* Plan not certified by a professional engineer.
* Plan does not follow sequence of the rule and/or cross-reference not provided.
Inspections and tests required by 40 CFR Part 112 are not in accordance with written procedures developed for the facility.
* No training on the applicable pollution control laws, rules, and regulations.
* No training on the contents of the SPCC Plan.
* Spill prevention briefings are not sceduled and conducted periodically.
* Starter controls on pumps are not locked in the off position or located at a site accessible only to authorized personnel when pumps are not in a non-operating or standby status.
* Adequate records (or NPDES permit records) of drainage from diked areas not maintained.
* Plan has inadequate or no discussion of facility drainage.
* Records of inspections (or customary business records) do not include inspections of tank supports/foundation, deterioration, discharges and/or accumulations of oil inside diked areas.