'**VIOLATIONS: 1) No evidence of three-year review of plan by owner/operator; 2) Inspections required by 40 CFR Part 112 are not in accordance with written procedures developed for the facility; 3) No training on the operation and maintenance of equipment to prevent discharges; 4) No training on the applicable laws, rules, and regulations; 5) Spill prevention briefings are not scheduled and conducted periodically; 6) Bypass valve not normally sealed closed; 7) Runoff rain water not inspected and/or will cause a harmful discharge as defined in 40 CFR 110; 8) Adequate records of drainage events are not maintained; 9) Records of inspections of aboveground tanks are not maintained; 10) Secondary containment inadequate for mobile or portable storage tanks; 11) Aboveground valves and pipelines are not inspected regularly; 12) Periodic pressure testing of the valve and pipelines is not conducted; 13) There is no inspection of lowermost drains and all outlets prior to filling and departure of any tank car or tank truck; and 14) facility not fully fenced and entrance gates are not locked and/or guarded when plant is unattended or not in production. **ASSESSED PENALTY: $1,950.00.