spill prevention control and countermeasure plan€¦ · countermeasure plan . ohio army national...

SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN

Ohio Army National Guard Field Maintenance Shop #11

3000 Symmes Road Hamilton, Ohio 45015

Prepared for:

Ohio Army National Guard 2825 Dublin-Granville Road

Columbus, Ohio 43235

Prepared by:

Tetra Tech, Inc. 250 West Court Street, 200W

Cincinnati, Ohio 45202

Tetra Tech Project No. 103S429001

September 2016

Reviewed Sept. 2017Reviewed June 2018

Reviewed January 2019

Hamilton - FMS #11 Ohio Army National Guard Spill Prevention, Control & Countermeasure Plan September 2016

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TABLE OF CONTENTS

TABLE OF CONTENTS ............................................................................................................... i

ACRONYM LIST ........................................................................................................................ iii

ENGINEER’S CERTIFICATION ................................................................................................. iv

MANAGEMENT APPROVAL ...................................................................................................... v

REVISION TRACKING FORM ................................................................................................... vi

1.0 INTRODUCTION ............................................................................................................ 1

2.0 FACILITY DESCRIPTION .............................................................................................. 2

2.1 General Information ............................................................................................ 2

2.2 Containers Not Covered by this SPCC Plan ........................................................ 3

2.3 Navigable Waters ................................................................................................ 3

3.0 APPLICABILITY DETERMINATION ............................................................................... 4

4.0 GENERAL PLAN REQUIREMENTS .............................................................................. 5

4.1 SPCC Plan Review and Submittal ...................................................................... 5

4.2 Conformance with Federal and Ohio Regulations ............................................... 5

4.3 Personnel Training .............................................................................................. 5

4.4 Security ............................................................................................................... 6

4.5 Recordkeeping .................................................................................................... 6

4.6 Spill/Release History ........................................................................................... 6

4.7 Spill Response .................................................................................................... 7

4.8 Inspection and Testing ........................................................................................ 8

4.9 Mobile and Portable Container Policy ................................................................. 9

4.10 Undiked Areas ...................................................................................................10

4.11 New Construction ...............................................................................................11

4.12 General Product Handling ..................................................................................11

5.0 CONTAINER AREAS ....................................................................................................12

5.1 Used Oil AST .....................................................................................................12

5.1.1 Spill Description ......................................................................................12

5.1.2 Release Containment and Control ..........................................................12

5.2 Diesel Fuel AST .................................................................................................13



5.3 POL Room and FMS Shop ................................................................................13


5.3.2 Release Containment and Control .........................................................14

5.4 Electrical Transformers ......................................................................................14



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6.0 CORRECTIVE ACTIONS ..............................................................................................16

LIST OF TABLES Table 1 - 40 CFR 112 Cross Walk............................................................................................. vii Table 2 - Spill Response and Reporting Procedures ................................................................... 8 Table 3 - Spill Reporting Agencies .............................................................................................. 8 Table 4 - AST & Piping Inspection and Testing ........................................................................... 9 Table 5 - Mobile and Portable Container Inspections and Testing ............................................. 10

LIST OF FIGURES Figure 1 - Site Location Figure 2 - Site Layout Figure 3 - SPCC Site Features

LIST OF APPENDICES

Appendix A - Selected Site Photographs Appendix B - SPCC Regulated Containers Appendix C - Certification of the Applicability of the Substantial Harm Criteria Appendix D - Discharge Report to USEPA Regional Administrator Appendix E - Emergency Spill Response Procedures Appendix F - Spill Incident Report Form Appendix G - Inspection Checklists


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ACRONYM LIST

Acronym Definition

AGOH Adjutant General of Ohio

AO Area of Operation

API American Petroleum Institute

AR Army Regulations

AST Aboveground Storage Tank

CFR Code of Federal Regulations

DAPAM Department of the Army Pamphlet

DOT Department of Transportation

FMS Field Maintenance Shop

FRP Facility Response Plan

GAA Grease, Automotive & Artillery

HAZWOPER Hazardous Waste Cleanup Operations

JOC Joint Operations Center

kVa Kilovolt-ampere

NCO Non-Commissioned Officer

NRC National Response Center

OAC Ohio Administrative Code

Ohio EPA Ohio Environmental Protection Agency

OHARNG Ohio Army National Guard

OSC On-Scene Coordinator

OSCP Oil Spill Contingency Plan

OSHA Occupational Safety and Health Administration

OWS Oil/Water Separator

PCB Polychlorinated Biphenyl

PE Professional Engineer

POL Petroleum, Oil and Lubricant

RCRA Resource, Conservation, and Recovery Act

RQ Regulated Quantity

SPCC(P) Spill Prevention, Control and Countermeasure (Plan)

STI Steel Tank Institute

USEPA Unites States Environmental Protection Agency

UST Underground Storage Tank


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Table 1 - 40 CFR 112 Cross Walk (Not all CFR 112 References are listed in this Table)

Final SPCC Rule Rule Requirement Equivalent Section

§ 112.3(d) PE certification Engineer’s Certification

§ 112.3(e)(1,2) Facility maintains copy of plan 1.0

§ 112.3(f) Extension of time 6.0

§ 112.4 Submittal requirements to the USEPA Regional Administrator

4.1

§ 112.5(a) Updating requirements 4.1

§ 112.5(b) SPCC Plan reviewed at least once every five years 4.1

§ 112.7 Cross-reference table to the parts of the regulation Table 1 – 40 CFR 112

Cross Walk

§ 112.7 Facility management approval Management Approval

§ 112.7(a)(1,2) Conformance with the regulations, details on equivalent environmental protection

4.2, 4.8, 4.9

§ 112.7(a)(3)(i) Plot plan showing the location and contents of each container, exempted USTs, piping, and transfer station

Figure 3

§ 112.7(a)(3)(ii) Discharge prevention and product handling 4.12, 5.x.2*

§ 112.7(a)(3)(iii) Discharge controls and secondary containment 4.7, 5.x.3*

§ 112.7(a)(3)(iv-vi) Discharge countermeasures, disposal, and notification 4.7

§ 112.7(a)(4) Provide information to enable reporter to describe location and type of spill

Appendix F

§ 112.7(b) Prediction of potential discharge (direction, rate of flow, amount)

