Summary of Finding
* Plan does not discuss conformance with SPCC requirement.
* Plan has inadequate or no description of the physical layout of the facility.
* Plan has inadequate or no description and procedures to use when a discharge may occur.
* Inadequate or no prediction of equipment failure which could result in discharge.
* Plan does not discuss appropriate containment/diversionary structures/equipment.
* Inspections and tests required by 40 CFR Part 112 are not in accordance with written procedures developed for the facility.
* Plan has inadequate or no discussion of personnel and spill prevention procedures.
* Drainage from undiked areas do not flow into catchment basins ponds, or lagoons, or no diversion systems to retain or return a discharge to the facility.
* Aboveground tanks are not subject to periodic integrity testing, such as hydrostatic, nondestructive methods, etc.
* Plan has inadequate or no discussion of bulk storage tanks.