EPA ALLEGES THAT SPIRIT SERVICES FAILED DO THE FOLLOWING: (1) PROVIDE SUFFICIENTLY IMPERVIOUS SECONDARY CONTAINMENT FOR THE ENTIRE CONTENTS OF THE LARGEST SINGLE TANK PLUS SUFFICIENT FREEBOARD TO ALLOW FOR PRECIPITATION; (2) PERIODICALLY TEST ABOVE GROUND CONTAINERS FOR INTEGRITY USING HYDROSTATIC TESTING, VISUAL INSPECTION, OR A SYSTEM OF NON-DESTRUCTIVE SHELL THICKNESS TESTING; KEEP COMPARISON RECORDS; INSPECT CONTAINTER SUPPORTS AND FOUNDATIONS; AND FREQUENTLY OBSERVE THE OUTSIDE OF CONTAINERS OF DETERIORATION, LEAKS, OR ACCUMULATION OF OIL INSIDE DIKED AREAS; (3) MAINTAIN A RECORD OF INSPECTIONS, SIGNED BY THE APPROPRIATE SUPERVISOR OR INSPECTOR, FOR A PERIOD OF THREE YEARS; (4)PROPERLY INSTRUCT OIL HANDLING PERSONNEL IN THE OPERATION AND MAINTENANCE OF EQUIPMENT TO PREVENT THE DISCHARGE OF OIL AND APPLICABLE POLLUTION CONTROL LAWS, RULES AND REGULATIONS; (5) SCHEDULE AND CONDUCT SPILL PREVENTION BRIEFINGS FOR THEIR OPERATING PERSONNEL AT INTERVALS FREQUENT ENOUGH TO ASSURE ADQUATE UNDERSTANDING OF HTE SPCC PLAN FOR THE FACILITY.