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NCGNE0795_COMPLETE FILE - HISTORICAL_20110928
STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. NCGNE DOC TYPE r� HISTORICAL FILE DOC DATE ❑ � t%I I � �i YYYYMMDD \ W - NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director September 28, 2011 Mr. David Pagliughi Morningstar Marinas @ Skipper's Landing 1152 Perth Road Troutman, North Carolina 28166 Subject: ( No -Exposure Certification.NCGNE0795 Morningstar Marinas @ Skipper's Landing 1152 Perth Road, Troutman, NC Iredell County Dear Mr. Pagliughi: Dee Freeman Secretary The Division has reviewed your submittal of the No -Exposure Certification form for Exclusion from NPDES Stormwater Permitting. Based on your submittal and signed certification of no exposure at the above referenced facility and the site visit of September 2, 2011, the Division is granting your conditional exclusion from permitting as provided for under 40 CFR 122.26(g), which is incorporated by reference in North Carolina regulations. We are also hereby rescinding your current permit Certificate of Coverage, NCG190083. Please note that by our acceptance of your no -exposure certification, you are obligated to maintain no - exposure conditions at your facility. If conditions change such that your facility can no longer qualify for a No - Exposure exclusion, you are obligated to immediately obtain NPDES permit coverage for your stormwater discharge. Otherwise, the discharge becomes subject to enforcement as an un-permitted discharge. Please refer to the information provided in the attached inspection report (last paragraph) highlighting an area at the site where exposure could occur and nullify your No -Exposure Certification. You must self re -certify your No -Exposure status annually using the included form or obtain NPDES permit coverage for any stormwater discharges from your facility. The annual self re -certification does not need to be subm;�ied to DvJQ unless requested. Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain environmental permits that may be required under other federal, state, or local regulations or ordinances. If you have any questions or need further information, please contact Ms. Marcia Allocco at (704) 235-2204, or at marcia.ailocco ncdenr. ov. Sincerely, for Coleen H. Sullins Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663-6040 4 Customer Service: 1-877-623-6748 InterneC www.ncwaterquaiity.org RECEIVED OCT 1 a 2011 InFcwftbon pWOGairtg Unit None rthCarolina Natut,ally An Eoual Ormul--nity 1 Affirmative Action R mlover - 30% RecvcJ8d00% Post Consumer pacer Mr. David Pagliughi NCGNE0795, Page 2 September 28, 2011 Enclosure: No -Exposure Self Re -certification Information sheet Annual No -Exposure Self Re -certification form Site inspection report CC' Stormwater Permitting Unit No- Exposure Files (Brian Lowther) Fran McPherson -Budget Office (fee waiver) Stormwater Permitting File NCG190083 Permit: NCGNE0795 Effective SOC: Effective County: Iredell Region: Mooresville Contact Person: David Pagliughi Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Compliance Inspection Report Expiration: Owner: Morningstar Marinas @ Skipper's Landing Expiration: Facility: Morningstar Marinas @ Skipper's Landing 1152 Perth Rd Title: Inspection Date: 09102/2011 Entry Time: 12:37 PM Primary Inspector: Marcia Alloccol �" Secondary Inspector(s): Troutman NC 28166 Phone: 704-528-3328 Certification: Exit Time: 01:06 PM Phone: Phone: 704-663-1699 Ext.2204 Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Stormwater Discharge, No Exposure Certificate Facility Status: ® Compliant ❑ Not Compliant Question Areas: 10 Miscellaneous Questions (See attachment summary) Page: 1 Permit: NCGNE0795 Owner - Facility: Morningstar Marinas @ Skipper's Landing Inspection Date: 09102I2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: The facility was visited through a new No -Exposure Certification request. Industrial activities performed at the facility include marina operations. The facility discharges stormwater to Lake Norman via one drop inlet and sheet flow over the impervious surfaces (concretelasphalt). The facility conducts the following industrial activities: • Boat fueling (no evidence of spills during inspection) • Boat weatherization (process is performed in a secondary containment unit; stored inside) • Boat pump -out services (mobile unit; no signs of residual material on equipment and stored inside) • Boat washing (occurs outside but facility contact noted that runoff does not reach Lake Norman) . The following requirements are required to maintain No -Exposure: • Any wash water from boat washing shall not be discharged to Lake Norman, if wash water reaches Lake Norman than this would nullify No -Exposure Certification and the permittee would need to apply for coverage under an industrial stormwater permit. Page: 2 5 Division of Water Quality / Surface Water Protection �A 4 NCDENRNational Pollutant Discharge Elimination System -1:,.,,,1.