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This violation will be closed owe PE certified plan is received. Violation#706-Failed to provide and maintain adequate secondary containment. If the single walled 1,000 gallons tank does not meet the definition of permanently closed(see violation 301)it needs to be addressed in the plan,unless it has been removed. Violation#710-Plan failed to adequately discuss procedures to test or inspect each container for Integrity. There are some concerns with Section 8 Periodic Integrity Testing Schedule(2009 revision)of the SPCC plan. • I am not sure that the UL Standards mentioned are inspection standards but instead are construction standards for aboveground tanks to be able to store certain product. Since this will be certified by a professional engineer this will be forwarded to the EPA who would have the authority to make a decision on this. • The regulations state that all tanks must be tested or inspected for integrity on a regular schedule and whenever material repairs are made.The inspection procedures only focus on Tank#1 and tank#2.The facility has more than 2 tanks at the facility.What is the integrity inspection/testing procedure for the other APSA regulated tanks?The other tanks would new a discussion in the environmental equivalence section since it is not clear that they are being inspected or tested for integrity under any industry standard.This should include per regulations the reasons for nonconformance in your Plan and describe in detail alternate methods and how you will achieve equivalent environmental protection. • The regulation states that You must determine,in accordance with industry standards,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.The qualifications of the person testing or inspecting the tanks is not described for any of the tanks. • One of the sections discussing the inspection of the tanks refers to containers that are subject to 21 CFR part 110.None of the tanks at the facility would be subject to that regulation and the paragraph would exclude the tanks from being inspected.This is the Food and Drug Administration Current Good Manufacturing Practice in Manufacturing, Packing or Holding Human Food. • A comment on the provided statements for return to compliance or for the SPCC plan. Federal SPCC regulations,State APSA regulations and local County ordinances do not set the inspection or testing schedule for the tanks.This is normally found in the selected industry standard or is set by the professional engineer,the same applies for the qualifications of the person inspecting the tanks. • The reasons why STI-SP001 is not being used should be in the SPCC plan,this would then be certified by the professional engineer.This would be the response provided for line item#710 part B in the return to compliance certification that was provided. Violation#726-Plan failed to adequately describe overfill prevention methods for each container. The plan states that overfill containment boxes/chambers are available for each AST.And that containers of 55 gallons are exempt?Be aware that containment boxes do not meet the overfill requirements of APSA/SPCC regulations. Another part of the plan states that the tanks have a cam locking filling device and fill trucks have automatic shutoffs when desired volume is reached. This will be verified during the next inspection.Overfill devices should meet one of the following requirements. i) High liquid level alarms with an audible or visual signal at a constantly attended operation or surveillance station. In smaller facilities an audible air vent may suffice. (ii)High liquid level pump cutoff devices set to stop flow at a predetermined container content level. (iii)Direct audible or code signal communication between the container gauger and the pumping station. (iv)A fast response system for determining the liquid level of each bulk storage container such as digital computers,telepulse,or direct vision gauges.If you use this alternative,a person must be present to monitor gauges and the overall filling of bulk storage containers. (v)You must regularly test liquid level sensing devices to ensure proper operation. Violation#4010-Unlisted Administration/Documentation violation. APPENDIX C TO PART 112--SUBSTANTIAL HARM CRITERIA is not included in the SPCC plan.Appendix C to Part 112 needs to be filled out and retained at the facility. 2