The Respondent failed to: (a) ensure that all the Class A, B and/or C operators at the four facilities (Roe FB, MLK FBCH, Mollo FB, and D?Amato CH) met operator training requirements from October 13, 2018 to December 20, 2020; (b) maintain required documentation of periodic walkthrough inspections at three of the facilities (Roe FB, MLK FBCH, and D?Amato CH) from October 13, 2018 to October 1, 2020; and (c) conduct the initial 3-year inspection of the overfill prevention equipment located at one facility (D?Amato CH) by October 13, 2018.