�, r•,� , �. NO EXPOSURE CERTIFICATION for Exclusion FNvn7vr�.rt wn NN'Uw.rb ;o�z�rs NCGNE0000 NO EXPOSURE CERTIFICATION FOR AGENCY USE OIKLY Date Received Year Month Da Certificate ofCoverage NICIGINE-10111915 National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit based on NO EXPOSURE: Submission of this No Exposure Certification constitutes notification that your facility does not require a permit for stormwater discharges associated with industrial activity in the State of North Carolina because it qualifies for a no exposure exclusion. A condition of no exposure at an industrial facility means all industrial materials and activities are protected by a storm resistant shelter (with some exceptions) to prevent exposure to rain, snow, snowmelt, and/or runoff. For permitted facilities in North Carolina, DWQ must approve your application for No Exposure Certification before this exclusion is effective. Until you are issued a No Exposure Certification and your NPDES permit is rescinded, your facility must continue to abide by the terms and conditions of the current permit. Industrial materials or activities include, but are not limited to: material handling equipment or activities, industrial machinery, raw materials, intermediate products, by-products, final products, or waste products. Material handling activities include the storage, loading and unloading, transportation, or conveyance of any raw material, intermediate product, final product or waste product. A storm resistant shelter is not required for the following industrial materials and activities: drums, barrels, tanks, and similar containers that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed" means banded or otherwise secured and with locked or non -operational taps or valves; adequately maintained vehicles used in material handling; and final products, other than products that would be mobilized in stormwater discharges (e.g., rock salt). A No Exposure Certification must be provided for each facgly qualifying for the no exposure exclusion. In addition, the exclusion from NPDES permitting is available on a facility -wide basis only —not for individual outfalls. If any industrial activities or materials are, or will be, exposed to precipitation, the facility is not eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, you certify that a condition of no exposure exists at this facility or site and are obligated to comply with the terms and conditions of 40 CFR 122.26(g). You are required to self re -certify your No Exposure Exclusion annually. For questions, please contact the DWO Regional Office for your area. (Seepage 6) (Please print or type) 1) Mailing address of owner/operator (address to which all certification correspondence will be mailed): Name M0JZNII-c,Sr,+IZ Contact Street Address City Telephone No, Email SW U-NE-12Aug2010 T2 a u-r-m► iy State /VC ZIP Code 2 S / d L 70y 5-2ir - 332 fi' Fax: may(_ SZl- 606l M&i,/UGH-.r & M0tZN,N"-r4RMArZ)N11J, C ON Page 1 of 7 0_17-y AUU 1 "aancr� a a'�>�kds,j NCGNE0000 No Exposure Certification 2) Location of facility producing discharge: Facility Name Facility Contact Facility Street Addres City County Telephone No. Email T-R o,j-rM AN _ State /L/ el ZIP Code Z le / d d :20 �Ug 33^,2g- Fax: 7 eyZ fS Gy6 I D Aky-L/ 1J &PrO MCIA A/6, STji�' /VI�r2/Alft�� �aM 3) Physical location information: Please provide a narrative description of how to get to the facility (use street names, stat road numbers and distance and direction rom a roadway intersection). ►� Y l W s 7L rrr+'r V Al ; 1 TH (A copy of a map with the facility clearly located on it should be included with the certification application.) 4) Is the facility located on Native American Lands? ❑ Yes No 5) Is this a Federal facility? ❑ Yes ❑ No 6) Latitude 35 03"S.gZ 9 �5I �/ / Longitude LO *5'3' Yl.11 O ✓ (deg., min., seconds) 7) This NPDES No Exposure Exclusion application applies to which of the following: ❑ New or Proposed Facility Date operation is to begin eyol Existing Date operation began / 00 ❑ Renewal of existing No Exposure Certification Certification No.: NCGNE 8) Was this facility or site ever covered under an NPDES Stormwater Permit?X Yes ❑ No If yes, what is the NPDES Permit Number? MC G19Oa 4 3 9) Standard Industrial Classification: Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial activity at this facility SIC Code: I/ 9 10) Provide brief descri tion of the types of Indus ial activities �and� products produced at this facility: 11) Does this facility have any Non -Discharge permits (ex: recycle permits)? No ❑ Yes If yes, list the permit numbers for all current Non -Discharge permits for this facility: Page 2 of 7 SWU-NE-12Aug2010 NCGNE0000 No Exposure Certification Exposure Checklists (12. - 14.) 