Comment submitted by Gary Reeves, George W. Lowry Oil, Inc.

I have researched all the requirements for the implementation of the SPCC Plan under 40 CFR 112 and the State of California EPA. The California EPA is exempting agricultural sites based on their tank size, (under 20,000 US gallons). Most of the potential harm to the US water ways is from agricultural tanks located at or near the water's edge. If you use Google Earth and follow the water ways you will see hundreds of tanks that are not required to have a plan from California EPA. With only two inspectors from Region 9, some of the California CUPAs are informing their farm boards not to worry. I have also looked at the Federal Plan and did not find a signed copy or a published copy in the Federal Register, though there is a copy on the US EPA web site??? If we are going to protect our water ways and improve the quality of life, we must address the agricultural and industrial users. All facilities that are required to have a Plan must be informed and regulated. The State Plan needs to conform to the Federal Plan and remove any confusion on who needs a Plan and what they need to do. Thanks for the opportunity Gary Reeves, PhD, PE