Figure 3, 5.x.5*

§ 112.7(c) Secondary containment 5.x.3*

§ 112.7(d) Contingency planning 4.7, 5.x.2*

§ 112.7(e) Inspections, tests, and records 4.5, 4.8, 4.9,

§ 112.7(f)(1) Personnel training program requirements 4.3

§ 112.7(f)(2) Accountability for discharge prevention 1.0

§ 112.7(g) Security 4.4

§ 112.7(h) Loading/unloading 5.x.2*

§ 112.7(i) Brittle fracture evaluation requirements N/A

§ 112.7(j) Conformance with State requirements N/A

§ 112.7(k) Qualified oil-filled operational equipment 5.x.2*

§ 112.8(b) Facility drainage 2.3, Figure 3

§ 112.8(c)(1) Compatible bulk storage containers 2.1

§ 112.8(c)(2) Bulk storage containers secondary containment 2.1, 5.x*

§ 112.8(c)(3) Requirements for drainage of diked areas 4.10

§ 112.8(c)(4) Cathodic protection for buried tanks N/A

§ 112.8(c)(5) Cathodic protection for partially buried tanks N/A

§ 112.8(c)(6) Inspections and integrity testing for aboveground containers

4.8, 4.9

§ 112.8(c)(7) Monitor internal heating coils N/A

§ 112.8(c)(8) High level alarm requirements 5.x.2*

§ 112.8(c)(9) Observe effluent treatment facilities N/A

§ 112.8(c)(10) Correct visible discharges 4.7

§ 112.8(c)(11) Locate mobile containers in secondary containment 4.9

§ 112.8(d) Facility transfer operations, pumping, and facility process

4.12

§ 112.20(e) Certification of Substantial Harm Criteria 3.0, Appendix C *Note that “5.x” indicates a subsection in each Container Area described under Section 5 of the SPCC Plan.


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1.0 INTRODUCTION

In May 2016, Tetra Tech Inc. (Tetra Tech) was contracted (Purchase Order: ADJ01-0000006210) by the Ohio Army National Guard (OHARNG) to prepare this Spill Prevention Control and Countermeasure (SPCC) Plan for the OHARNG Hamilton Field Maintenance Shop Number 11 located in Hamilton, Ohio (see Figure 1). Tetra Tech conducted a visit to the Hamilton Field Maintenance Shop facility (Hamilton FMS #11 or Site) in July 2016 and subsequently prepared this SPCC Plan on behalf of the OHARNG. The Oil Pollution Prevention regulations, administered under the authority of the United States Environmental Protection Agency (USEPA), require certain facilities to prepare and implement an SPCC Plan to reduce or eliminate oil discharges to navigable waters of the United States. This SPCC Plan has been prepared per the requirements of the Army Regulations (AR) 200-1, Department of the Army Pamphlet (DAPAM) 200-1, and the applicable portions of Title 40, Code of Federal Regulations (CFR), Part 112. The State of Ohio currently does not have specific regulations governing SPCC Plans, therefore, AR 200-1 and 40 CFR regulations shall take precedence at FMS #11. The Site has regulated quantities of petroleum, oil, and lubricants (POL) on Site. These POL are regulated by 40 CFR 112, because the facility meets one of the following requirements:

The aggregate total aboveground petroleum-based material storage capacity is at least 1,320 gallons, or;

The total underground POL storage capacity is at least 42,000 gallons. The total underground POL storage capacity excludes those underground storage tanks (USTs) that are currently subject to 40 CFR Part 280 or Part 281.

The format of this SPCC Plan follows the requirements of 40 CFR 112. This regulation mandates the documentation of the equipment, manpower, procedures and measures taken to control or prevent a petroleum-based material spill from reaching navigable waters of the United States. This SPCC Plan was written based upon information obtained during a Site visit conducted by Tetra Tech personnel in July 2016 as well as information provided by OHARNG. In order for this SPCC Plan to be effective in the event of a spill, it must be reviewed and understood by facility personnel. This SPCC Plan must be kept on Site in a location accessible to all personnel and must be reviewed periodically to allow for proper implementation of SPCC Plan procedures.


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2.0 FACILITY DESCRIPTION

This section of the SPCC Plan will provide general information about the facility, information about containers not covered by this SPCC Plan, and a discussion about navigable waters near the facility.

2.1 General Information The Hamilton FMS #11 is located in Butler County, Hamilton, Ohio, at 39° 20’ 52.26” North latitude; 84° 31’ 05.92” West longitude (see Figure 1). The Hamilton FMS #11 is located on the northeast corner of Symmes and North Gilmore Roads (see Figures 2 and 3). The Site is bordered by Turner Transfer to the north; agricultural land and General Electric to the east; Symmes Road followed by Wright-Bernet, Inc. to the south; and North Gilmore Road followed by M. Bohlke Veneer Corporation to the west (see Figure 2). Selected photographs are included in Appendix A. The function of this installation is to provide organizational and limited direct maintenance support for OHARNG units. The OHARNG property consists of three buildings – an Armory, FMS #11, and a cold storage building (see Figure 3). The Site consists of a three-bay maintenance garage with office spaces, equipment and parts storage, POL materials, and hazardous materials. The building is surrounding by concrete and gravel parking areas, and a concrete wash rack equipped with a canopy is located north of the FMS building. Figures 2 and 3 show the general layout of the Site facility. Parking for the facility is located south of the Armory building. A security fence surrounds all three buildings, locked gates are located along North Gilmore Road and adjacent to the Armory building in the parking lot. The following SPCC-regulated oils are used on Site:

Lubricants and greases;

Diesel fuel;

Mineral oil in transformers;

Hydraulic and gear oils; and

Used oil.

All containers that hold 55 gallons or more of SPCC-regulated oils are considered to be SPCC-regulated containers. Appendix B lists specific information for the SPCC regulated containers at the Site. Regulated containers on Site are designed to be compatible with the materials stored and operate at ambient temperatures and pressures. OHARNG personnel stated that secondary containment structures are sufficiently impervious to the oils they are intended to contain. No containers using internal heating coils were observed or reported to be utilized on Site. Hamilton FMS #11 does not have USTs, tank car(s) or tank truck loading/unloading rack(s), pipelines, or field-constructed tanks. The Site is not a Resource, Conservation, and Recovery Act (RCRA) large quantity generator and therefore does not require a RCRA contingency plan. In addition, there are no reported polychlorinated biphenyl (PCB) oil storage containers or PCB-containing transformers onsite. Drums containing POL materials are stored within a petroleum storage room and used within FMS building. Used motor oil is stored within an aboveground storage tank (AST) on the east side of the FMS #11 building, and a diesel fuel AST is located west of the FMS #11 building.


