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-a One black metal 55 gallon drum of petroleum product was observed on a wooden pallet next to the stairway of area D7 on the map and was not addressed in the SPCC plan. -b One black metal 55 gallon drum of Transmission MDL was observed inside of area D7 and was not addressed in the SPCC plan. -c One metal 55 gallon drum of gear oil was observed on a secondary containment pallet in area D7 and was not addressed in the SPCC plan. -d One blue metal 55 gallon drum of oily water was observed in the machine shop and was not addressed in the SPCC plan. -e One 1000 gallon poly tank of oily water in the vehicle wash area was listed as"steel' in Table 1 of the SPCC plan. -f Three blue metal 55 gallon drums of oil and one green metal 55 gallon drum of oily water were observed in area D3 and were not included in the SPCC plan. -g Page 27 of the SPCC plan says that the cardboard bailer will use the alternative requirements in 40CFR 112.7(k) (2).Table 1 in the SPCC plan contradicts this and says the cardboard bailer will use general containment. No general containment was observed near the cardboard bailer. -h The SPCC plan states that the three generators are operational oil-filled equipment. Generators do not meet the definition of operational oil-filled equipment. The Spill Prevention, Control,and Countermeasure(SPCC) Plan must be amended when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge,within 6 months of the change, and implemented as soon as possible, not later than 6 months following preparation of the amendment. Immediately ensure that the SPCC Plan accurately represents the procedures and policies currently in place at the facility. This is a Class II violation. Response: a, b and c:The drums identified have been placed in an oil storage cabinet with a capacity of 845 gallons.The drums are now stored inside this cabinet. See photo (Figures 2 and 3) in Appendix B. d. All oil containers over 55 gallons are shown on Figure 3 in Appendix A and listed in Table 1 of Appendix B of the updated SPCC Plan. e. All oil containers over 55 gallons are shown on Figure 3 in Appendix A and listed in Table 1 of Appendix B of the updated SPCC Plan. f. We have updated the SPCC plan to correctly identify the oil drums in area D-3 of Figure 3 of the SPCC plan. g. All oil-filled operational equipment, including the Cardboard Baler, is correctly identified in Table 1. h. The fuel tanks of the generators are correctly identified in Table 1. Violation#609—CFR 112.7(a)(3vi), 112.7(a4) Plan failed to adequately contain procedures for reporting a discharge. The Spill Prevention, Control,and Countermeasure(SPCC) Plan does not provide information and procedures to enable a person to adequately report a discharge.The phone number for the San Joaquin County Environmental Health Department is missing. If a response plan was not submitted to the Regional Administrator,this information must be included in the SPCC Plan. Immediately ensure the SPCC Plan includes the phone number for the SJC EHD and submit a copy of the revision to the EHD. This is a Class II violation. Response: We have updated the SPCC plan to add the phone number for SJC-EHD to Tables 4&5 of the Contingency Plan in Appendix C. A revised copy of the SPCC plan will be submitted to the EHD upon completion by July 31'h. See copy of updated SPCC plan. Violation#630—CFR 112.7(k) Failure to provide general secondary containment or alternative for oil-filled operational equipment. On page 27 of the SPCC plan it states that the facility will use the alternative requirements for oil-filled operational