* Inadequate or no prediction of equipment failure which could result in discharges.
* Written procedures 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.
* Walls of containment system are slightly eroded or have low areas.
* Records of inspections of aboveground tanks are not maintained.
* Plan has inadequatae or no discussion of facility transfer operatings, pumping, and in-plant processes.
* Plan has inadequate or no discussion of facility security.