)(6)-Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs.You must determine,in accordance with industry standards,the appropriate qualifications for personnel performing tests and inspections,the frequency and type of testing and inspections,which take into account container size,configuration,and design(such as containers that are:shop-built, field-erected,skid-mounted,elevated,equipped with a liner,double-walled,or partially buried). Examples of these integrity tests include,but are not limited to:visual inspection,hydrostatic testing,radiographic testing,ultrasonic testing,acoustic emissions testing,or other systems of non- destructive testing.You must keep comparison records and you must also inspect the container's supports and foundations. In addition,you must frequently inspect the outside of the container for signs of deterioration,discharges,or accumulation of oil inside diked areas.Records of inspections and tests kept under usual and customary business practices satisfy the recordkeeping requirements of this paragraph. 3