1. SECTION 311(B)(6)(B)(I) OF THE CLEAN WATER ACT ( CWA ), 33 U.S.C. SECTION 1321(B)(6)(B)(I), AS AMENDED BY THE OIL POLLUTION ACT OF 1990. 2. SMITH OPERATING AND MANAGEMENT FACILITY: HUMBLE TENSAS-DELTA LEASE SECTION 14, T6 N, R4 E TROUT, LA SALLE PARISH, LOUISIANA 71371 3. RESPONDENT WAS IN VIOLATION OF SECTION 311 OF THE CWA BY: 1) NO EVIDENCE OF THREE YEAR REVIEW OF PLAN BY OWNER/OP- ERATOR; 2) INSPECTIONS REQUIRED BY 40 CFR PART 112 ARE NOT IN ACCORDANCE WITH WRITTEN PROCEDURES DEVELOPED FOR THE FACILITY; 3) WRITTEN PROCEDURES AND A RECORD OF IN- SPECTIONS ARE NOT SIGNED BY FACILITY SUPERVISOR; 4) WRIT- TEN PROCEDURES AND A RECORD OF INSPECTIONS ARE NOT MADE PART OF THE PLAN; 5) WRITTEN PROCEDURES AND A RECORD OF INSPECTIONS ARE NOT MAINTAINED FOR THREE YEARS; 6) NO TRAINING ON THE OPERATION AND MAINTENANCE OF EQUIPMENT TO PREVENT DISCHARGES: 7) NO TRAINING ON THE APPLICABLE LAWS, RULES, AND REGULATIONS; 8) NO DESIGNATED PERSON RE- SPONSIBLE FOR SPILL PREVENTION; 9) SPILL PREVENTION BRIEFINGS ARE NOT SCHEDULED AND CONDUCTED PERIODICALLY; 10) PLAN HAS INADEQUATE OR NO DISCUSSION OF PERSONNEL AND SPILL PREVENTION PROCEDURES; 11) TANK MATERIALS AND CON- STRUCTION ARE NOT COMPATIBLE WITH THE OIL STORED AND THE CONDITIONS OF STORAGE; AND 12) VI