5-1

Chapter 5 Piping and Pipelines 5

CHAPTER 5 

Piping and Pipelines

This chapter summarizes:

 Underground and aboveground piping

 Loading and unloading racks

5.1 Common Causes of Leaks

Most leaks from both underground storage tank (UST) and aboveground storage tank (AST) systems occur in the piping and connections that are a resul

faulty installation, poor preventive maintenance, and lack of adequate protection from corrosion. Aboveground piping also is at risk of releases from physical

damage such as vehicle collision; therefore, it is important to install, maintain, 

and operate piping properly.

5.2 Underground Piping

To safeguard underground piping, use a contractor who installs piping according to a nationally recognized code of practice. Nationally recognized codes

standards, and test methods include:

 National Association of Corrosion Engineers (NACE) International S

PracticeSP 0285, “External Corrosion Control of Underground Storage

Systems by Cathodic Protectio

 NACE International Standard Pratice SP 0169, “Control of

Corrosion on Underground or Submerged Metallic Piping Syste

 American Petroleum Institute Recommended Practice 1632, “Cat

Protection of Underground Petroleum Storage Tanks and Piping Sy

 American Petroleum Institute Recommended Practice 570, “P

Inspection Code: In-service Inspection, Rating, Repair, and Alterati

Piping System

 Steel Tank Institute Recommended Practice R892, “Recommended P

for Corrosion Protection of Underground Piping Networks Associated w

Liquid Storage and Dispensing Syst

 NACE International Test Method TM0497, “Measurement Techniques

to Criteria for Cathodic Protection on Underground or Submerged Metalli

Piping Systems

Have the contractor certify that the piping was installed correctly in accordance

with the certification of installation requirements found in 40 CFR 280.20(e). I

addition, take the following steps:

 Equip the piping with continuous leak detection

 Provide the piping with corrosion protection

 Provide the piping with secondary containment

 Leak detection requirements for 

UST pressurized piping installed 

prior to April 11, 2016 are in 40 CFR 

280.41(b)(1)(i) and those for suction 

piping are in 40 CFR 280.41(b)(1)(ii). 

Piping installed or replaced after 

April 11, 2016 must meet the requirements in 40 CFR 280.41(b)(2).

 Corrosion protection requirements for UST piping are in 40 CFR 

280.20(b) and 280.31.

 Interstitial monitoring requirements for UST piping are in 40 

CFR 280.43(g). This applies to all 

UST piping installed after April 11, 

2016, except for suction piping that 

meets the requirements of 40 CFR 

280.41(b)(1)(ii)(A) through (E).

 Closure requirements for UST 

piping are found in 40 CFR Part 280, 

Subpart G.

 Release reporting and recordkeeping requirements for UST piping are 

found in 40 CFR Part 280, Subpart E.

The Law Says
5-2 Chapter 5 Piping and Pipelin

 Follow applicable regulations when conducting pipe closure.

 Report and record any releases

For a typical schematic of piping for UST systems, see Exhibit 5−

EXHIBIT 5−1

Overhead Schematic of Piping at a UST Facility

5.2.1 Operation and Maintenance Requirements

Overall operation and maintenance (O&M) requirements for USTs (see Chapter 3

Underground Storage Tanks) may be generally applied to piping. Piping-specific

O&M requirements are identified below:

 Operate and maintain corrosion protection systems to continuously provide 

protection to the metal components of piping that routinely contain 

regulated substances and are in contact with the ground (40 CFR 280.31(a))

 Replace metal pipe sections and fittings that have released product because

of corrosion or other damage (40 CFR 280.33(c))

 Repair fiberglass (non-corrodible) pipes and fittings in accordance with the

manufacturer’s specifications (40 CFR 280.33(c))

 Conduct line tightness testing on repaired piping within 30 days of the repair 

(40 CFR 280.33(d)).Test cathodic protection systems within 6 months of repai

(40 CFR 280.33(e))
Chapter 5 Piping and Pipelines 5

5.2.2 Leak Detection for UST Piping

At least every 30 days, UST systems (tanks and piping) must be monitored f

leaks using proper leak detection methods. Leak detection methods must be

able to detect a leak from any portion of the tank and connected underground 

piping that routinely contains product. Leak detection must be installed, calibrated, operated, and maintained according to the manufacturer’s instructions.

There are two main types of piping: (1) pressurized piping and (2) suction piping.

