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Union Point SPCC Plan contact lists do not include the National Response Center, or CA DFW Office of Spill Prevention and Response; Cal me ,r incaFFectly listed as a clean-up cantFacteF. 40 G.A.R. 142.7(e) FequiFes that the f-acility eenduct inspeetiens and tests aeeeFdanee vioth ;AgFitten pFeeedwes that the .-/.,.eFateF.,r the ceFtifying engineer.J.,.,.,Ieps fee the facility UniAGA PAGiRt SPGG Plan inspectien pFermedure states that"All wegetatiOR r-ARtrAIIPd ARCI Re wegetatien is allewed te n aFe r.t near the g el'r.i. AST 40 C.F.R. 112.7(h) addresses facility tank car and tank truck loading/unloading racks. Union Point SPCC Plan cites this section of the regulation, although there is not a loading/unloading rack at the facility.Tank Loading Area Containment should be addressed under 40 CFR 112.7(c) 40 C.F.R. 112.8(c)(1) requires a facility to restrain drainage from diked storage areas by valves to prevent a discharge into the drainage system or facility effluent treatment system, except where facility systems are designed to control such discharge. Union Point SPCC Plan variously states that 'no dikes exist on the facility'; 'There is no drain valves for two of the oil product containment areas'; and "There is one drainage valve on Union Point Marina Bar&Grill, Inc's oil product storage control systems." 40 C.F.R. 112.8(c)(2) requires a facility to construct all bulk storage tank installations so that you provide a secondary means of containment for the entire capacity of the largest single container and sufficient freeboard to contain precipitation. Union Point SPCC Plan calculation of fuel tank secondary containment does not allow for freeboard for precipitation, and shows that the secondary containment is not sufficient for 2000 gallons even without freeboard. No discussion found of secondary containment for used cooking oil tank, or calculation. 40 C.F.R. 112.8(c)(6) requires that 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 are determined in accordance with industry standards, Union Point SPCC Plan does not indicate the industry standard used to determine appropriate inspections and testing. Plan includes reference to a standards organization (Steel Tank Institute) but does not indicate the specific standard that is applicable for the inspections. If STI SP001 is the intended standard,the checklists of Union Point SPCC Plan Appendices B&C are not substantially equivalent. 40 C.F.R. 112.20(e) requires that if the owner or operator of a facility determines that the facility could not, because of its location, reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines,the owner or operator shall complete and maintain at the facility the certification form contained in appendix C. Union Point SPCC Plan Substantial Harm Determination does not include the Certification contained in 40 CFR 112 Appendix C,Attachment C-II. In addition to the preparation of an SPCC Plan, the regulations of 40 C.F.R. 112 require implementation of the Plan. When the training and first inspections required by the regulation and detailed in the Plan have been documented, electronic copies of those records should be submitted to EPA(email attachments are acceptable) as verification. Your continuing cooperation is appreciated, 3