Summary of Findings:
Plan has inadequate or no description of the physical layout of the facility.
Inspections and tests required by 40 CFR Prt 112 are not in accordance with written procedures developed for the facility.
Above ground valves and pipelines are not examined periodically on a scheduled basis for general condition (includes items, such as: flange joints, valve glands 2nd bodies, drip pans, pipeline supports, bleeder and gauge valves, polish rods/stuffing box.