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2.2 Containers Not Covered by this SPCC Plan Smaller containers (less than 55 gallons) of POL are stored within the FMS building and within the POL room in the northeast corner of the building. These non-regulated containers are not covered under this plan. Containers owned and operated by contractors temporarily working at the Site are not covered by this SPCC Plan. Such containers may include fuel tanker trucks or ASTs temporarily brought onto the Site. Each contractor is responsible for determining SPCC Plan applicability and developing a site-specific SPCC Plan, if necessary. Although not included in the SPCC Plan, related spill response activities may still involve Hamilton FMS #11 personnel.

2.3 Navigable Waters The Site is generally flat with little or no relief. Surface water flow will typically drain toward storm water catch basins located in the gravel areas surrounding the building, toward a drainage swale north and east of the FMS building, or will infiltrate unpaved surfaces. The swale discharges to drainage ditches that run along Symmes Road. A catch basin is located in the center of the concrete wash rack. This wash rack is sloped such that the wash water discharges into the drain. The water from this catch basin discharges into an oil/water separator (OWS) located off the northeast corner of the building. Trench drains are present within the Hamilton FMS #11 building on both the east and west sides, and within the POL room. OHARNG personnel stated that trench drains at the FMS building drain to the OWS, and the OWS drains to the sanitary drainage system.


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3.0 APPLICABILITY DETERMINATION

According to 40 CFR 112.1, Hamilton FMS #11 requires an SPCC Plan. The facility-wide aboveground oil storage capacity totals more than 1,320 gallons and oil discharges could reach navigable waters. AR 200-1, chapter 11, paragraph 11-4b(2) states, “Ensure that the SPCC Plan addresses secondary containment (or lack thereof) at oil and hazardous material storage facilities.” 40 CFR 112.20(e) requires that affected facilities determine their potential to cause substantial harm and file a Facility Response Plan (FRP) with the USEPA Regional Administrator, if necessary. As required by 40 CFR 112.20(e), the Certification of the Applicability of the Substantial Harm Criteria is included in Appendix C of this SPCC Plan. The Hamilton FMS #11 has less than one million gallons of oil storage capacity, does not transfer oil over water to/from vessels, and does not pose a threat of substantial harm to fish and wildlife, a sensitive environment, or a drinking water intake. Therefore, an FRP is not required for the Hamilton FMS #11.


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4.0 GENERAL PLAN REQUIREMENTS

The following section presents general requirements for the Hamilton FMS #11 SPCC Plan.

4.1 SPCC Plan Review and Submittal This SPCC Plan must be reviewed and evaluated at least once every five (5) years. This SPCC Plan must be amended within six (6) months of the review if more effective, field-proven prevention and control technologies that would significantly reduce the likelihood of a discharge are available at the time of the review. If there are any technical amendments to the SPCC Plan, then a Professional Engineer (PE) must recertify it. Technical amendments include physical modifications or changes in facility procedures. If all changes are non-technical (e.g., contact name, phone number, container identification number, etc.), environmental personnel can review the SPCC Plan and sign the revision tracking form on page vi. This SPCC Plan must also be updated whenever there is a change in the facility design, construction, operation, or maintenance that materially affects its discharge potential. These types of changes include, but are not limited to, commissioning or decommissioning containers; replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of piping systems; construction or demolition that might alter secondary containment structures; changes of product or service; or revision of standard operation or maintenance procedures. Movement of containers within an area that does not increase either the likelihood or the potential severity of a discharge would not require an update to the SPCC Plan. Required SPCC Plan amendments must be prepared within six (6) months of the change in operation and implemented as soon as possible, but not later than six (6) months following preparation of the amendment. The revisions page at the beginning of this SPCC Plan must be updated to include all technical and non-technical changes to the SPCC Plan. A report must be submitted to the USEPA Regional Administrator only if the Site has:

Discharged more than 1,000 gallons of oil in a single discharge; or

Discharged more than 42 gallons of oil in each of two discharges, occurring within any twelve (12) month period.

40 CFR 112.4(a) lists the information that must be submitted to the USEPA Regional Administrator no more than sixty (60) days from the date of the discharge that required the submittal. This required information is also presented in Appendix D. The Regional Administrator may also require that the SPCC Plan be submitted for review.

4.2 Conformance with Federal and Ohio Regulations The main purpose of this SPCC Plan is to comply with the requirements of 40 CFR 112. Ohio does not have spill requirements more stringent than the Federal requirements in regards to SPCC Plans. Ohio Administrative Code (OAC) Rule 3750 sets requirements for spill notification and follow-up reporting.

4.3 Personnel Training As required by 40 CFR 112.7(f)(1 and 3), oil handling personnel are trained to prevent discharges. This training and annual spill prevention briefings include a review of this SPCC Plan, applicable


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pollution control laws, spill response procedures, inspection and recordkeeping requirements, and the spill history for Hamilton FMS #11. Personnel also receive specific training in petroleum product handling procedures and equipment maintenance and operation. Hamilton FMS #11 personnel responsible for fuel transfers receive additional training commensurate with their specific job requirements. The additional training MAY include some of the following topics:

Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) (29 CFR 1910.120);

OSHA Hazard Communication Standard (29 CFR 1910.1200);

OSHA Process Safety Standard (29 CFR 1910.119);

RCRA Personnel Training (40 CFR 265.16);

RCRA Waste Handling / Emergency Procedures (40 CFR 262.34(d)); and

Department of Transportation (DOT) Hazardous Materials Training (49 CFR 172, Subpart H).

Records of additional training are maintained by individual units or activities. As part of this training, personnel are instructed in the operation and maintenance of equipment to prevent discharges, discharge procedure protocols, general facility operations, as well as about applicable pollution control laws, rules, and regulations. Training records for all current employees are kept on Site. Documentation of training received by former employees is kept at least three years from the date the employee last worked at the facility. Training records consist of each employees name, signature, and date.