Pressurized piping and suction piping must use the leak detection methods

described below. 

5.2.2.1 Pressurized Piping

Each pressurized piping run must have one of the line leak detection methods, as

well as monitoring methods, provided in Exhibit 5−2.

EXHIBIT 5−2

Pressurized Piping Release Monitoring

Pressurized Piping Installed or Replaced on or 

prior to April 11, 2016

Pressurized Piping 

Installed or Replaced 

after April 11, 2016

Piping must have devices that automatically shut off, restrict

flow, or trigger an alarm that indicates a leak 1 ND annual li

tightness test of the piping must take place, or in lieu of the 

annual tightness test, one of the following monthly methods 

must be used:

Interstitial monitoring

 Groundwater monitoring

 Vapor monitoring2

 Continuous in-tank leak detection

 Statistical inventory reconciliatio

 Other methods approved by the implementing agency

In addition to the

requirements on the 

left, pressurized piping 

installed or replaced 

after April 11, 2016

must have secondary 

containment with 

interstitial monitoring.2

1An automatic line leak detector (LLD) that is an automatic flow restrictor, an automatic flow shutoff, or continuous

alarm system.

2Interstitial monitoring, vapor monitoring, groundwater monitoring, and statistical inventory reconciliation have the 

same regulatory requirements for piping as they do for tanks. (See Chapter 4, Underground Storage Tanks)

5.2.2.2 Suction Piping

Each suction piping run must have one of the line leak detection methods, as

well as monitoring methods, provided in Exhibit 5−3.

Line tightness testing must be:

 Able to detect a 0.1 gallon per hour 

leak rate 1.5 times the operating 

pressure.

 Conducted annually. If the test is 

performed at pressures lower than 

1.5 times operating pressure, the 

leak rate to be detected must be 

correspondingly lower.

Automatic LLDs and line tightness 

tests must also be able to meet the 

federal regulatory requirements regarding probabilities of detection and 

false alarm.

Did You Know?
5-4 Chapter 5 Piping and Pipelin

EXHIBIT 5−3

Suction Piping Release Monitoring

Suction piping installed or replaced on or 

prior to April 11, 2016

Suction piping 

installed or replaced 

after April 11, 2016

Suction piping meeting the description below does not need

release detection:

 Below-grade piping operating at less than atmospheric 

pressure is sloped so that the piping’s contents will drain back 

into the storage tank if the suction is released.

 Only one check valve is included in each suction line and is 

located directly below the suction pump.

Suction piping that does meet the above criteria must either

have line tightness testing at least every 3 years or any of the 

following monthly monitoring:

 Vapor monitoring

 Groundwater monitorin

Interstitial monitorin

 Statistical inventory reconciliatio

 Other approved methods

Suction piping

installed or replaced 

after April 11, 2016,

must have secondary 

containment 

with interstitial 

monitoring, except 

suction piping 

meeting the 

description to the left.

5.2.3 Closure of UST Piping

Temporary and permanent closure requirements for UST piping are the same 

for USTs (see Chapter 3, Underground Storage Tanks

5.2.4 Recordkeeping and Reporting

Recordkeeping and reporting requirements for underground piping are the same

as for USTs (see Chapter 3, Underground Storage Tanks

5.3 Spill Prevention, Control, and 

Countermeasure Requirements

Piping and pipelines (underground and aboveground) for transporting petroleum within the facility are regulated under the Spill Prevention, Control, a

Countermeasure (SPCC) regulations. For information on the applicability of th

SPCC regulations, refer to Chapter 1, Environmental and Emergency Respons

Planning and Chapter 4, Aboveground Storage Tanks and Containers. If your

facility is subject to SPCC regulations, you must demonstrate compliance with th

piping requirements in your facility’s SPCC Plan. The contents of this plan w

respect to piping are listed below:

 Facility Diagram: The plan must include a facility diagram that includes all

transfer stations and connecting pipes, including intrafacility gathering lines 

that are otherwise exempt (40 CFR 112.7(a)(3)

 Security: The plan must contain a description of how to secure out-of-service

and loading and unloading connections of oil pipelines (40 CFR 112.7(g))
Chapter 5 Piping and Pipelines 5

5.3.1 Underground Piping

The SPCC Plan must describe procedures for meeting the following techni

requirements for underground piping:

