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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 (baker@sjgov.org Please note my email address has changed to(baker@sjgov.org From: Burgin, Andy C (Fresno) USA<andy.burgin@lehighhanson.com> Sent:Wednesday, May 22, 2019 10:13 AM To: Baker, Lydia <Ibaker@sigov.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. If you require that we further discuss the environmental equivalence statement. From the attached EPA document, "The environmental equivalence provision, contained in 112.7(a)(2), allows for deviation from specific requirements of the SPCC rule, as long as the alternative measures provide equivalent environmental protection." Again SP001 is not a specific requirement in the SPCC rule, although setting up an inspection schedule is. We are continuing inspections, therefore we do not need a deviation statement to not use SP001. To further discuss, "equivalent protection" is defined in the attached EPA document as: "In SPCC context, equivalent environmental protection means an equal level of protection of navigable waters and adjoining shoreline from oil pollution." From your office's perspective how does the use of a different form not an equivalent protection to navigable water and adjoining shorelines or more to the point how would any spill from this facility impact these resources? 5