4.4 Security A security fence surrounds the entire OHARNG facility and includes the Armory, Cold storage, and FMS #11 building. Locked entrance gates are present along North Gilmore Road and on the east side of the Armory. Security access is required at all times to enter the armory building. The facility is adequately lighted both inside the building and outside to prevent vandalism and to provide for safe night response in the event of a spill.

4.5 Recordkeeping Site personnel maintain regular inspection and test records in accordance with 40 CFR 112.7(e); these records are maintained for a minimum of three (3) years. General inspection and testing procedures for containers are described in more detail in Sections 4.8 and 4.9. Exceptions to the general procedures are identified in individual container area descriptions in Section 5 of this SPCC Plan.

4.6 Spill/Release History No known spills or releases of petroleum-based products have occurred at the Hamilton FMS #11 for the past five years.


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4.7 Spill Response In accordance with 40 CFR 112.20, the Hamilton FMS #11 facility could not reasonably be expected to cause substantial harm to the environment by discharging POL into or upon the navigable waters of the United States or adjoining shorelines, due primarily to its storage capacity and location. The Site is required to complete the Certification of the Applicability of the Substantial Harm Criteria form that is presented in Appendix C. This form shall be maintained on Site with this SPCC Plan as required by 40 CFR 112.20(e). If a spill occurs, installation personnel follow the response, reporting, and cleanup procedures appropriate to the level of spill. First, determine whether the spill is incidental, or an emergency spill. A spill is considered incidental if it meets the following criteria:

It has no potential of reaching water;

It does not leave the property;

It is less than 25 gallons (considered the Reportable Quantity (RQ));

It does not pose a safety or health hazard;

It does not pose a long term environmental hazard; and

It can be controlled at the time of release with available response materials on Site. A spill is considered an emergency if it meets any of the following criteria:

The spill has reached State waters;

The spill poses a safety or health hazard;

The spill is greater than 25 gallons; or

The spill has traveled off OHARNG property. The emergency spill response procedures are outlined in Appendix E. Personnel will promptly correct and cleanup (using available absorbents or spill kits) any visible POL discharges 24 gallons or less which are still on an impervious surface. All POL spills of any size that contact the ground or surface water or any size spills of a hazardous material (even on impervious surfaces) are reported immediately to the environmental office. Tables 2 & 3 indicates the response and reporting procedures for various spills and Reporting Agencies phone numbers. Response to spills should be protective of human life and health, property, and the environment. Personnel discovering a spill should report it immediately and respond in accordance with their abilities, training, and equipment available. If response can be done safely, then effort should be made to stop the spread of the spill, particularly protecting drains and flowing water. Stopping the source of the spill and eliminating any possible sources of ignition are also vital. The Fire Department is the primary spill responder and can be reached at 911. Information on cleanup contractors, if necessary, is maintained by the environmental office. Emergency spill reporting includes notifying the Joint Operations Center (JOC) and the OHARNG Environmental Office. The JOC is responsible for all reporting to external agencies, including Ohio


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EPA. Per OAC Rule 3750, the JOC will notify Ohio EPA within 30 minutes of spill discovery to navigable waters or 25 gallons to ground.

Table 2 - Spill Response and Reporting Procedures

Spill Volume Response Reporting

Hazardous Material Less than RQ

Environmental Office OHARNG Environmental

Hazardous Material Greater than RQ

Fire Department JOC (who will notify Ohio EPA), OHARNG Environmental

Any amount of POL that reaches a navigable water

Fire Department JOC (who will notify Ohio EPA and the NRC), OHARNG Environmental

25 gallons or more of POL in a single event

Fire Department JOC (who will notify Ohio EPA), OHARNG Environmental

Table 3 - Spill Reporting Agencies

Agency Phone

JOC 1-888-637-9053 or 614-336-7551

City of Hamilton Fire Department 911

OHARNG Environmental Office 614-336-7079

Environmental Program Manager 614-336-7095

Ohio EPA 1-800-282-9378*

NRC 1-800-424-8802*

*These numbers are for the Environmental Office, and should only be utilized if neither the JOC nor anyone in the Environmental Office can be reached.

The Spill Incident Report Form, included in Appendix F, should be completed within 24 hours after a spill and sent to the Environmental Office. Spill response equipment (absorbents, barriers, and personal protective equipment) is maintained throughout the Site, specifically in the Armory, POL room, within the FMS building (two kits), and adjacent to the diesel AST. The City of Hamilton Fire Department will respond to spills, but will concentrate on containment. Cleanup will start after the Fire Department determines that public safety has been protected. Spill cleanup will be completed by onsite personnel on a small scale and OHARNG Environmental with aid from contractors on a larger scale. Recovered oils are managed through existing disposal contracts as used oil, or hazardous waste if contaminated.

4.8 Inspection and Testing Inspection and testing of tanks is required by 40 CFR 112.8(c)(6). The inspection and testing procedures for regulated containers in this SPCC Plan are based on applicable industry standards. Mobile and portable tank (including 55-gallon drum) inspection and testing requirements are described in Section 4.9. Monthly AST inspections include the full length of piping associated with the AST. This is a much greater frequency of piping inspection than required by American Petroleum Institute (API) Piping Inspection Code 570 (every 5 years or as determined by risk based analysis). In addition, if underground piping becomes exposed during excavation, construction, or demolition, a visual inspection for corrosion is required. If corrosion is found, then immediate corrective measures are


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undertaken (such as protective wrapping and coating or pipe replacement) and further excavation is completed to more fully examine the piping. 40 CFR 112.8(c)(8)(v) also requires verification of liquid level sensors on all bulk storage containers, which are tested monthly. Table 4 shows the documented inspections and the corresponding Steel Tank Institute (STI) standard required of all bulk storage tanks and piping. Inspection checklists are in Appendix G. Section 4.5 describes recordkeeping procedures.

