FLETC Charleston SPCC Plan 2023.pdf

SPILL PREVENTION, CONTROL, AND

COUNTERMEASURES (SPCC) PLAN

FLETC - Charleston 2000 Bainbridge Avenue

North Charleston, SC 29405

Original Prepared by:

HGS Engineering, Inc.

Anniston, Alabama 36201 May 2018

Five Year Review by:

Herbert S. Clifton P.E.

FLETC Facilities Management Division Engineer May 2023

FLETC - Charleston Spill Prevention, Control, and Countermeasures (SPCC) Plan

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The purpose of this Spill Prevention, Control, and Countermeasures (SPCC) Plan is to describe measures implemented by FLETC - Charleston to prevent oil discharges from occurring. The SPCC describes how FLETC - Charleston responds to a spill in a safe, effective, and timely manner to mitigate the impacts of a discharge. This Plan has been prepared to meet requirements of Title 40, Code of Federal Regulations, Part 112 (40 CFR Part 112). Under Federal Regulations, a Plan is required for any facility with a total aboveground storage capacity of more than 1,320 gallons (counting only containers of 55 gallons or greater). The applicability is dependent on the tank’s maximum design storage volume, not operational volume.

The implementation of the measures described in this plan is of utmost importance and should be studied by all employees. When properly implemented, this plan will significantly decrease the potential for spills or discharges. In the event of a spill related emergency, this plan can be used as a guideline for proper response.

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Emergency Contacts FLETC Charleston

2000 Bainbridge Avenue

Designated person responsible for spill prevention: Jeff Blankenship

843-368-9985 (cell)

EMERGENCY TELEPHONE NUMBERS:

Jeff Blankenship, Environmental Protection Specialist (843) 566-8511 (Office)

(843) 368-9895 (Cell)

Local Emergency Response

North Charleston Fire Department

(843) 740-2616 or 911

U.S. Coast Guard Sector Charleston (843) 740-7050

Medical 911

FLETC Security (843) 974-6303

Response/Cleanup Contractor

ASRC Federal Services (843) 745-2764

Notification

National Response Center (800) 424-8802

Environmental Protection Agency, Spill/Emergency Response (800) 282-9378

Region 4 EPA (800) 241-1754

SC DHEC Lowcountry Office (843) 953-0150

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TABLE OF CONTENTS

Page

Introduction 1 Part 1: Plan Administration

1.1 Management Approval and Designated Person 3

1.2 Professional Engineer Certification 3

1.3 Location of SPCC Plan 4

1.4 Plan Review 4

1.5 Facilities, Procedures, Methods, or Equipment Not Yet Fully Operational 5

1.6 Cross-Reference with SPCC Provisions 5

Part 2: General Facility Information

2.1 Facility Description 8

2.2 Evaluation of Discharge Potential 9

Part 3: Discharge Prevention – General SPCC Provisions

3.1 Compliance with Applicable Requirements 10

3.2 Facility Layout Diagram 10

3.3 Spill Reporting 10

3.4 Potential Discharge Volumes and Direction of Flow 11

3.5 Containment and Diversionary Structures 11

3.6 Practicability of Secondary Containment 13

3.7 Inspections, Tests, and Records 13

3.8 Personnel, Training, and Discharge Prevention Procedures 16

3.9 Security 16

3.10 Tank Truck Unloading Requirements 16

3.11 Brittle Fracture Evaluation 18

3.12 Conformance with State and Local Applicable Requirements 18 Part 4: Discharge Prevention – SPCC Provisions for Onshore Facilities (Excluding Production Facilities)

4.1 Facility Drainage 19

4.2 Bulk Storage Containers 19

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4.3 Transfer Operations, Pumping, and In-Plant Processes

Part 5: Discharge Response

5.1 Response to a Minor Discharge 22

5.2 Response to a Major Discharge 23

5.3 Waste Disposal 24

5.4 Discharge Notification 24

5.5 Cleanup Contractors and Equipment Suppliers 25

List of Tables

Table 1-1: Plan Review Log 5 Table 1-2: SPCC Cross-Reference 6 Table 2-1: Oil Containers 9 Table 3-1: Potential Discharge Volume and Direction of Flow 11 Table 3-2: Inspection and Testing Program 14 Table 3-3: Fuel Transfer Procedures 18