12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not eligible for the no exposure exclusion. a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes XNo residuals from using, storing or cleaning industrial machinery or equipment remain and are exposed to stormwater b. Materials or residuals on the ground or in stormwater inlets from spills/leaks El Yes ANo c. Materials or products from past industrial activity ❑ Yes No d. Material handling equipment (except adequately maintained vehicles) ❑ Yes No e. Materials or products during loading/unloading or transporting activities ❑ Yes i No f. Materials or products stored outdoors (except final products intended for outside ❑ Yes )(No use [e.g., new cars] where exposure to stormwater does not result in the discharge of pollutants) g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, ❑ Yes ANo and similar containers h. Materials or products handled/stored on roads or railways owned or maintained by El Yes KNo the discharger i. Waste material (except waste in covered, non -leaking containers [e.g., dumpsters]) ❑ Yes No j. Application or disposal of process wastewater (unless otherwise permitted) ❑ Yes No k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑ Yes XNo otherwise regulated (i.e., under an air quality control permit) and evident in the stormwater outflow 1. Empty containers that previously contained materials that are not properly stored ❑ Yes KNo (i.e., not closed and stored upside down to prevent precipitation accumulation) m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers ❑ Yes KNo stored outside, has the facility had any releases in the past three (3) years? 13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not eligible for the no exposure exclusion. a. Are exterior ASTs and piping free of rust, damaged or weathered coating, pits, or Yes ❑ No ❑ N/A deterioration, or evidence of leaks? b. Is secondary containment provided for all exterior ASTs? If so, is it free of any Yes ❑ No ❑ N/A cracks, holes, or evidence of leaks, and are drain valves maintained locked shut? Page 3 of 7 SWU-NE-12Au92010 NCGNE0000 No Exposure Certification 14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the no exposure exclusion. a. Is secondary containment provided for all single above ground storage containers (including drums, barrels, etc.) with a capacity of more than 660- gallons? b. is secondary containment provided for above ground storage containers stored in close proximity to each other with a combined capacity of more than 1,320- gallons? c. Is secondary containment provided for Title III Section 313 Superfund Amendments and Reauthorization Act (SARA) water priority chemicals`? d. Is secondary containment provided for hazardous substances`* designated in 40 CFR §116? e. Are release valves on all secondary containment structures locked? 1 S) Hazardous Waste: a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste generated per month) of hazardous waste? c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste generated per month) of hazardous waste? If you answered yes to questions b. or c., please provide the following information: Type(s) of waste: How is material stored: Where is material stored: How many disposal shipments per year: Name of transport / disposal vendor: Vendor address: Footnotes to Questions 14) c. & d. ❑ Yes ❑ No 0 NIA ❑ Yes ❑ No A NIA ❑ Yes ❑ No )'N/A ❑ Yes ❑ No X NIA ❑ Yes ❑ No A NIA ©Yes X No ❑ Yes Xi No ❑ Yes XNo 'Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require secondary containment_ However, some exceptions may be made for de minimis amounts of certain substances, and/or other qualifiers, as described in the exemptions from reporting requirements of Title III SARA 313 in 40 CFR §372.38. **Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require secondary containment. However, some exceptions may be made for amounts less than the Reportable Quantities of the hazardous substances listed in 40 CFR §117.3. Page 4 of 7 SWU•NE-12Aug2010 NCGNE0000 No Exposure Certification 16) Other information: If you answer "Yes" to any of the following items, you might not be eligible for the no exposure exclusion. A more in-depth evaluation of the site circumstances may be required. a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? ❑ Yes No b. Does your facility have coal piles on site? ❑ Yes ,Pl No c. Does your facility store other fuel sources outside in piles, such as wood chips, ❑ Yes XNo sawdust, etc.? d. Does your facility have air emissions associated with its industrial activity (e.g., ❑ Yes X No degreasing operations, plating, painting and metal finishing)? If so, describe the industrial activity: e. If you answered yes to