Table 4 - AST and Piping Inspection and Testing

Inspection/Test Standard Method Frequency

Presence of water in primary tank STI SP001-05,

Appendix C Visual Monthly

Presence of water, oil, or debris in secondary containment

STI SP001-05, Appendix C

Manual Monthly

Operation of leak detection system STI SP001-05,

Appendix C Manual Monthly

Piping connections and openings properly sealed STI SP001-05,


Drain valves operable and in closed position STI SP001-05,


Operation of liquid level sensor STI SP001-05,

Appendix C Manual Monthly

Visible signs of leakage, corrosion, or damage STI SP001-05, App C and API

570, App D Visual Monthly

Exterior and coating deterioration/corrosion/distortion


Visual Yearly

Operation and cleanliness of operating and emergency vents


Visual Yearly

Emergency vent gasket STI SP001-05,

Appendix C Visual Yearly

Property drainage around tank STI SP001-05,


Tank supports, pad, and foundation damage STI SP001-05,


Tank grounding and electrical wiring STI SP001-05,


Operation of overfill protection devices STI SP001-05,


Certified STI Inspection (Not required of double-walled tanks – 5,000 gallons or less)


Enhanced visual and

records review

20 years

4.9 Mobile and Portable Container Policy Hamilton FMS #11 is implementing this policy to manage oils and fuels stored in drums, portable containers, and mobile containers with an oil storage capacity between 55 gallons and 2,000 gallons. Portable containers are typically mounted on skids or saddles and may remain in place for an extended period of time; 55-gallon drums are also considered portable containers. Mobile containers are mounted to frames with wheels. Examples of mobile containers include fuel pods,


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mobile generator fuel tanks, and tanker trucks. Personnel frequently move these containers or alter the number of containers in a particular area. For this reason, the exact location of each drum, portable container, or mobile container is not included in this SPCC Plan. However, the areas that are commonly used for storage of drums or other mobile and portable containers (and the maximum allowable volume of POL products stored in those areas) are identified in this SPCC Plan. All containers covered by this Mobile and Portable Container Policy must have the means available to prevent discharges to navigable waters. This may include spill kits or spill pallets, diked storage areas, and/or storing containers inside a building. Inspection and testing of all bulk storage tanks is required by 40 CFR 112.8(c)(6). The inspection and testing procedures for regulated containers in this SPCC Plan are based on consideration of applicable industry standards. Mobile and portable tank (including 55-gallon drum) inspection and testing requirements are contained in STI Standard SP001-05 (July 2006 revision). This standard requires periodic inspections by owners and recertification to DOT standards at varying intervals, depending on the material of construction and secondary containment used. Inspection checklists are in Appendix G.

Table 5 - Mobile and Portable Container Inspections and Testing

Inspection/Test Standard Method Frequency

Presence of water, oil, or debris in interstice or secondary containment


Manual Monthly

Visible signs of leakage or corrosion/distortion


Visual Monthly

Drain valves operable and in closed position


Visual Monthly

DOT recertification and leak testing (required only if no secondary

containment is used)

49 CFR 173.28 49 CFR 178.803 49 CFR 180.605

Hydrostatic Test, Mass

Measurement, Level

Measurement, Pressure

Decay, etc.

Plastic – Every 7 Years

Steel –

Every 12 Years

Stainless Steel –

Every 17 Years

Records of external inspections are maintained for at least three years. Records of integrity tests shall be maintained for the life of the container. The Hamilton FMS #11 does not intend to keep drums beyond the DOT recertification test period. Personnel will track the containers age if a drum is to be used for more than the DOT recertification test period (see Table 4).

4.10 Undiked Areas The SPCC regulations in 40 CFR 112.8(b) require facilities to prevent potential discharges from undiked areas by designing drainage systems that flow into catchment basins or lagoons. A storm water catch basin was observed south of the FMS #11 building and OHARNG personnel stated that it is connected to the local municipal storm sewer system.


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4.11 New Construction

Any new construction will comply with the applicable requirements of 40 CFR 112.8(d). New buried metallic piping will either have a protective coating or cathodic protection. In the event that piping is exposed during an excavation, the pipe will be inspected for corrosion and repaired or replaced as necessary.

4.12 General Product Handling Installation personnel follow standard operating procedures for product handling as listed in applicable military standards. In general, personnel follow the spill prevention procedures below when transferring product to or from a tanker truck:

Load or unload in approved locations only;

At least two people will be in the immediate area of the refueler and tank fill port;

Establish communications between the pumping and receiving stations;

Verify the available volume of the receiving container;

Properly close all drainage valves for any secondary containment;

Allow sufficient headspace volume (approximately 10% of the total capacity) in the receiving container for thermal expansion; and

Visually inspect all valves for leakage when transfer is complete.


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5.0 CONTAINER AREAS

This section of the SPCC Plan provides details about SPCC-regulated containers in each area. An area typically encompasses all the containers owned and maintained by a single shop or functional unit. Transformers have been grouped as an “area” because of their common contents and procedures. All SPCC-regulated containers, regardless of container area, are in the consolidated table in Appendix B. Four areas of potential POL release at Hamilton FMS #11 have been identified (see photographs in Appendix A and Figure 3):

Used oil AST;

Diesel fuel AST;

POL room and FMS shop; and

Electrical transformers.

The term “visual” is used in Section 5 to describe a method of overfill prevention wherein the person filling a container can see the level of product in the container while it is being filled and can immediately shut off inflow upon reaching 90% of container capacity [(40 CFR 112.8(8)(iii-iv)]. Four spill kits are located throughout the FMS #11 building and unpaved gravel areas (see Figure 3). The locations are as follows: adjacent to the diesel fuel AST, within the POL room, and two locations within the FMS #11 building. In addition, two spill kits are located in the southwest corner of the Armory.

5.1 Used Oil AST The used oil AST is located on the east side of the FMS building (see Figure 3) and stores up to a maximum capacity of 500 gallons of used oil. The AST is a ConVault double-walled, concrete reinforced tank and is filled through a used oil collection sink and used oil filter crushing unit located within the FMS shop. The oil is transferred to the AST via a pneumatic pump. The AST is emptied on an as-needed basis.

5.1.1 Spill Description Several opportunities exist for a spill or release to occur from the AST. The most common release can occur during the emptying of the tank. Other potential spills include tank rupture, dislodging or breaking of the delivery fittings, valve failure, deliberate discharge, leakage or rupture of the receiving tank truck, or premature departure of the receiving vehicle. Tank failure would likely be contained via the double-walled construction of the AST. Should a spill or release occur, material would likely pool on the concrete below or infiltrate into the unpaved gravel surfaces. If not attended to, a spill could reach storm water catch basins located east of the FMS building (see Figure 3).

