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 POLLUTION ACT OF 1990. 2. PHOENIX OPERATING COMPANY J. A. ALDER TANK BATTERY ROUTE 1, BOX 131A ROSSTON, NEVADA COUNTY, ARKANSAS 71858 3. RESPONDENTWAS IN VIOLATION OF SECTION 311(J) OF THE CWA BY: ) NO EVIDENCE OF THREE YEAR REVIEW OF PLAN BY OWNER/ OPERATOR; 2) WRITTEN PROCEDURES AND A RECORD OF INSPECT- IONS ARE NOT MADE PART OF THE PLAN; 3) WRITTEN PROCEDURES AND A RECORD OF INSPECTIONS ARE NOT MAINTAINED FOR THREE YEARS; 4) NO TRAINING ON THE OPERATION AND MAINTENANCE OF EQUIPMENT TO PREVENT DISCHARGES; 5) NO TRAINING ON THE APPLICABLE LAWS, RULES, AND REGULATIONS; 6) SPILL PRE- VENTION BRIEFINGS ARE NOT SCHEDULED AND CONDUCTED PERIOD- ICALLY; 7) PLAN HAS INADEQUATE OR NO DISCUSSION OF PER- SONNEL AND SPILL PREVENTION PROCEDURES; 8) ACCUMULATED OIL IN THR SECONDARY CONTAINMENT SYSTEM(S) IS NOT PICKED UP AND RETURNED TO STORAGE OR PROPERLY DISPOSED OF IN AC- CORDANCE WITH THE REGULATIONS; 9) FIELD DRAINAGE DITCHES, AND OIL TRAPS, SUMPS, OR SKIMMERS ARE NOT REGULARLY IN- SPECTED FOR OIL, AND/OR OIL IS NOT REMOVED; 10) ADEQUATE RECORDS OF DRAINAGE EVENTS ARE NOT MAINTAINED; AND 11) MATERIALS OF CONSTRUCTION ARE NOT