Appendices

A: Site Plan and Facility Diagram 26 B: Substantial Harm Determination 29 C: Facility Inspection Checklists 30 D: Record of the Annual Discharge Prevention Briefing and Training 33 E: Records of Tank Integrity and Pressure Tests 34 F: Emergency Contacts 35 G: Discharge Notification Form 36 H: Discharge Response Equipment Inventory 38 I: Agency Notification Standard Report 39 J. SPCC Contingency Plan 40

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LIST OF ACRONYMS AND ABBREVIATIONS

AST Aboveground Storage Tank

EPA U.S. Environmental Protection Agency

NPDES National Pollutant Discharge Elimination System

PE Professional Engineer

POTW Publicly Owned Treatment Works

SCDHEC South Carolina Department of Health and Environmental Control

SPCC Spill Prevention, Control, and Countermeasures

STI Steel Tank Institute

UST Underground Storage Tank

FLETC Charleston Spill Prevention, Control, and Countermeasures (SPCC) Plan

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INTRODUCTION

Purpose

The purpose of this Spill Prevention, Control, and Countermeasures (SPCC) Plan is to describe measures implemented by FLETC Charleston to prevent oil discharges from occurring, and to respond in a safe, effective, and timely manner to mitigate the impacts of a discharge.

This Plan has been prepared to meet the requirements of Title 40, Code of Federal

Regulations, Part 112 (40 CFR Part 112).

In addition to fulfilling requirements of 40 CFR Part 112, this SPCC Plan is used as a reference for oil storage information and testing records, as a tool to communicate practices on preventing and responding to discharges with employees, as a guide to facility inspections, and as a resource during emergency response.

It has determined that this facility does not pose a risk of substantial harm under 40 CFR

Part 112, as recorded in the “Substantial Harm Determination” included in Appendix B of this Plan.

This Plan provides guidance on key actions that must be performed to comply with the SPCC rule:

Complete monthly and annual site inspections as outlined in the Inspection, Tests, and Records section of this Plan (Section 3.7) using the inspection checklists included in Appendix C.

Perform preventive maintenance of equipment, secondary containment systems, and/or discharge prevention systems described in this Plan as needed to keep them in proper operating conditions.

Conduct annual employee training as outlined in the Personnel, Training, and

Discharge Prevention Procedures section of this Plan (Section 3.8) and document them on the log included in Appendix D.

If either of the following occurs, submit the SPCC Plan to the EPA Region 4

Regional Administrator (RA) and the South Carolina Department of Health and Environmental Control (DHEC), along with other information as detailed in Section

5.4 of this Plan:

The facility discharges more than 1,000 gallons of oil into or upon the navigable waters of the U.S. or adjoining shorelines in a single spill event;

or

The facility discharges oil in quantity greater than 42 gallons in each of two spill events within any 12-month period.

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Review the SPCC Plan at least once every five (5) years and amend it to include more effective prevention and control technology, if such technology will significantly reduce the likelihood of a spill event and has been proven effective in the field at the time of the review. Plan amendments, other than administrative changes discussed above, must be recertified by a Professional Engineer on the certification page in Section 1.2 of this Plan.

Amend the SPCC Plan within six (6) months whenever where is a change in facility design, construction, operation, or maintenance that materially affects the facility’s spill potential. The revised Plan must be recertified by a Professional Engineer

(PE).

Review the Plan on an annual basis. Update the Plan to reflect any “administrative changes” that are applicable, such as personnel changes or revisions to contact information, such as phone numbers. Administrative changes must be documented in the Plan review log of Section 1.6 of this Plan, but do not have to be certified by a PE.

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Part 1: Plan Administration

1.1 Management Approval and Designated Person (40 CFR 112.7)

FLETC Charleston is committed to preventing discharges of oil to navigable waters and the environment, and to maintaining the highest standards for spill prevention, control, and countermeasures through the implementation and regular review and amendment of the Plan. This SPCC Plan has the full approval of management. The necessary resources have been committed to implement the measures described in this Plan.

The Environmental Protection Specialist is the Designated Person Accountable for Oil Spill Prevention at the facility.

Authorized Facility Representative:

Name: L. Wayne Anderson

Title: Site Director FLETC Charleston

Signature: __________________________

Date: ______________________

1.2 Location of SPCC Plan (40 CFR 112.3(e))

In accordance with 40 CFR 112.3(e), a complete copy of this SPCC Plan is maintained in the Environmental Office.