5.1.2 Release Containment and Control The primary spill containment and control equipment available for use near the AST are stored in a spill kit located within the FMS #11 building (see Figure 3). This equipment consists of absorbent spill pads and booms. The pads and booms are absorbent and containment materials specifically


13

manufactured for use in oil-based spills. Additionally, the disposal contractor is equipped with spill containment and response materials, and drip pans are utilized during emptying operations. Fire extinguishers are located throughout the Hamilton FMS #11 facility. Tank emptying operations are directly monitored by personnel on duty. In addition, facility personnel conduct monthly inspections to verify the integrity and oil level of the tank. Spill materials such as absorbent pads and booms can be used to absorb product which has or is currently being released from the AST. Nearby surface soil and gravel can also be used as an absorbent material to prevent the spread of spilled petroleum. Spent absorbent materials including soil and gravel should be properly contained and disposed of once the immediate spill response actions are addressed.

5.2 Diesel Fuel AST The diesel fuel AST is located west of the FMS building (see Figure 3) and stores up to 2,500 gallons of diesel fuel. The AST is a double-walled tank and is filled by a mobile contractor. The fuel is utilized to fuel mobile equipment at the Hamilton FMS #11 and armory buildings. The AST is filled on an as-needed basis, and OHARNG personnel are present during filling and fueling operations.

5.2.1 Spill Description Several opportunities exist for a spill or release to occur from the AST. The most common release can occur during the filling of the tank. Other potential spills include tank truck rupture, dislodging or breaking of the delivery fittings, valve failure, deliberate discharge, leakage or rupture of the receiving fuel tank, or premature departure of the dispensing vehicle. Tank failure would likely be contained via the double-walled construction of the AST. Should a spill or release occur, material would likely infiltrate into the unpaved gravel surfaces. If not attended to, a spill could reach storm water catch basins located west of the FMS building (see Figure 3).

5.2.2 Release Containment and Control The primary spill containment and control equipment available for use near the AST are stored in a spill kit adjacent to the AST (see Figure 3). This equipment consists of absorbent spill pads and booms. The pads and booms are absorbent and containment materials specifically manufactured for use in oil-based spills. Additionally, the refueling contractor is equipped with spill containment and response materials, and drip pans are utilized during refueling operations. Fire extinguishers are located throughout the Hamilton FMS #11 facility. Refueling operations are directly monitored by personnel on duty. Spill materials such as absorbent pads and booms can be used to absorb product which has or is currently being released from the AST. Nearby surface soil and gravel can also be used as an absorbent material to prevent the spread of spilled petroleum. Spent absorbent materials including soil and gravel should be properly contained and disposed of once the immediate spill response actions are addressed.

5.3 POL Room and FMS Shop The POL room is located off the northeast corner of the FMS #11 building (see Figure 3) and contains 55-gallon drums of POL as well as smaller containers of fuel, grease, oils, and paints. Smaller containers are stored within a flammable materials storage cabinet or on shelving. OHARNG personnel stated that the POL room has a trench drain at the door that can be plugged.


14

The drain discharges to the OWS. The FMS shop contains flammable materials cabinets with small containers (less than five gallons) of paints, solvents, and POL materials. OHARNG personnel stated that trench drains are present on either side of the FMS shop and the drains discharge to the OWS.

5.3.1 Spill Description Spilled material within the POL room would be contained by the trench drain. If the drain was not plugged at the time of a release, the spilled product would discharge to the OWS. Spilled material within the flammable materials cabinets in the POL room or within the FMS shop would be contained within the cabinets. Larger spills in the FMS shop could reach the trench drains that discharge to the OWS. A spill within the POL room or FMS shop could occur from a rupture of a container, a faulty container, or by accidental spillage.

5.3.2 Release Containment and Control The primary spill containment and control equipment available for use is stored within the POL room and the FMS shop. This equipment consists of absorbent spill pads and booms. The pads and booms are absorbent and containment materials specifically manufactured for use in oil-based spills. Drip pans are utilized during maintenance activities involving fluids. In addition, fire extinguishers are located in the FMS #11 building. Spill materials such as absorbent pads and booms can be used to absorb product which has or is currently being released from the containers. Spent absorbent materials should be properly contained and disposed of once the immediate spill response actions are addressed.

5.4 Electrical Transformers Electrical and hydraulic operating equipment is specifically excluded from the definition of bulk storage containers in 40 CFR 112.2, meaning that requirements for secondary containment and testing do not apply. However, a requirement for appropriate containment and diversionary structures to prevent a spill from reaching navigable waters (40 CFR 112.7(c)) still applies. Amendments to 40 CFR 112 (December 2008) exempt “oil-filled operational equipment” such as transformers and hydraulics from secondary containment requirements if inspections procedures are documented and a spill contingency plan, with a commitment to control any spills, is prepared. Two pad-mounted electrical transformers are present on the Site: one adjacent to the northwest corner of the FMS #11 building and one off the southwestern corner of the cold storage building (see Figure 3). Limited information was available on the transformers; however, labeling indicated that they have an electrical capacity of 1,882 kilovolt-amperes (kVa). No labeling as to the polychlorinated biphenyl (PCB) content was observed; however, OHARNG Environmental Office personnel indicated that the onsite transformers are non-PCB. Based on the electrical capacity of the transformer, it likely contains approximately 350-650 gallons of oil. All oil contained within the transformer is considered exempt, by definition, only from secondary containment requirements. However, this exemption is only allowed as long as oil-containing electrical equipment are inspected and included in this SPCC Plan.

5.4.1 Spill Description A spill or release from the electrical transformer at the Site could occur from a leak or spill during maintenance activities. Alternatively, a release of transformer fluid could occur from a rupture of


15

a transformer due to damage from lack of maintenance, damage during storm activity, or damage resultant of an electrical short or other problem. Should a release occur from the transformer, released material would infiltrate the unpaved gravel surfaces.

