Summary of Findings:
* Inadequate or no prediction of equipment failure which could result in discharges.
* Written procudures and a record of inspections are not made part of the plan.
* Spill prevention briefings are not scheduled and conducted periodically.
* Plan has inadequate or no discussion of facility drainage.
* Secondary containment appears to be grossly inadequate.
* Records of inspections of aboveground tanks are not maintained.
* Plan has inadequate or no disucssion of facility transfer operations, pumping, and in-plant processes.
* Plan has inadequate or no discussion of facility security.