d., are those emissions permitted by an Air Quality Permit? ❑ Yes ❑ No X1 NIA Please specify: f. Please list any other environmental program permits (federal, state, etc.) not specified earlier in this application (such as Hazardous Waste Permits, etc.): Permit: SDTF ` yCj" d 1/ , Program: !V L S ePfqV 9,,W* "^FAT_ Permit: o sr—Fw& T-Lh;_A" 0- D360n7 Program: UA V.nJ S4e,-ie Taw - Permit: Program: Permit: Program: Permit: Program: Permit: Program: Permit: Program: Page 5 of 7 5W U-NE-12Aug2010 NCGNE0000 No Exposure Certification 17) Certification: I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of "no exposure" and obtaining an exclusion from NPDES stormwater permitting. I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities or materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.26(g)(2)). I understand that I am obligated to annually self re -certify No ExQosure and, it requested, submit the re -certification to DWQ or the operator of the local municipal separate storm sewer system (MS4) into which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of Water Quality, or MS4 operator where the discharge is into the local MS4, to perform inspections to confirm the condition of no exposure and to make such inspection reports publicly available upon request. In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief such information is true, complete, and accurate. Printed Name of Person Signing; Ar . J P., ry Title: �—. C4erti- MqnaQtr (Signature of Applicant) 7 /!I'll (Date Signed) Please note: This application for the No Exposure Exclusion is subject to approval by the NCDENR Regional Office prior to issuance. The Regional Office may inspect your facility for compliance with no exposure conditions prior to that approval. The Regional Office may also inspect your facility at any time in the future for compliance with the No Exposure Exclusion. North Carolina General Statute 143-215.6 B(i) provides that: Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan, or other document tiled or required to be maintained under this Article or a rule implementing this Article; or who knowingly makes a false statement of a material fact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the [Environmental Management] Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed ten thousand dollars ($10.000). There is currently no fee for a No Exposure Exclusion, Page 6of7 SWU-NE-12Aug2010 NCGNEOOOO No Exposure Certification Final Checklist This application should include the following items: This completed application and all supporting documentation. A map with the location of the facility clearly marked. 1% If the site currently has an NPDES Stormwater Permit, be sure to indicate the permit number in Question 8. Mail the entire package to: Stormwater Permitting Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Note The submission of this document does not guarantee the issuance of a No Exposure Exclusion. For questions, please contact the DWQ Regional Office for your area. DWQ Regional Office Contact Information: Asheville Office ...... (828) 296-4500 Fayetteville Office ... (910) 433-3300 Mooresville Office ... (704) 663-1699 Raleigh Office ........ (919) 791-4200 Washington Office ...(252) 946-6481 Wilmington Office ... (910) 796-7215 Winston-Salem ...... (336) 771-5000 Central Office .........(919) 807-6300 Page 7of7 SWU-NE-12Aug2010 i c { a+ '• + •i ses C r'+1r w �f i�• ' .a.sw u. ', ."rt y. tiers 1 � ' -1J m4 i RIP C--UC4T BLOCK/SELF. { `. ��SL ,4crL V ri�'�'s rrri �S• rea �' 4 p `� I';:.5+9 5.1"._ .�,o DOCtiS ii t1 � . = .r. - :6�.! iIis. • _�.�i c, ^{ r �•�r 4� i i � tim."�SLtf]Oi. N-•L S6 ram: _ y i icT w.a »y� • h � }- tP ,� si+.l. � :Y _.-.r. 2•:..3' {': Yam. . f a -..• �.� 4�• ' �•n:.w �' � "' •`.� i 04 WLIXNG r r � s.i.�.., � ,fir � .r �� • � � � i r . � �' .._i 1 j,��-:.,:•. way •. �r � \ .i�lL��.3�' 1..� ( '.yf'. T X\��\'\`�' �i.£. w. ; S!. `�5 �•IwIG •F1d!'• �1 \\\\ \\\ 10.6 fir 1 r NNBar _ a -- 1 sasr �'+.? _ , i �• 1 J !` r =' _ t i�S P. s �SF}�' SO S1CLi+ • + +� i ' �! �]i. i • ". PDrg52=7 ];f ,�,� �i�' --•v� .id 11 'i F j}1j 1111 1i11 V j111 alit C,4L`.. FlI-T� No Exposure Certification Questions Permit No.: NCG NCSO NCGNE Facility Name: n .. Permit Effective: NA Discharges to: Inspection Date: Inspection Type CEI CSI Complaint Other Inspector(s): Agency: C-M2RO MCWQP Entry Time: ,a .. Facility Contact (s)__�j i Exit Time '. Work Days Facility Status: Compliant Non -Compliant Neither C'"n Page 1 of 3 Rev. 1, 6109 No Exposure Certification Questions If you answer "Yes" to any of these questions the facility is not eligible for No Exposure (or for question #10 might not be eligible) Yes FNoj NA 1. Does the facility/site use, store, or clean industrial machinery or equipment and are those areas, where residuals from using, storing, or cleaning industrial machinery or equipment remain exposed to ❑ ❑ stormwater? 