1.3 Plan Review (40 CFR 112.3 and 112.5)

1.3.1 Changes in Facility Configuration

In accordance with 40 CFR 112.5(a), FLETC Charleston periodically reviews and evaluates this SPCC Plan for any changes in facility design, construction, operation, or maintenance that materially affects the facility’s potential for an oil discharge, including, but not limited to:

< commissioning/decommissioning of containers, to include UST/AST.

< reconstruction, replacement, or installation of piping systems.

< construction or demolition that might alter secondary containment structures; or < changes in service, revisions to standard operations, modification of testing/inspection procedures, and use of new or modified industry standards or maintenance procedures.

Amendments to the Plan made to address changes of this nature are referred to as technical amendments and must be certified by a PE. Non-technical amendments can be done (and must be documented in this section) by the Environmental Protection Specialist. Non-technical amendments include the following:

< change in the name or contact information (i.e., telephone numbers) o f individuals responsible for the implementation of this Plan; or

< change in the name or contact information of spill response or c l e a n u p contractors.

FLETC Charleston must make the needed revisions to the SPCC Plan as soon as possible, but no later than six months after the change occurs. The Plan must be implemented as soon as possible following any technical amendment, but no later than six months from the date of the amendment. The Environmental Protection Specialist is responsible for initiating and coordinating revisions to the SPCC Plan.

1.3.2 Scheduled Plan Reviews

In accordance with 40 CFR 112.5(b), FLETC Charleston reviews this SPCC Plan at least once every five years. Revisions to the Plan, if needed, are made within six months of the five-year review. A registered Professional Engineer certifies any technical amendment to the Plan, as described above, in accordance with 40 CFR 112.3(d). This Plan was updated May 15, 2023. The next plan review is therefore scheduled to take place on or prior to May 15, 2028.

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1.3.3 Record of Plan Reviews

Scheduled reviews and Plan amendments are recorded in the Plan Review Log (Table 1-1). This log must be completed even if no amendment is made to the Plan as a result of the review. Unless a technical or administrative change prompts an earlier review of the Plan, the next scheduled review of this Plan must occur by May 15, 2028.

1.4 Facilities, Procedures, Methods, or Equipment Not Yet Fully Operational (40 CFR 112.7)

Bulk storage containers at this facility have been tested for integrity since their installation. Section

4.2.6 of this Plan describes the inspection program to be implemented following a regular schedule, including the dates by which each of the bulk storage containers must be tested.

1.5 Cross-Reference with SPCC Provisions (40 CFR 112.7)

This SPCC Plan does not follow the exact order presented in 40 CFR part 112. Section headings identify, where appropriate, the relevant section(s) of the SPCC rule. Table 1-2 presents a cross-reference of Plan sections relative to applicable parts of 40 CFR part 112.

Table 1-1: Plan Review Log

By Date Activity

PE

certification required? Comments

Jeff Blankenship

5/15/2018 Update Plan Yes Create new SPCC Plan

James A Brown 5/10/2023 Plan update/five-year review

Yes Plan update/five-year review

H.S. Clifton 5/31/2023 Plan Certification Yes Plan Certified

* PE certifications of this Plan are summarized below.

Date Scope PE Name Licensing State and

Registration No.

5/15/2018 Certification of Plan Harry Summers AL#17129

5/31/2023 Plan update/five-year review H.S. Clifton GA#16611

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Table 1-2: SPCC Cross-Reference

Provision Plan Section Page 112.3(d) Professional Engineer Certification 3

112.3(e) Location of SPCC Plan 4

112.5 Plan Review 4

Table 1-1

112.7 Management Approval 3

112.7 Cross-Reference with SPCC Rule Table 1-2

112.7(a)(3) Part 2: General Facility Information Appendix A: Site Plan and Facility Diagram

