1. SECTION 311(B)(6)(B)(I) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1321(B)(6)(B)(I), AS AMENDED BY THE OIL POLLUTUION ACT OF 1990. 2. THOMAS PIPE & STEEL, INC. 2421 NORTHLINE ROAD PORT ALLEN, WEST BATON ROUGE PARISH, LOUISIANA 70767 3. RESPONDENT WAS IN VIOLATION OF SECTION 311(J) OF THE CWA BY: 1) PLAN NOT CERTIFIED BY A PROFESSIONAL ENGINEER; 2) INADEQUATE OR NO PREDICTION OF EQUIPMENT FAILURE WHICH COULD RESULT IN DISCHARGES; 3) WRITTEN PROCEDURES AND A RECORD OF INSPECTIONS ARE NOT MADE PART OF THE PLAN; 4) PLAN HAS INADEQUATE OR NO DISCUSSION OF PERSONNEL AND SPILL PREVENTION PROCEDURES; 5) ADEQUATE RECORDS OF DRAINAGE EVENTS ARE NOT MAINTAINED; 6) RECORDS OF IN- SPECTIONS OF ABOVEGROUND TANKS ARE NOT MAINTAINED; 7) PLAN HAS INADEQUATE OR NO DISCUSSION OF BULK STORAGE TANKS; 8) PLAN HAS INADEQUATE OR NO DISCUSSION OF FACILI- TY TRANSFER OPERATIONS, PUMPING, AND IN-PLANT PROCESSES; 9) INADEQUATE SECONDARY CONTAINMENT, AND/OR RACK DRAINAGE DOES NOT FLOW TO CATCHMENT BASIN, TREATMENT SYSTEM, OR QUICK DRAINAGE SYSTEM; 10) PLAN HAS INADEQUATE OR NO DIS- CUSSION OF FACILITY TANK CAR AND TANK TRUCK LOADING/UN- LOADING RACK; AND 11) PLAN HAS INADEQUATE OR NO DISCUS- SION OF FACILITY SECURITY. 4. RELIEF SOUGHT PURSUANT TO SECTION