1. No evidence of three yer review of plan by owner/operator.
2. wirtten procedures and a record of inspections are not maintained for three years.
3. No traininhg on the operation and maintenance of equipment to prevent discharges.
4. No training on the applicable laws, rules, and regulations.
5. Field drainage ditches, road ditches, and oil traps, sumps, or skimmers are not regularly inspected for oil, and/or oil is not removed.
6. Adequate records of drainage events are not maintained.
7. Excessive vegetation which affects the integrity of the containment system.
8. Visual tank inspections are not conducted periodically by appropriate personnel and/or inspections do not include tank foundation and supports.
9. Above ground valves and pipelines are nto examined periodically on a scheduled basis for general condition (includes items, such as: flange joints, valve glands 2nd bodies, drip pans, pipeline supports, bleeder and gauge valves, polish roads/stuffing box.
10. Brine disposal facilities are not examined often.
11. Inadequate or no flowline maintenance program (includes: examination, corrosion protection, flowline repalcement).