RESPONDENT FAILED TO PROVIDE CATHODIC PROTECTION ON METAL PIPING COMPONENTS OBSERVED TO BE IN CONTACT WITH THE GROUND/SOIL AT THE TIME OF INSPECTION. FOLLOWING INSPECTION, METAL PIPING COMPONENTS WERE ISOLATED FROM THE GROUND/SOIL. RESPONDENT FAILED TO PERFORM RELEASE DETECTION FROM NOVEMBER 2, 2009 TO MARCH 15, 2010 AND FROM NOVEMBER 18, 2010 UNTIL FEBRUARY 20, 2011. SPECIFICALLY, FACILITY DID NOT RECEIVED DELIVERIES OF FUEL DURING WINTER MONTHS WHEN THE UST WAS NOT IN USE. THIS ALLOWED THE UST TO REMAIN BELOW THE LEVEL WHERE THE ATG WOULD FUNCTION PROPERLY. FACILITY WAS IMPLEMENTING NEW STANDARD OPERATING PROCEDURES WITH REGARD TO THE FILLING OF THE UST. RESPONDENT FAILED TO INVESTIGATE AND REPORT A SUSPECTED RELEASE ON JULY 7, 2010 IT RECEIVED A FAIL FROM THE ATG SYSTEM.