RESPONDENT FAILED TO PREPARE SPCC PLAN IN ACCORDANCD WITH SECTION 112.7, AS REQUIRED BY 40 C.F.R. SECTION 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 SECTION 112.7(b); DISCUSS CONFORMANCES WITH THE MINIMAL SPILL PREVENTION STANDARDS OF SECTION 112.7(c); DISCUSS CONFORMANCE WITH APPLICABLE GUIDELINES OF THE FOLLOW SUBSECTIONS OF 112.7(e); (1) FACILITY DRAINAGE (ONSHORE); (2) BULK STORAGE TANKS (ONSHORE); (3) FACILITY TRANSFER OPERATIONS; (4) FACILITY TANK CAR AND TANK TRUCK LOADING/UNLOADING; (5) INSPECTIONS AND RECORDS; (9) SECURITY; AND (10) PERSONNEL, TRAINING AND SPILL PREVENTION PROCEDURES. FAILURE TO IMPLEMENT AN SPCC PLAN IN ACCORDANCE WITH SECTION 112.7, AS REQUIRED BY 40 C.F.R. SECTION 112.3(a)(1973). RESPONDENT FAILED TO IMPLEMENT: TANK TRUCK LOADING AND UNLOADING AREA GUIDELINES OF SECTION 112.7(c)(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 SECTION 112.7(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; PERSONN