 Secondary Containment: Secondary containment or diversionary structures

are required for underground piping to prevent releases to navigable waters 

and adjoining shorelines and to capture the discharge of oil until cleanup 

occurs. Double-walled piping is the most common method of containment,

although other options are allowed as long as they are consistent with good 

engineering practice and approved by a licensed Professional Engineer (

reviewing the SPCC Pl

 Corrective Actions: Whenever buried piping is exposed, examine it for 

corrosion damage and take any necessary corrective actions. The plan must

describe procedures to promptly correct visible discharges that result in a 

loss of oil from seams, gaskets, piping, pumps, valves, rivets, and bolts (40 

CFR 112.8(c)(10)). If corrosion damage is discovered, additional examinatio

and corrective action, as indicated by the magnitude of the damage, must be 

performed (40 CFR 112.8(d)(1))

 Protective Coating and Corrosion Protection: Buried piping must be 

protected with wrapping and coating. Cathodic protection that satisfies the 

corrosion protection standards (40 CFR 112.8(d)(1)) must be provided. Where

cathodic protection of underground piping is not used, a facility could use 

double-walled piping combined with an interstitial leak detection system 

as an alternative. Another option would be to implement a comprehensive

monitoring, detection, and prevention maintenance program for piping 

where effective cathodic protection is not reasonably achievable to detect 

and address potential discharges.

 Leak Detection: Conduct integrity and leak testing at the time of installation, 

modification, relocation, retrofitting, upgrading, or replacement.

Your SPCC Plan must describe any environmental protection alternatives deem

equivalent to cathodic protection that must be certified by the sealing P

5.3.2 Aboveground Piping

The SPCC Plan must describe procedures for meeting the following technical 

aboveground piping:

 Secondary Containment: Secondary containment or diversionary structures

are required for aboveground piping to prevent releases to navigable waters 

and adjoining shorelines and to capture the discharge of oil until cleanup 

occurs. Double-walled piping is the most common method of containment,

although other options are allowed as long as they are consistent with good 

engineering practice and approved by a licensed Professional Engineer (

reviewing the SPCC Pl

 Piping Supports: Design pipe supports to prevent sagging, minimize

corrosion, and allow for expansion and contraction (40 CFR 112.8(d)(3))
5-6 Chapter 5 Piping and Pipelin

 Piping Inspections: Inspect all aboveground pipelines regularly. Check the

conditions of the pipe supports, connecting joints, valves, gauges, pumps, 

and catch basins. They should be free of leaks, drips, and oil-stained soil

underneath (40 CFR 112.8(d)(4))

 Maintenance: Promptly replace and repair defective or leaking piping and

equipment, and keep records of any repairs. Flow valves must be periodically 

packed with grease, and gaskets must be replaced to prevent leaks. Pumps

may require periodic rebuilding, and connecting lines may need to be 

resealed to prevent leaks (40 CFR 112.8(c)(10))

 Warning Signs: Post warning signs to alert traffic of aboveground piping, or

verbally warn drivers, as appropriate (40 CFR 112.8(d)(5))

 Out-of-Service: When lines are taken out-of-service or are in standby for 

extended periods, cap or blind-flange and mark the connection at the 

transfer point.

5.3.3 Loading and Unloading Racks

A loading and unloading rack is a fixed structure (such as a platform or gangway)

necessary for loading or unloading a tank truck or tank car.  loading arm is

essential for a loading and unloading rack that typically includes at least one 

swivel joint. Other components may include any combination of the following: 

piping assemblages, valves, pumps, shutoff devices, overfill sensors or personnel 

safety devices.

SPCC regulations require that loading and unloading racks have secondar

containment to contain the contents from the largest single compartment of a 

tank car or tank truck. The most common system of secondary containment for

loading and unloading racks is a covered, curbed, graded area that drains to a 

sump (sometimes called a quick drainage system). If the drainage system does

not flow to a catchment basin or wastewater treatment system, then the area 

should have curbing. One option to meet this requirement is to use an oil/water 

separator as part of a quick drainage system.

Other requirements for loading and unloading racks are:

 Warning lights, physical barriers, warning signs, wheel chocks, or vehicle 

brake interlock systems must be used to prevent a vehicle from leaving 

before it is completely disconnected from the fuel transfer lines (40 CF

112.7(h)(2)).

