OIL POLLUTION ACT AS FOLLOWS: FAILED TO IMPLEMENT A PROGRAM OF FACILITY RESPONSE DRILLS AND EXERCISES FOR OIL SPILL RESPONE; FAILED TO PERFORM INSPECTIONS (OR ADEQUATE INSPECTIONS), OR FAILED TO MAINTAIN PROPER RECORDS OF SUCH INSPECTIONS AT THE FACILITY; FAILED TO COMPLY WITH PERSONNEL, TRAINING AND DISCHARGE PREVENTION PROCEDURES; FAILED TO COMPLY WITH SECURITY REGULATIONS PERTAINING TO FACILITY LIGHTING; FAILED TO RETAIN ADEQUATE RECORDS OF DIKE DRAINAGE EVENTS; AND FAILED TO INCLUDE IN ITS SPCC PLAN COMPLETE DISCUSSIONS REGARDING CERTIFICATION REQUIREMENTS FOR TECHNICAL AMENDMENTS OR THE REQUIREMENTS FOR TANK TRUCK LOADING/UNLOADING RACKS.