Evaluated site hydraulics and hydrology, physical condition of facility, manufacturing operations and management, product freight transport operations and existing environmental management systems. Then developed SPCC, including visual integrity assessment of 7,000-gallon ASTs containing polyester resin, 10,000 gallon diesel fleet fueling AST, drummed protective coatings, etc. Calculated secondary containment capacities around ASTs and load-unload racks. Plan included development of appropriate checklists and procedures for facility equipment inspections, product delivery operations, emergency spill response, etc. Plan also included program of required upgrades to facility pavements, curbing, AST secondary containment, etc., and replacement of polyester-resin tanks with new, more modern systems.