 Tank car or tank truck drains and outlets must be closed and inspected for

leaks prior to filling and prior to departure (40 CFR 112.7(h)(3))

Loading and unloading areas that use a single hose and connection or standpipe

are not considered racks. These transfer areas must meet the general secondary

containment requirements but do not necessarily need to be sized for the largest 

compartment of the tank car or truck. However, containment size must be based

on good engineering judgment (see Chapter 4, Aboveground Storage Tanks and 

Containers for examples of general secondary containment measures).

SPCC Plan regulations require that 

loading and unloading racks be 

properly designed, operated, and 

maintained:

 Secondary Containment requirements are found in 40 CFR 

112.7(h)(1).

 Connection/Disconnection Safety 

Methods to prevent vehicles 

from departing before complete 

disconnection of lines are found 

in 40 CFR 112.7(h)(2).

 Truck Inspection requirements are 

found in 40 CFR 112.7(h)(3).

The Law Says...

 Pipelines that transport fuel off 

facility grounds must comply 

with the safety, operating, testing, 

and reporting requirements of 49 

CFR 195.

 The Pipeline and Hazardous 

Materials Safety Administration 

(PHMSA) requires a Pipeline 

Response Plan for certain onshore pipelines (49 CFR 194). 

For reference, see Chapter 1, 

Environmental and Emergency 

Response Planning.

The Law Says...
Chapter 5 Piping and Pipelines 5

5.4 Transportation Pipeline Systems

The U.S. Department of Transportation (DOT) shipping regulations address requirements for loading and unloading of packages and cargo as well as li

via loading and unloading racks. Other DOT regulations address interstate an

cross-country pipeline operations.

5.4.1 Loading and Unloading Racks

All drivers must follow loading and unloading procedures established by 

regulations in 49 CFR 177 Subpart B for highway shipments via tank trucks and 4

CFR 174 Subpart C for railway tank car loadin

In general, the following requirements apply to tank cars and tank trucks

 No smoking is allowed while loading and unloading explosives, flammable

liquids, solids, and gases, and oxidizing agents (40 CFR 177.834(c))

 Hand brakes must be securely set and other precautions taken to prevent

motion during loading and unloading (40 CFR 177.834(e))

 Drivers or designated employees must attend to or observe loading and

unloading activities (40 CFR 177.834(i))

Refer to the DOT regulations for additional requirements for specific materials, su

as flammable or combustible liquids and flammable gases.

5.4.2 Cross-country Pipelines

Pipelines used to transport fuel outside facility grounds (such as cross-country

pipelines) are subject to the design, construction, operation, and safety standards 

established by the DOT Office of Pipeline Safety (49 CFR 195). DOT regulat

transportation-related portion of the pipeline running to, or from, a fuel terminal 

while the U.S. Environmental Protection Agency (EPA) regulates the termin

transfer operations. Cross-country pipelines regulated by DOT include associate

pipeline pumping stations and breakout tanks.

5.4.2.1 Steel Pipeline Systems

You must meet the following requirements for new carbon steel pipeline systems 

and existing steel pipe systems that are relocated, replaced, or otherwise changed:

 Comply with the minimum design requirements of 49 CFR 195 Subpart C

including pipe, valve, fitting requirements, and internal inspection devices.

 Construct your pipeline systems according to the minimum requirements of 

49 CFR 195 Subpart D, including using qualified personnel and conducting t

proper inspections. Cathodic protection, welding work, pumping stations, and 

breakout tanks must meet certain requirements. Keep construction records for 

the life of each pipeline facility.

Do not operate your pipeline unless it has been pressure tested without leakage

according to 49 CFR 195 Subpart
5-8 Chapter 5 Piping and Pipelin

5.4.2.2 Operation and Maintenance

Operate your cross-country steel pipeline system at the level of safety required 

by 49 CFR 195 Subpart F. For each pipeline system, prepare and follow a manua

of written procedures for conducting normal O&M activities and for handling 

emergencies. Additional requirements include the following

 Establish and conduct a continuing training program to instruct O&M

personnel and emergency response personnel.

 Maintain current maps and records of your pipeline systems.

 Maintain the operating pressure at or below the pipeline design pressure.

 Provide a communication system for the transmission of information

necessary for the safe operation of your pipeline system.

 Place and maintain line markers over each buried pipeline, especially at road

and railroad crossings.

 Conduct the appropriate tests, inspections, and repairs of pipeline, valves, 

and fittings to maintain good working order at all times.

