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April 2012 Page 3 -2 <br />secondary containment around each of its ASTs, there is no need for an impracticable exception <br />under 112.7(d). <br />As an added measure of safety against a discharge into the Purgatoire River and as secondary <br />containment for the transformers on site, there is a system of drainage ditches that encircles the <br />NECC Facilities (Figure A -5) that ultimately drains into Detention Pond 007. <br />The NECC facilities are also equipped with spill kits that are located adjacent to ASTs. The <br />contents of the spill kits generally include absorbent pads and other absorbent materials, socks, <br />booms and personal protective equipment (PPE) such as safety glasses and gloves. During <br />periodic inspections described in Section 3.5, these spill kits shall also be examined and <br />restocked according to the inventory sheet in Appendix J. <br />3.5 Inspections, Tests and Records [40 CFR 112.7(e)] <br />NECC facility personnel shall periodically observe the ASTs during operating hours. The ASTs <br />and above - ground associated piping and dispensing systems shall be inspected monthly. The <br />results of the inspections shall be recorded on the forms that are included as Appendix C. Spill <br />response kits kept on site shall also be checked during the monthly AST inspection, and <br />restocked as required. The results of the inspections shall be recorded on the form included in <br />Appendix J. The monthly inspection reports shall be kept for at least three years in a file <br />maintained by the Facility Manager or other designated employee. <br />Inspections of the tanks shall include, but are not limited to, observations of the exterior of the <br />tank for signs of deterioration or discharge. Further observations should include inspection of <br />the tank foundation and supports for signs of instability, and inspection of the vent, fill, and <br />discharge pipes for signs of poor connection that could potentially cause a leak. In addition to <br />these monthly inspections, the facility will periodically verify the integrity of each tank in <br />accordance with an industry- standard inspection procedure such as Steel Tank Institute (STI) <br />SP001 -03 or American Petroleum Institute (API) 653 or other equivalent as provided by an <br />outside certified tank inspector. The frequency of this non - destructive testing will be as <br />specified by the selected industry- standard procedure and records of these inspections kept in <br />with the forms in Appendix C. <br />3.6 Personnel, Training and Discharge Prevention Procedures [40 CFR 112.7(f)] <br />The Mine Superintendent is ultimately responsible for oil discharge prevention and preparedness <br />protocols at the NECC facility. Specific procedures, training, and record keeping outlined in this <br />document will be the day -to -day responsibility of the Environmental Compliance Officer at <br />NECC. <br />NECC shall provide SPCC spill training for personnel involved with handling petroleum <br />products as well as yearly discharge prevention briefings for all personnel involved in oil <br />handling. The Environmental Compliance Officer shall arrange for annual training, which shall <br />include the following training topics: <br />• Introduction to pollution control laws <br />SPCC Plan <br />MR 115 Page 27 -15 Rev. May 2012 <br />