Respondent failed to prepare SPCC Plan in accordance with § 112.7, as required by 40 C.F.R. § 112.3(a). The Facility's SPCC Plan failed to: predict direction, rate of flow, and quantity of oil that could potentially be discharged due to major types of equipment failures as required by § 112.7(b); discuss conformance with the minimal spill prevention standards of § 112. 7( c); discuss conformance with applicable guidelines of the follow subsections of § 112. 7( e): (\) facility drainage(onshore); (2) bulk storage tanks (onshore); (3) facility transfer operations; (4) facility tank car and tank truck loading/unloading; (8) inspections and records;(9) security; and (10) personnel, training and spill prevention procedures. Failure to implement an SPCC Plan in accordance with § 112.7, as required by 40 C.F.R. § I 12.3(a) (1973). Respondent failed to implement: tank truck loading and unloading area guidelines of § 112.7(e)(4)(ii) by failing to provide a containment system at the rack designed to hold at least maximum capacity of any single compartment of a tank car or tank truck loaded or unloaded in the plant; inspections and records guidelines of § I 12.7(e)(8) by failing to implement written procedures for all required inspections, failing to record inspections
in its SPCC Plan, failing to ensure inspection records were signed by the appropriate supervisor or inspector, and failing to maintain such records for three years; personnel, training and spill prevention proce