 For each pumping station and breakout station, maintain adequate 

firefighting equipment and the appropriate signs and prevent unauthorized 

entry.

 Prepare a written program to prevent damage to buried pipelines by

excavation activities.

The O&M manual must be reviewed annually for accuracy and effectiveness

5.4.2.3 Pipeline Safety and Integrity

DOT requires a written report within 5 to 10 working days of discovery of any o

the pipeline safety-related conditions described in 49 CFR 195.55. For instance,

reportable conditions include corrosion damage, material defects, unintended 

pipeline movement (for example, from earthquakes or floods), and malfunctions 

resulting in a pressure rise of more than 110% of its maximum operating pressure. 

The Safety-Related Condition Report must be sent to the PHMSA via its online portal (see Section 5.7, For More Information) or via fax 202−36

Alternatively (but least desirable), it can be mailed to Information Resourc

Manager, Pipeline and Hazardous Materials Safety Administration, PHP−2

New Jersey Avenue SE, Washington, DC, 2

DOT published Pipeline Integrity Management regulations in 49CFR 195.452

pipelines in highly populated areas, in environmentally sensitive areas, and near 

commercially navigable waters. 

To reduce the potential for failure in these critical areas, the rules require continual assessment and evaluation of pipeline integrity. This consists of inspections o

testing to identify corrosion and other damage, automatic or remotely operated 

values for rapid shutdown of pipelines, risk analysis of pipeline segments, and 

corrective measures or repairs to prevent rupture. Pipeline operators must document their integrity management program in writing and periodically review and

update it. 
Chapter 5 Piping and Pipelines 5

5.4.2.4 Written Public Awareness Programs

Each cross-country pipeline operator is required to develop and implement a

written continuing public education program in accordance with 49 CFR 195.440.

The program must educate the public, emergency agencies, local public officials,

and persons engaged in excavation about the possible hazards of unintended 

releases, emergency notification procedures, and safety steps in the event of 

a pipeline release. Awareness activities and events given for the public and

nearby municipalities, schools, or businesses should be documented. Additional

requirements for the written program are found in the PI Standard 1162, Pub

Awareness Programs for Pipeline Operators. Pipeline operators, including interstate

and intrastate petroleum pipelines, is required to submit their written program 

to PHMSA upon request. In addition to the requirements described above, o

submissions, reports, and procedures, required by pipeline operators are identified in Exhibit 5-4.

EXHIBIT 5−4

Required Plans, Procedures, Notifications, Submittals, and Written Programs

Plan, Procedure, Notification, Submittal, Written 

Program

Requirement

Conversion to Service Procedures 49 CFR 19

Safety Procedures for Regulated Rural Gathering Lines 49 CFR

Integrity Management (IM) Program and Baseli

Assessment Pl

49 CFR 195.12 and

.452

Annual Report 49 CFR 195

Accident Reports 49 CFR 195.50 and 

Written Procedure to Calculate Amount of Release 49 CFR 195.5

Safety-Related Condition Reports 49 CFR 195.55 an

Facility Abandonment or Deactivation Report 49 CFR 19

Provide National Pipeline Mapping System Geospatial

to PHMSA Annu

49 CFR 195.6

Welding Procedures 49 CFR 195.2

Nondestructive Weld Testing Procedures 49 CFR 195

O&M Procedural Manual for Operations (Normal) 49 CFR 195.

O&M Procedural Manual for Operations (Abnormal an

emergencies)

49 CFR 195.40

Public Awareness and Education Program 49 CFR 19

Damage Prevention Program 49 CFR 195

Written Control Room Management Procedures 49 CFR 195.

Qualification Program 49 CFR 195.5

Spill and accident reporting requirements for pipeline facilities are summarized in

Chapter 2, Incident and Spill Reporting.
5-10 Chapter 5 Piping and Pipelin

5.5 Cross-Country Pipelines—DLA Energy 

Requirements

In response to public concern over U.S. pipeline incidents DLA Energy crea

program to safeguard all cross-country pipelines under its operational control. 

This includes requirements to

 Inspect and evaluate pipeline and pipeline components at rivers, streams,

and other water crossings.

 Conduct a close-interval survey of cathodic protection.

 Conduct caliper pig surveys to identify irregularities and obstructions to flow. 

