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April 2012 Page 4 -2 <br />4.3.6 Testing and Inspections [40 CFR 112.8(c)(6)] <br />Testing and inspections of ASTs is discussed in Section 3.5 of this Plan. <br />4.3.7 Heating Coils [40 CFR 112.8(c)(7)] <br />The NECC facility does not utilize heating coils for any of the bulk storage tanks on site. <br />4.3.8 Overfill Prevention Systems [40 CFR 112.8(c)(8)] <br />It is our understanding the six ASTs at NECC have dial level gauges on them and the two used <br />oil tanks have no gauges currently. <br />Per 112.8(c)/l 12.12(c) Bulk Storage Containers of the CFR SPCC Checklist:2 <br />Each container equipped with at least one of the following for liquid level <br />sensing: (i) high liquid level alarms with an audible or visual signal at a <br />constantly attended operation or surveillance station, or audible air vent in <br />smaller facilities, (ii) high liquid level pump cutoff devices set to stop flow at a <br />predetermined container content level, (iii) direct audible or code signal <br />communication between container gauger and pumping station, (iv) fast response <br />system (such as digital computers, telepulse, or direct vision gauges) and a <br />person is present to monitor gauges and the overall filling of bulk storage <br />containers, (v) liquid level sensing devices regularly tested to ensure proper <br />operation. <br />Although further investigation is needed into this matter, a cost effective means of meeting the <br />above standard would be a Krueger tank gauge with alarm or similar device. <br />4.3.9 Effluent Treatment [40 CFR 112.8(c)(9)] <br />The storm water effluent will be monitored as prescribed under the NPDES Permit CO- 00009063 <br />and ultimately be discharged into the Middle Fork of the Purgatoire River. There are no <br />additional effluent treatment facilities present. <br />4.3.10 Visible Discharge [40 CFR 112.8(c)(10)] <br />Any visible discharge from any storage container will be dealt with swiftly according the <br />Discharge Response Plan outlined in Section 5. <br />4.3.11 Portable Containers [40 CFR 112.8(c)(11)] <br />There are numerous 5- gallon containers and drums of oil products on the property at any given <br />time. When the smaller 5- gallon containers are not in use, they are returned to an area that has <br />'- U.S. Environmental Protection Agency (2005), "SPCC Field Inspection and Plan Review Checklist," Version 1.0, <br />November 28, 16 p. <br />3 New Elk Coal Company LLC (2008), "Colorado Discharge Permit System Permit Number CO- 0000906, Las <br />Animas County," issued October 24. <br />SPCC Plan <br />MR 115 Page 27 -20 Rev. May 2012 <br />