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1) Some loss of protective coating leading to corrosion was noted on the piping at the 3 <br />diesel tanks. <br />40 C.F.R., 112.7(e)(3)(iv) [1999-2002] 40 C.F.R. 112.8(d) (4) [revised 2002] requires that <br />all aboveground piping should be regularly inspected to assess general condition. (A <br />record of these inspections is required to be maintained for a period of three years.) <br />Protective coatings on piping and tanks should be maintained as needed in order to <br />prevent corrosion and possible leaks. Some preventative maintenance on the piping at the <br />diesel tanks is indicated. <br />2) Facility staff could not identify where floor drains flow (and could be intercepted) in the <br />event of a spill. This type of information should be readily available and incorporated into <br />training as part of spill response training for employees. <br />40 C.F.R 112.7 [1999-2002][revised 2002] requires that the facility should have a well <br />thought out plan that includes sufficient information for facility spill prevention and <br />response planning. This information should be incorporated into, at a minimum, yearly <br />training for oil -handling employees to ensure they understand the response plan and <br />prevention procedures at the facility. <br />3) During the inspection, minor sheen was observed within the vehicle unloading/loading <br />containment unit. This was most likely associated with flex hose draining. <br />The facility may want to install flex hose racks or storage troughs to prevent hoses from <br />draining into containment creating storm water management issues. <br />In December 1973, the U.S. EPA issued its oil pollution prevention regulations for non - <br />transportation -related onshore and offshore facilities (40 C.F.R. Part 112). On August 16, 2002, <br />the U.S. EPA amended these regulations to provide clarification to the 1973 regulations and <br />reduce the overall compliance burden on regulated industries. In general, the purpose of the <br />regulations is to prevent oil spills from non -transportation -related facilities by establishing <br />pollution prevention procedures, methods, and equipment requirements for owners and operators <br />of facilities engaged in drilling, producing, gathering, storing, processing, refining, transferring, <br />distributing or consuming oil. Information on the compliance date for the new regulations and <br />guidance to assist with your facility's compliance can be found at the U.S. EPA Oil Program <br />website: www.epa.gov/oilspill. <br />Please be reminded that in the event of an oil or hazardous substance discharge to waters <br />of the United States in violation of Section 311(b)(3) of the Clean Water Act ("CWA"), 33 <br />U.S.C. § 1321(b)(3), the facility owner or operator is required pursuant to Section 311(b)(5) of <br />the CWA, 33 U.S.C. § 1321(b)(5), to immediately report all such discharge. Reports must be <br />made to the National Response Center at 1-800-424-8802. Failure to comply with notification <br />requirements may result in both civil and criminal penalties. <br />