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You also asked, "If SP001 is the only inspection form,then why has no local, state, or federal agency passed code to <br /> require it's use?" SP001 is not the only inspection form, but it was included in your SPCC plan that is why it was <br /> specifically mentioned in the report. You are also correct in stating that "Environmental Equivalence" can be used to <br /> deviate from the industry standard, but CFR 112.7 (a)(2) states: <br /> (2)Comply with all applicable requirements listed in this part. Except as provided in§112.6,your Plan may deviate from the requirements in <br /> paragraphs(g),(h)(2)and(3),and(i)of this section and the requirements in subparts B and C of this part,except the secondary containment <br /> requirements in paragraphs(c)and(h)(1)of this section,and§§112.8(c)(2), 112.8(c)(11), 112.9(c)(2),112.9(d)(3),112.10(c), 112.12(c)(2),and <br /> 112.12(c)(11),where applicable to a specific facility,if you provide equivalent environmental protection by some other means of spill prevention, <br /> control,or countermeasure.Where your Plan does not conform to the applicable requirements in paragraphs(g),(h)(2)and(3),and(i)of this <br /> section,or the requirements of subparts B and C of this part,except the secondary containment requirements in paragraph(c)and(h)(1)of this <br /> section,and§§112.8(c)(2),112.8(c)(11), 112.9(c)(2), 112.10(c), 112.12(c)(2),and 112.12(c)(11),you must state the reasons for nonconformance in <br /> your Plan and describe in detail alternate methods and how you will achieve equivalent environmental protection.If the Regional Administrator <br /> determines that the measures described in your Plan do not provide equivalent environmental protection,he may require that you amend your <br /> Plan,following the procedures in§112.4(d)and(e). <br /> Your facility's plan does not state the reasons for the nonconformance in their plan and describe in detail alternate <br /> methods and how they will achieve equivalent environmental protection. <br /> Suggested Corrective Action: Follow the SP001 standard or another industry standard or provide equivalence. Ensure <br /> that this is discussed in the SPCC plan. An alternative would be a hybrid plan which is discussed in the EPA guidance <br /> pages 7-46. <br /> For#715: CFR 112.8(c)(8)(v) states: <br /> (v)You must regularly test liquid level sensing devices to ensure proper operation. <br /> While it is true that during the inspection the clock gauge appeared to not be damaged, a visual inspection of the clock <br /> gauge is not adequate to determine proper operation. The regulation requires liquid level sensing devices to be tested <br /> per good engineering practices. The SP001 standard does have the question in the monthly checklist that addresses this <br /> regulation but that is not included in your facility's current inspection form: <br /> Is overfill prevention equipment in good working condition?If it is equipped with a mechanical test mechanism,actuate the mechanism to confirm <br /> operation. <br /> Suggested Corrective Action: Incorporate the above question into your current monthly inspection form (or make your <br /> form clear as to what is exactly being inspected/tested) or discuss how liquid level sensing devices will be tested to <br /> ensure proper operation in the SPCC plan. <br /> If you have any questions please let me know. <br /> Best Regards, <br /> Lydia Baker <br /> Registered Environmental Health Specialist <br /> San Joaquin County <br /> Environmental Health Department <br /> 209-468-8257 <br /> (baker@sigov.org <br /> Please note my email address has changed to(baker@sjgov.org <br /> 4 <br />