* Inspections and tests required by 40 CFR Part 112 are not in accordance with written procedures developed for the facility.
* Plan has inadequate or no discussion of personnel and spill prevention procedures.
* Drainage from undiked areas do not flow into catchment basins ponds, or lagoons, or no diversion systems to retain or return a discharge to the facility.
* Plan has inadequate or no discussion of facility drainage.
* Plan has inadequate or no discussion of facility transfer operations, pumping, and facility process.