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112.8(d)(4).There maybe other applicable sections of 112.8 that may need to be discussed. Violation#301-Failed to amend Plan as necessary. Technical amendments were made to the plan.The double walled tanks are now described as single walled tanks.The two 100 gallon tanks which had used oil have been removed.This plus other changes to the plan are technical changes and require certification by the Professional Engineer.The inspection was conducted in January 2019 and the certification on the plan by the professional engineer is dated May 2018. Also a written statement will be required that assures the department the APSA regulated tanks which are closed meet the definition of permanently closed tanks found in 112.2"Permanently closed means any container or facility for which: (1)All liquid and sludge has been removed from each container and connecting line;and(2)All connecting lines and piping have been disconnected from the container and blanked off,all valves(except for ventilation valves)have been closed and locked,and conspicuous signs have been posted on each container stating that it is a permanently closed container and noting the date of closure." Violation#601-Failure of Plan to fulfill basic requirements including a cross-referencing section. There is no reference for CFR 112.8(c)(2), 112.8(c)(11), 112.8(d)(1), 112.8(d)(4).There may be other applicable sections of 112.8 that may need to be referenced. Violation#604-Plan failed to include oil type and storage capacity for each container. CFR 112.7(a)(3)(i)states that the plan must address"...The type of oil in each fixed container and its storage capacity. For mobile or portable containers,either provide the type of oil and storage capacity for each container or provide an estimate of the potential number of mobile or portable containers,the types of oil,and anticipated storage capacities;..." Page 20 of the SPCC plan lists"drums".The 55 gallon drums are portable containers and the type and storage capacity for EACH 55 gallon drum OR an estimate of the potential number of drums,the types of oil and anticipated storage capacities is not provided. Violation#609-Plan failed to adequately contain procedures for reporting a discharge. The phone number for the CUPA or the San Joaquin County Environmental Health Department is not correct. The correct phone number is (209)468-3420.This number is the 24 hour number for reporting spills and is the main number for the department. Violation#612-Plan failed to include secondary containment, diversionary structures,or equip to prevent discharge. The"sealed" sewer connection or cleanout should be addressed in the SPCC plan and certified through the Professional Engineer.The 15,000 tanks are now described as using that area as the secondary containment.The Engineer would have to certify in accordance with good engineering practice that 15,000 gallons of liquid plus any rain would be contained until cleanup can occur,including that no liquid would escape through that "sealed"sewer port. Violation 8618-Failed to keep records of procedures,inspections,or integrity tests for three years. The return to compliance states that"Monthly inspections started 01/31/19" The violation states that the annual inspections forms provided in the SPCC plan are not being sued for any of the tanks.Something which assures the department that all inspections required by the SPCC plan are being conducted on all tanks and the records retained for the applicable amount of time would be needed. Violation 8711-Failed to perform scheduled tank tests or inspections by appropriately qualified personnel. The tanks have not been tested as per industry standard SP-001. Once the report is complete it will need to be submitted. Violation 8720-Failed to provide corrosion protection for buried piping. The return to compliance states that"Piping installed prior to August 16,2002."This would have to be addressed in the plan and certified by the professional engineer.Also keep in mind that 112.8(d)states,in part, that"... If a section of buried line is exposed for any reason,you must carefully inspect it for deterioration. If you find corrosion damage,you must undertake additional examination and corrective action as indicated by the 3