Excavate, repair, and inspect segments identified as problem areas

 Conduct ultrasonic or magniflux surveys (using sound or magnetism) 

to determine internal pipe conditions. Excavation of underground pipes

at random locations may be required for ultrasonic testing of actual wall 

thickness.

 Compute the internal design pressure after actual wall thickness is 

determined (if design records are unavailable).

 With the above information and safe operating pressure, conduct a pressure 

test to verify the absence of leaks. Other leak detection technologies may be 

accepted by regulatory agencies.

Although specifically developed for government-owned, contractor-operated

(GOCO) facilities, the above recommendations can be applied to any fuel facility 

operation.

5.6 State Requirements

Some states may have piping requirements that are more stringent than federal

regulations. For example, Florida has additional construction and secondary 

containment requirements for integral UST piping. Be sure to check your stat

UST o AST regulations for piping and loading rack requirements. In add

 See Chapter 3, Underground Storage Tanks, Section 3.7, State Requirements

 See Chapter 4, Aboveground Storage Tanks and Containers: Section 4.9, State

Requirements and Appendix 4-1, States with Aboveground Storage Tank 

Regulations.

Also, check your state pipeline safety agency (often the utility commission) for

pipeline requirements more stringent than federal regulations. Refer to the

“Compendium of State Pipeline Safety Requirements and Initiatives Prov

Increased Public Safety Levels” compared to the CFR (referenced in Section 

For More Information). States and their respective more stringent requirements

compared to 49 CFR 195 are identified in Exhibit 5-5

State Requirements
Chapter 5 Piping and Pipelines 5-

EXHIBIT 5−5

More Stringent State Pipeline Regulations Compared to Federal Regulations

More Stringent State Piping Regulations Compared to Federal Regulations in 49 CFR 195

State Enhance

Reportin

More 

Direct

Oversight

Corrosion 

Control

Design

and 

Instal

Pressure

Testin

Leak

Test

Damage

Preventio

Broader 

in Scop

AZ x x x 

CA x x x x 

LA

NM 

PA

TX x x x x 

WA x x x x 

5.7 For More Information 

For Information On... See...

Piping Related Agencies

EPA Office of Underground Storage Tanks www.epa.go

(800) 424−9346

DOT Pipeline and Hazardous Materials S

Administration (P

www.phmsa.dot.gov

(202) 366−4433

PHMSA Portal (for submitting rep

https://portal.phmsa.dot.gov/portal

Users must be registered and assigned 

an Operator D numbe

American Petroleum Institute (API) www.a

U.S. National Response Team www.nrt

EPA Office of Emergency Management www.epa.gov/emergencies/index

Call 811 Before You Dig www.call811.co

Documents and References

API Standard 570−Piping Inspection

Inspection, Repair, Alternation, and Rerating

In−service Piping Syst

https://www.api.org/products-and-services/

standards

API Recommended Practice 1162, 

Awareness Programs for Pipeline Operat

https://www.api.org/products-and-services/

standards

PHMSAAdvisory Bulletin ADB−

Submission of Public Awareness Program 

Revie

https://www.gpo.gov/fdsys/pkg/FR-2006-

06-16/html/E6-9400.htm

Compendium of State Pipeline Saf

Requirements and Initiatives Providi

Increased Public Safety Levels Compared

Code of Federal Regulation

https://psc.mo.gov/CMSInternetData/

NaturalGas/Publications/CompendiumNAPSR-Second-Edition-CLEAN-gl-100313.

pdf

For More Information
5-12 Chapter 5 Piping and Pipelin

5.8 Action Items

Item Date 

Started

Date 

Completed N/A Comment(s)

Engineer and construct

your piping systems in 

accordance with recognized 

national standards, including 

cathodic protection systems, 

and pipe supports.



Use certified installers to 

install or modify piping

systems. 

Maintain adequate

emergency response

equipment, including spill 

response and fire control 

measures.



Periodically pressure test 

your piping for integrity to 

prevent accidental failures. 

Prepare your SPC

contingency and response

plans to prevent releases,

and establish a plan of action 

in the event of a piping 

failure.



Train your staff in piping spill 

response.



Routinely inspect your piping 

for actual or potential 

product releases.



Properly manage piping 

wastes (including spill 

cleanup, removed paint), 

especially if hazardous waste.



Notify and report to 

regulatory agencies in 

the event that a release is 

detected.



Maintain records of training, 

inspections, testing, pipe 

repairs, and self- inspections 

to prove compliance.



Action Items