THIS REFERRAL DESCRIBES HOW ADM VIOLATED SECTION 311(J) OF THE CWA AND 40 C.F.R. PART 112 WHEN IT FAILED TO DEVELOP, SUBMIT TO EPA, AND IMPLEMENT FRPS AT FIVE FACILITIES IN REGION 7. THESE FACILITIES ARE LOCATED IN CEDAR RAPIDS, IOWA (THE CEDAR RAPIDS FACILITY); COLUMBUS, NEBRASKA (THE COLUMBUS FACILITY); DES MOINES, IOWA (THE DES MOINES FACILITY); MEXICO, MISSOURI (THE MEXICO FACILITY); AND DEERFIELD, MISSOURI (THE DEERFIELD FACILITY). THE TOTAL ESTIMATED STORAGE CAPACITY OF OIL PRODUCTS AT THESE FIVE FACILITIES, THAT EACH OPERATED WITHOUT REQUIRED FRPS IN PLACE FOR EXTENDED PERIODS OF TIME, IS OVER 36 MILLION GALLONS. ADDITIONALLY, EPA CONDUCTED INSPECTIONS AT ADM'S COLUMBUS AND CEDAR RAPIDS FACILITY IN 2011 THAT DOCUMENTED VIOLATIONS OF THE INDUSTRIAL STORMWATER REQUIREMENTS OF SECTION 402(P) OF THE CWA. LASTLY, A 2012 INSPECTION OF THE DEERFIELD FACILITY DOCUMENTED VIOLATIONS OF SECTION 402(A) OF THE CWA.