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CFR 112.8(c)(6)Plan failed to adequately discuss procedures to test or inspect each container for integrity.The SPCC plan references Requesting an additional the Steel Tank Institute's SP001 standard.The SPCC plan deviates from the SP-001 standard and does not require annual inspections 60 days while being by the facility as required by the SP-001 standard.A determination on the appropriate qualifications for personnel performing tests reviewed and updated and inspections,the frequency and type of testing and inspections,which take into account container size,configuration,and design by Engineering per the industry standards has not been addressed in the plan per the SP-001 standard.The SPCC plan states that the age of the Department. 20,000 and 30,000 gallon tanks is unknown and integrity testing under SP-001 standards may be due.The outside of the 20,000 and 30,000 gallons containers is not being inspected for signs of deterioration,discharges,or accumulation of oil inside diked areas.The 20,000 and 30,000 gallons containers are described by the facility as being double walled and the interstitial space of the tanks is not being inspected.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 qualifications for personnel performing tests and inspections,the frequency and type of testing and inspections,which take into account container size,configuration,and design(such 710 as containers that are:shop-built,field-erected,skid-mounted,elevated,equipped with a liner,double-walled,or partially buried). Open 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 should describe the selected industry standard and describe the appropriate qualifications for personnel performing tests and inspections and the frequency and type of testing and inspections as required by the standard,or provide equivalence as allowed by CFR 112.7(a)(2).If integrity testing of the tanks is due,provide the reports required by the insutry standard.This is a repeat violation,Class II. CFR 112.8(c)(11)Failed to locate properly or provide sufficient secondary containment for mobile/portable containers.The 55 gallon Requesting an additional drums were observed with absorbent booms as secondary containment.Part of the the SPCC plan states that there should be a 3.5 60 days while being inch berm around the containment area.It is unclear in the SPCC plan whether or not the booms are sufficient to contain the capacity reviewed and updated of the largest single compartment or container with sufficient freeboard to contain precipitation before the booms become saturated by Engineering and can can hold more petroleum product.Position or locate mobile or portable oil storage containers to prevent a discharge as Department. 718 described in§112.1(b).Except for mobile refuelers and other non-transportation-related tank trucks,you must furnish a secondary Open means of containment,such as a dike or catchment basin,sufficient to contain the capacity of the largest single compartment or container with sufficient freeboard to contain precipitation.The SPCC plan should discuss what is sufficient secondary containment portable containers at this facility,or provide impracticability determination pursuant to CFR 112.7(d).This is a repeat violation,Class