* Inspections required by 40 CFR Part 112 are not in accordance with written procedures developed for the facility.
* Written procedures and a record of inspections are not made part of the plan.
* Written procedures and a drecord of inspections are not maintained for three years.
* No designated person responsible for spill prevention
* Drainage from undiked areas not into ponds, lagoons, or catchment basins, or no diversion systems to return spills to the facility.
* Adequate records of drainage events are not maintained.