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(3) Prior to filling and departure of any tank car or tank truck,closely inspect for discharges the lowermost drain and all outlets of suck vehicles, and if necessary, ensure that they are tightened, adjusted,or replaced to prevent liquid discharge while in transit. Violation#705- Container not compatible with oil stored and/or storage conditions. As described on page 33 the drums and totes are noted as being mobile and portable which don't fall under APSA regulations. Unfortunately, mobile and portable containers do fall under APSA/SPCC regulations as long as they have a capacity of 55 gallons or more and store petroleum product or a product which contains a fraction of petroleum. Mobile and portable containers fall under the category and regulations of Bulk Storage containers. The definition is found below. I have also included guidance on the bulk storage containers. Bulk storage container means any container used to store oil.These containers are used for purposes including, but not limited to,the storage of oil prior to use,while being used,or prior to further distribution in commerce.Oil-filled electrical,operating,or manufacturing equipment is not a bulk storage container. This violation was for the SPCC plan only addressing and certifying material and construction for 4 tanks within the diked area and 3 tanks outside the diked area.The SPCC plan does not address the other bulk storage containers onsite, which also includes mobile and portable containers. 112.8 c) Bulk storage containers. (1) Not use a container for the storage of oil unless its material and construction are compatible with the material stored and conditions of storage such as pressure and temperature. Violation#706-Failed to provide and maintain adequate secondary containment. Noting the two dyed tanks are manifolded together creating a total of 25,000 gallons.We measured our containment and calculated it holds 32,000 gallons which will cover the manifolded tank amount. This would need to be part of the SPCC plan and certified by a registered Professional Engineer. I would also recommend that the engineer use the 25-year,24-hour storm event as the standard to verify sufficient freeboard to contain precipitation, since this is what the EPA believes is the proper standard (67 FR 47117,July 17, 2002). Violation#710- Plan failed to adequately discuss procedures to test or inspect each container for integrity. I have attached copies of the testing done on the tanks. This violation was for the certifying engineer not choosing an industry standard for the tanks.At this point,since there is no standard for the tanks,we would not ask for testing since we wouldn't know which standard would apply to the tanks. It is up to the engineer to certify which standard would be appropriate for the tanks.The certified SPCC plan should 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,none of this is found in the SPCC plan. Once the SPCC plan addresses this,it can be determined if there is testing required and at what frequency. I have included some guidance on industry standards. I cannot open the inspection reports,but I think that Mr. Reeves performed the tank inspections. He is a certified SP-001 inspector,here is a link for the SP-001 inspection guidelines,this is just an overview. This will require a certification by a PE. Violation#718- Failed to locate properly or provide sufficient secondary containment for mobile/portable containers. As noted on page 33 the description of drums and totes are discussed as mobile and portable storage containers located within the warehouse. The warehouse is the secondary containment for these drums and totes since any spill or discharge will be contained inside on the concrete floor. If a spill or discharge were to escape the confinement of the warehouse the liquids will drain East towards the 56,000 gallon spill containment swale area and be contained within that area. Page 33 of the provided sections of the SPCC plan do not reference secondary containment for the drums and totes inside the warehouse.The section that is to address this violation in the SPCC plan,titled"Mobile or Portable Storage Containers 40 CFR 112.8(c)(11)states that the totes and 55-gallon oil drums are portable and the applicable requirements of 40 CFR 112.8(c)(11)does not apply to this facility or SPCC Plan(40 CFR 112.7(e)(2)(xi)(This section does not exist in regulations.There is a 112.7(e),which deals with inspections of tanks,55 gallon drums and the totes would need to comply with inspection guidelines found in the industry standard that would apply to the facility.The secondary containment for the mobile/portable containers needs to be addressed in the SPCC plan and certified by the PE. If the building is the secondary containment for the drums and totes,the walls will need to be certified by the PE, as well. 2