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619 The adequacy of the onsite vehicle departure system in the loading area was not discussed <br /> • The Plan update addresses the requirements for the onsite vehicle departure system. <br /> Recommended practices and procedures will be implemented and will be included in our driver <br /> training. <br /> 620 No procedures for inspecting the lowermost drains and all outlets of fuel delivery vehicles were <br /> outlined <br /> • The Plan update addresses the requirements for the inspecting drains and outlets of fuel <br /> delivery trucks. Recommended practices and procedures will be implemented and will be <br /> included in our driver training. <br /> 712 The plan does not adequately describe the integrity testing schedule <br /> • The Plan update will address the integrity testing schedule <br /> 716 The SPCC plan didn't discuss overfill prevention <br /> • The Plan update will discuss overfill prevention and if there are additional requirements they <br /> will be implemented within 6 months <br /> 717 The SPCC plan didn't discuss the requirements for testing overfill prevention equipment <br /> • The Plan update will discuss the testing requirements and provide inspection intervals. <br /> 727 No records for underground piping integrity testing were available for review <br /> • Underground piping is double walled pipe and is continually monitored. Monitoring <br /> requirements will be addressed in the Plan update. <br />