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623 - Plan failed to address security of site and valves, lock out/tag out, and lighting. The SPCC plan still does not address lighting. The regulation states the following Describe in your Plan how you secure and control access to the oil handling, processing and storage areas; secure master flow and drain valves; prevent unauthorized access to starter controls on oil pumps; secure out-of-service and loading/unloading connections of oil pipelines; and address the appropriateness of security lighting to both prevent acts of vandalism and assist in the discovery of oil discharges. 706 - Failed to provide and maintain adequate secondary containment. Similar to violation 613 — The plan does not address whether or not the entire capacity of the largest tank will be contained within the secondary containment, and sufficient freeboard to contain precipitation. It is unclear what the secondary containment is in some cases and whether or not the secondary containment is sufficiently impervious to contain discharged oil. 710 - Plan failed to adequately discuss procedures to test or inspect each container for integrity. The plan states the following In addition to these monthly inspections, the facility will periodically verify the integrity of each tank in accordance with an industry standard inspection procedure such as STI- SP001-03. The frequency of such testing will be as specified by the selected industry standard procedure. The regulations state the following Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs. You must determine, in accordance with industry standards, the appropriate g_ualifications for personnel performing tests and inspections, the frequency and type of testing and inspections, which take into account container size, configuration, and design (such as containers that are: shop-built, field-erected, skid-mounted, elevated, equipped with a liner, double-walled, or partially buried). Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing. You must keep comparison records and you must also inspect the container's supports and foundations. In addition, you must frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices satisfy the recordkeeping requirements of this paragraph. The SPCC plan references the STI SP-001 standard but fails to follow the standards requirements. Yearly inspections of the tanks are not addressed.The appropriate qualifications for personnel performing tests and inspections are not discussed, the frequency and type of testing and inspections required by the standard are not discussed. There are different categories that the tanks may fall under, it is up to the engineer to certify which category the tanks fall under and the type of inspections and frequencies required under those categories. Furthermore the included inspection checklist references API standard 653. If both standards will be used then API 653 will need a discussion which satisfies the regulations, this is apart from the STI SP-001 standard discussion. 726 - Plan failed to adequately describe overfill prevention methods for each container. The SPCC plan seems to only address overfill prevention for the 20,000 gallon tank. All bulk storage containers should be addressed (any container with a capacity of 55 gallons or more that store petroleum products). The regulation state the following Engineer or update each container installation in accordance with good engineering practice to avoid discharges. You must provide at least one of the following devices: 2