RESPONDENT FAILED TO: KEEP THEIR MANAGEMENT PLANS UP TO DATE, CONDUCT AN INITIAL INSPECTION AND CREATE A MANAGEMENT PLAN, AS REQUIRERD UNDER 40 C.F.R. SECTION 763.93(g)(3), 40 C.F.R. SECTION 763.85(a)(1) AND 40 C.F.R. SECTION 763.93(a), RESPECTIVELY.