5.4.2 Release Containment and Control The primary spill containment equipment available for use is stored either within the FMS #11 building or adjacent to the diesel fuel AST (see Figure 3). This equipment consists of absorbent pads and booms within spill kits. Fire extinguishers are located within throughout the facility building. Spent absorbent materials from spill cleanup should be properly contained and disposed of once the immediate spill response actions are addressed.


16

6.0 CORRECTIVE ACTIONS

Facilities that are unable to implement their Corrective Actions within six (6) months of certification must submit a written extension request to the USEPA Regional Administrator in accordance with the requirements of 40 CFR 112.3(f). No corrective actions are required by this SPCC Plan.


Figures

®0 2,0001,000

Feet

FIGURE 1SITE LOCATION

SITELOCATION

Approximate Site Boundary

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FMS #113000 SYMMES ROAD

HAMILTON, OHIO

SOURCE: MODIFIED FROM USGS, GREENHILLS, OH 1981& GLENDALE, OH 1987 QUADRANGLES.

®0 15075

Feet

FIGURE 2SITE LAYOUT


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HAMILTON, OHIO

GeneralElectric

Wright-Bernet Inc

M BohlkeVeneer Corp

TurnerTransfer

Symmes Rd

N Gi

lmore

Rd

®0 10050

Feet

FIGURE 3SPCC SITE FEATURES


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HAMILTON, OHIO")H Hazmat Storage Shed!(U Used Oil AST

!@ Storm Drain

!(D Diesel AST")T Pad-Mounted Transformer

Trench Drains

Armory

ColdStorage

")H

!(U

!@

!(D

")T

")H

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!@

!@

WashRack

")K Spill Kit

!(O Oil\Water Separator

Surface WaterFlow Direction

!(O")K

")K

")K

")K

")T POLRoom

FMS #11

Fence

Gate

Gate

Swale

")K")K


Appendix A

Selected Photographs

Hamilton - FMS #11 Ohio Army National GuardSpill Prevention, Control & Countermeasure Plan September 2016

Diesel AST: 2,500-gallon diesel AST and associated spill kit. The cold storage building isvisible behind the AST.

Oil/Water Separator: Oil/Water separator located off the northeast corner of the FMS building.


Transformer: Pad-mounted transformer located on the north side of the FMS building. Thecold storage building is visible in the background.

Transformer: Pad-mounted transformer located on the south side of the cold storage building.


Used Oil AST: 500-gallon AST located on the east side of the FMS building, which is visible inthe background.

Wash Rack: On-site wash rack and trench drain, which reportedly discharges to the oil/waterseparator.


Spill Kit: Spill kit located within the FMS #11 building.

FMS #11: Contents of a flammable materials cabinet located with the FMS #11 building.


POL Room: Shelving and trench drain within the POL room.

Spill Kit: Spill kit located next to the door of the POL room.


POL Room: 55-gallon drums within the POL room.


Appendix B

SPCC Regulated Containers


Table B-1 SPCC Regulated Containers

Container ID/Location

Capacity (Gallons)

Material of Construction

Product Stored Secondary

Containment Type

Used Oil AST 500 Steel Used oil Double-walled

Diesel Fuel AST 2,500 Steel Diesel Double-walled

POL Room/FMS Shop Steel Plastic

Antifreeze* Lube Oil Gear Oil

Hydraulic Fluid Brake Cleaner

Cleaner/Degreaser* GAA

Self-contained room, spill

cabinets, OWS intercepted drains

Electrical Transformers

FMS #11 350-650 Steel Mineral Oil Single-walled

Cold Storage 350-650 Steel Mineral Oil Single-walled

*Does not contain oil, not regulated by 40 CFR 112


Appendix C

Certification of the Applicability of the Substantial Harm Criteria (As per 40 CFR 112.20(f) Appendix D)


Appendix D

Discharge Report to USEPA Regional Administrator


Discharge Report to USEPA Regional Administrator

Facility name and location: Field Maintenance Shop #11, Hamilton, Ohio 45015

Name(s) of the owner or operator of facility:

Ohio Army National Guard

Date and year of initial facility operation:

Maximum storage or handling capacity of the facility & normal daily throughput:

Estimated amount of spill and type of oil:

Cause(s) of spill, including a failure analysis of system or subsystem in which the failure occurred:

Corrective actions and/or countermeasures taken, including an adequate description of equipment repairs and/or replacements:

Additional preventive measures taken or contemplated to minimize the possibility of recurrence:

Provide the following:

Task Completed Comments

□

Description of facility, including maps, flow diagrams, and topographical maps.

□

The names of individuals and/or organizations also contacted and the date and time contacted.


Appendix E

Emergency Spill Response Procedures


1. EMERGENCY SPILL RESPONSE PROCEDURES.

a. Report the spill to the On-Scene Coordinator (OSC) immediately (See 3a below). b. Identify the spilled substance and evaluate the hazard. RESIST THE URGE TO RUSH IN! Don't

become an accident statistic or part of the problem. IF IN DOUBT, STAY OUT! c. Secure the scene. Set up an adequate perimeter to assure the safety of bystanders and limit

access to essential personnel. d. If possible, without exposure of personnel to hazard, contain the spill using whatever means

available. e. Always enter the spill area from upwind, uphill or upstream. f. Prevent spills from flowing into drainage ditches, storm and sewer drains, and bodies of water

using the absorbents on hand, earthen dams or sandbags. g. Keep ignition sources (matches, lighters, equipment) as far from the spill as possible. Do not

allow anyone to smoke at the scene of the incident. If possible use non-sparking (brass or plastic) tools when working to contain the spill on site.

h. Refer to the Spill Prevention Control and Countermeasure Plan (SPCC Plan) if required (See 3b (10) below).

2. REPORTING SPILLS/EMERGENCY PHONE NUMBERS.

a. Report all spills to the Ohio National Guard Joint Operations Center using the toll free number (1-888-637-9053).

b. Always email a Spill Incident Report Form (AGOH Form 200-1-7-R) to the Environmental Office within 24hrs, regardless of the spill amount.

c. If the spill is a threat to human health or safety notify the Ohio State Highway Patrol (By District) and/or the local Fire Department immediately

3. PREPLANNING.

a. Designate an OSC. The OSC must be an Officer or a Non-Commissioned Officer (NCO). Convoy and refueling operations require an OSC.

b. OSC Responsibilities: (1) Inventory all POL products and hazardous materials before each training event. (2) Keep a Material Safety Data Sheet on hand for each POL product and hazardous material. (3) Know where all POL products and hazardous materials are stored at all times. (4) Ensure emergency spill response kits are readily available. Ensure non-sparking shovels and

other tools are available to contain spills if possible. These materials should be placed in a vehicle not carrying hazardous materials or POL.

