Summary of Findings:
No management approval of plan.
Inadequate or no prediction of equipment failure which could dresult in discharges.
Inspections and tests required by 40 CFR Part 112 are not in a accordance with written procudures developed for the facility.
Written procedures and inspection records are not signed by appropriate supervisor or inspector.
Written procedures and inspection records are not kept with the plan and are not maintained for three years.
No designated person accountable for spill prevention.