EPA Region 3 conducted an SPCC/FRP inspection in late 1997 by at a major east coast refinery, situated along Curtis Bay in Baltimore MD. Curtis Bay drains into the Chesapeake Bay and a release from the site could severely impact a sensitive ecological area. During the inspection, the inspectors observed evidence of deterioration in the concrete foundations of several of the tanks. A Notice of Non-Compliance was sent to the company outlining deficiencies noted during the inspection and from the SPCC plan review. The company addressed the SPCC plan deficiencies but failed to address issues regarding the tank foundations, periodic integrity testing and protection of buried piping. An Administrative Complaint was issued under Section 311 of the CWA. The company denied the allegations and asked for an administrative hearing. An Alternate Dispute Resolution (ADR) process was arranged. One result of the ADR was that the Facility agreed to further assess the cathodic protection system and soil corrosivity, and to evaluate the foundations of five of the ASTs. Simultaneously, EPA arranged for an expert to provide technical consulting support in the area of American Petroleum Institute (API) 653 inspections and compliance procedures. When the company submitted the results of their API inspection, they indicated that the ASTs were safe and calculated the remaining service life to exceed the 20 year inspection interval requirement. They proposed the next inspection interval to be the maximum of 20 years. EPA's consultant was able to demonstrate that the company had made incorrect assumptions about the as-built tank foundation design. This resulted in incorrect calculations regarding the degree of existing cathodic protection. As a result, EPA prevailed in recalculating a service life/internal inspection interval of 4.58 years and requiring some additional corrective measures to be taken at the facility. The result of EPA's action is that the ASTs located at the site will be operated with a higher degree of safety and environmental protection.

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