'**VIOLATIONS: 1) Plan not certified by a professional engineer; 2) Inadequate or no prediction of equipment failure which could result in discharges; 3) Written procedures and a record of inspections are not maintained for three years; 4) No training on the operation and maintenance of equipment to prevent discharges; 5) Spill prevention briefings are not scheduled and conducted periodically; 6) Valves used to drain diked areas are not of manual, open-and-closed design; 7) Adequate records of drainage events are not maintained; 8) Records of inspections of aboveground tanks are not maintained; and 8) Periodic pressure testing of the valves and pipelines is not conducted. **ASSESSED PENALTY: $950.00.