Plan not certified by a professional engineer.
Inadequate or no prediction of equipment failure which could result in discharges.
Plan does not discuss and/or facility does not implement appropriate containment/diversionary structures/equipment.
Inspections and tests required by 40 CFR Part 112 are not in accordance with written procedures developed for the facility.
Written procedures and inspection records are not maintain for three years.
Facility lighting not adequate to facilitate the discovery of spills during hours of darkness and to deter vandalism.
Adequate records (or NPDES permit records) of drainage from diked areas nto maintained.
Containment bypass valves are not sealed closed when not draining rainwater.
Mobile or protable storage containers are not positioned to prevent discharged oil from reaching navigable water.
Plan has inadeqaute or no disucssion of bulk storage tanks.
Vehicle traffic is not warned of aboveground piping or other oil transfer operations.