2. Is there any evidence of materials or residuals on the ground or in stormwater inlets from spills or ❑ ❑ leaks? 3. Is there any evidence of materials, residuals, or products from past industrial activity (past sources of ❑ Sd ❑ contamination that have remained on site which could cause a condition of exposure)? 4. Are any materials or final products (including improperly maintained material handling equipment, transformers, cooling towers, and air compressors) exposed to precipitation during material handling, loading/unloading, or transporting activities, now or in the foreseeable future? [The containers, racks, ❑ V ❑ and other transport platforms (e.g., wooden pallets) used for the storage or conveyance of these final products can also be stored outside, providing the containers, racks, and platforms are pollutant -free]. 5. Are any materials or products contained in open, deteriorated or leaking storage drums, barrels, ❑ ❑ tanks, and similar containers exposed to precipitation, now or in the foreseeable future? 6. Are any materials or products exposed to precipitation handled or stored on roads or railways owned ❑ ❑ or maintained by the discharger? 7. Is any waste material (except waste in covered, non -leaking containers, e.g., dumpsters) ❑ ❑ exposed to precipitation, now or in the foreseeable future? 8. Is there application or disposal.of process wastewater (unless otherwise permitted) exposed to ❑ ❑ precipitation, now or in the foreseeable future? 9. Is there particulate matter or visible deposits of residuals from roof stacks/vents not otherwise ❑ ❑ regulated, i.e., under an air quality control permit, exposed to precipitation? 10. Does the facility have an Emissions permit with the Division of Air Quality? What pollutants does it ❑ ❑ cover? Does the facility file a TRI report? What chemicals are released? Comments: Page 2 of 3 Rev. 1, 6109 �r No Exposure Certification Questions If you answer "No" to any of these questions the facility is not eligible for No Exposure Yes No NA 11. Are drums, barrels, tanks, and similar containers exposed to precipitation labeled, tightly sealed, in good condition, free of leaks and any deterioration, and properly stored? ❑ ❑ S/ 12. Are materials stored in original containers with original labels? ❑ ❑ 13. Are incompatible materials stored separately? ❑ ❑ 14. Do drums, barrels, tanks, and similar containers exposed to precipitation meet DOT specifications, including compatibility? ❑ ❑ 15. If empty containers that previously contained materials are exposed to precipitation are they properly stored (i.e., closed and stored upside down to prevent precipitation from accumulating on top of the drums around the bung)? ❑ ❑ 16. For facilities or sites with exterior ASTs and drums, barrels, tanks, and similar containers stored outside, has the facility been free of any releases in the past 3 years? ❑ ❑ 17. Is the storage area secured to prevent unauthorized entrances? ❑ ❑ 18. Are exterior ASTs physically separated from and not associated with vehicle maintenance? ❑ ❑ 19. Are piping, flanges, valves, pumps or other equipment exposed to precipitation free of any evidence of leaks and spills? ❑ ❑ ' -,i 20. Are exterior ASTs and piping exposed to precipitation protected from traffic lanes to minimize exposure? ❑ ❑ 21. Are exterior AST coatings free of signs of bubbled, cracked, damaged, or weathered coating? ❑ ❑ 22. Are exterior ASTs or piping/supports free of rust, pits or deterioration or evidence of leaks? ❑ ❑ 23. Are exterior AST leak detection systems operating properly? ❑ ❑ 24. Are exterior AST capacity indicating equipment operating properly? ❑ ❑ 25. Is secondary containment provided for all exterior ASTs? Is secondary containment free of any holes, or evidence of leaks? El Elcracks, 26. Is exterior AST secondary containment enclosure free of accumulated water? ❑ ❑ 27. Are exterior AST secondary containment drain valves maintained locked shut? ❑ ❑ 28. Are drain logs being maintained for all exterior AST secondary containment? ❑ ❑ 29. Are spill kits available and adequate? ❑ ❑ 30. For facilities or sites with exterior ASTs and drums, barrels, tanks, and similar containers stored outside, has the facility developed and implemented an SPCC plan, an inspection and maintenance program, material handling procedures, and site specific loading and unloading procedures? ❑ ❑ 31. For facilities or sites with ASTs and drums, barrels, tanks, and similar containers stored outside, has the facility developed and implemented an employee training program addressing spill prevention control and countermeasures, inspection and maintenance, material handling procedures, and site specific loading and unloading procedures? ❑ ❑ 5/ Comments: Page 3 of 3 Rev. 1, 6109