(5) Know where all emergency spill response kits are stationed at all times. (6) Ensure secondary containment is properly deployed during fueling operations. (7) Ensure hazards associated with storage and transportation of POL and other hazardous

materials are incorporated into Composite Risk Management analysis. (8) Ensure all spills are reported to the Environmental Office within 24 hours. (9) Ensure every fueling asset has an Oil Spill Contingency Plan (OSCP) in the cab or equipment

record folder. (10) Determine if there is a Spill Prevention Control and Countermeasure Plan (SPCC Plan) for

the facility or installation where training is being conducted. If there is, obtain a copy and review it prior to the training event. Not all locations have an SPCC Plan. In the absence of an SPCC Plan, this card takes precedence.

(11) Know the phone numbers of emergency responders in your area of operation (AO). SPECIAL INSTRUCTIONS: Post one copy of this document in the convoy commander’s vehicle, at all refueling points, inside all emergency spill response kits, and in all vehicles transporting POL or hazardous materials. AGOH Form 200-1-6-R (20 March 07) (Supersedes AGOH Form 200-1-6-R dated 1 March 92)


Appendix F

Spill Incident Report Form


SPILL INCIDENT REPORT FORM Hamilton FMS #11 – 3000 Symmes Road, Hamilton OH 45015 ● (513) 874-0539

Unit:______________________________ State:______ Report Date & Time:_______________

On-Scene Coordinator (OSC Name & Grade): ______________________ Phone:____________

Spill Location (Grid or Common Name):_____________________________________________

What was Spilled (Mogas, Diesel, JPS, Other)?_______________________________________

If Other, Please Specify:_________________________________________________________

How Much was Spilled (Gallons)?__________________________________________________

When Did the Spill Occur (Date & Time)?____________________________________________

How did the Spill Occur?_________________________________________________________

____________________________________________________________________________

____________________________________________________________________________

What Remedial Action was Taken?________________________________________________

____________________________________________________________________________

____________________________________________________________________________

Were there any Injuries (Cause & Number)?__________________________________________

How Much Soil was Removed (Yards, Barrels, Trash Bags, etc.)?_________________________

Where was the Soil Stockpiled (Grid or Common Name)?_______________________________

Was the Site Cleared by the Environmental Office (Yes or No, Date & Time)?________________

Who Cleared the Site?__________________________________________________________

Fill out and fax or mail this form to the Environmental Office within 24 hour of incident occurrence.

- - - - - - - - - - - - - - - - - - - - - For Environmental Office Use Only - - - - - - - - - - - - - - - - - - - - -

Final Disposition:______________________________________________________________

____________________________________________________________________________

____________________________________________________________________________

____________________________________________________________________________

____________________________________________________________________________


Appendix G

Inspection Checklists


Used Oil AST SPCC Monthly Inspection Sheet

DATE

X = Okay or fixed

C = Needs to be corrected

NA = Not applicable

January

__

___

___

Febru

ary

__

___

__

Marc

h__

___

___

_

Apri

l__

___

__

___

_

May___

__

___

___

June__

___

__

___

July

___

___

___

__

Aug

ust_

____

___

_

Septe

mber_

____

_

Octo

ber_

__

__

___

Novem

ber_

__

__

_

Decem

ber_

__

__

_

INSPECTOR’S INITIALS

No water in primary tank

No water, oil, or debris in secondary containment

Leak detection system ok

Drain valves operable and closed

Liquid level sensor working

Spill kit available

Fire extinguisher near

Exterior and coating


Emergency vent gasket

Property drainage around tank

Tank supports, pad, and foundation damage

Tank grounding and electrical wiring

Operation of overfill protection devices


Diesel Fuel AST SPCC Monthly Inspection Sheet

DATE

X = Okay or fixed


NA = Not applicable

January

__

___

___

Febru

ary

__

___

__

Marc

h__

___

___

_

Apri

l__

___

__

___

_

May___

__

___

___

June__

___

__

___

July

___

___

___

__

Aug

ust_

____

___

_

Septe

mber_

____

_

Octo

ber_

__

__

___

Novem

ber_

__

__

_

Decem

ber_

__

__

_


No water in primary tank

No water, oil, or debris in secondary containment

Leak detection system ok

Drain valves operable and closed

Liquid level sensor working

Spill kit available


Exterior and coating


Emergency vent gasket

Property drainage around tank

Tank supports, pad, and foundation damage

Tank grounding and electrical wiring

Operation of overfill protection devices


Portable Containers SPCC Monthly Inspection Sheet

DATE

X = Okay or fixed


NA = Not applicable

January

__

___

___

Febru

ary

__

___

__

Marc

h__

___

___

_

Apri

l__

___

__

___

_

May___

__

___

___

June__

___

__

___

July

___

___

___

__

Aug

ust_

____

___

_

Septe

mber_

____

_

Octo

ber_

__

__

___

Novem

ber_

__

__

_

Decem

ber_

__

__

_


FMS #11

Good condition

Containers labeled

No loose lids

No open containers

No leaks

No incompatibles together

Spill kit available


POL Room

Good condition

Containers labeled

No loose lids

No open containers

No leaks


Spill kit available



Transformers SPCC Monthly Inspection Sheet

DATE

X = Okay or fixed


NA = Not applicable

January

__

___

___

Febru

ary

__

___

__

Marc

h__

___

___

_

Apri

l__

___

__

___

_

May___

__

___

___

June__

___

__

___

July

___

___

___

__

Aug

ust_

____

___

_

Septe

mber_

____

_

Octo

ber_

__

__

___

Novem

ber_

__

__

_

Decem

ber_

__

__

_


Electrical Transformer – FMS #11

Good condition

No leaks


Spill kit available


Electrical Transformer – Cold Storage

Good condition

No leaks


Spill kit available


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