Appendix A

112.7(a)(4) 5.4 Discharge Notification 24 Appendix G

112.7(a)(5) Part 5: Discharge Response 22

112.7(b) 3.4 Potential Discharge Volumes and Direction of Flow 10

112.7(c) 3.5 Containment and Diversionary Structures 11

112.7(d) 3.6 Practicability of Secondary Containment 13

112.7(e) 3.7 Inspections, Tests, and Records 13

112.7(f) 3.8 Personnel, Training and Discharge Prevention Procedures 15

112.7(g) 3.9 Security 16

112.7(h) 3.10 Tank Truck Loading/Unloading 16

112.7(i) 3.11 Brittle Fracture Evaluation 18

112.7(j) 3.12 Conformance with Applicable State and Local Requirements 18

112.8(b) 4.1 Facility Drainage 18

112.8(c)(1) 4.2.1 Construction 20

112.8(c)(2) 4.2.2 Secondary Containment 20

112.8(c)(3) 4.2.3 Drainage of Diked Areas 20

112.8(c)(4) 4.2.4 Corrosion Protection 20

112.8(c)(5) 4.2.5 Partially Buried and Bunkered Storage Tanks 20

112.8(c)(6) 4.2.6 Inspection Appendix C - Facility Inspection Checklists

Appendix C

112.8(c)(7) 4.2.7 Heating Coils 20

112.8(c)(8) 4.2.8 Overfill Prevention System 20

112.8(c)(9) 4.2.9 Effluent Treatment Facilities 21

112.8(c)(10) 4.2.10 Visible Discharges 21

112.8(c)(11) 4.2.11 Mobile and Portable Containers 21

112.8(d) 4.3 Transfer Operations, Pumping and In-Plant Processes 21

112.20(e) Certification of Substantial Harm Determination Appendix B

* Only selected excerpts of relevant rule text are provided. For a complete list of SPCC requirements, refer to the full text of 40 CFR part 112.

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Part 2: General Facility Information

Name: FLETC Charleston

Address: 2000 Bainbridge Avenue

(843) 566-8500

Type: Federal Law Enforcement Training Center

Owner/Operator: U.S. Department of Homeland Security

Primary contact: Jeff Blankenship, Environmental Protection Specialist

Cell: (843) 368-9895

2.1 Facility Description (40 CFR 112.7(a)(3))

2.1.1 Location and Activities

FLETC Charleston is a Federal government training facility located in an industrial area along Bainbridge Avenue. in North Charleston, SC. On-site operations include shipping/receiving, indoor/outdoor training, vehicle fueling, cafeteria operations, and administrative offices. The facility is in operation for one shift, Monday-Friday and maintains roughly 63 employees. Security for the site overall is provided through the use of a security service onsite 24 hours a day, 7 days a week. The entirety of the site is fenced, and the security service randomly patrols the site.

Security for oil containers is provided through access control measures such as storing drums in secured locations and locked filling devices.

The police and fire department are the first response for potential safety and hazard conditions, including spill control. The appropriate emergency response telephone numbers are available to anyone who observes a suspect situation.

The Site Plan and Facility Diagram included in Appendix A of this Plan show the location and layout of the facility. The Facility Diagram shows the location of oil containers, buildings, loading/unloading and transfer areas, and critical spill control structures.

2.1.2 Oil Storage

Oils and other petroleum products stored at FLETC Charleston include:

• Diesel used for vehicle fueling and powering emergency generators & boilers.

• Gasoline used for vehicle fueling and lawn/maintenance equipment.

• Elevator Hydraulic Fluid.

• Used motor oils.

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The facility also stores a varying stock of smaller quantity oil products for equipment and vehicle maintenance. The capacities of oil containers present at the site are listed below and are also indicated on the facility diagram in Figure A-2. All containers with capacity of 55 gallons or more are included. Electrical transformers are owned by the local utility (South Carolina Electric & Gas) and are not covered by this plan.

Table 2-1: Oil Containers

SPCC ID Descr. Location Contents Volume (Gals)

1 Generator Belly Tank Building 1 #2 Diesel 180

150 Gallon Elevator Reservoir

Building 1 Elevator Room

Hydraulic Fluid

3 Generator Belly Tank Building 16 #2 Diesel 224

4 55 Gallon Drums Building 26 Used oil, gasoline ~220

5 55 Gallon Drum

Building 39 Elevator Room Hydraulic Fluid 55

6 2,500 Gallon DW AST Building 28

REMOVED 2018

#2 Diesel Fuel 2,500

Elevator Reservoir

Building 39 Elevator Room

Elevator Reservoir

Elevator Reservoir

10 Generator Belly Tank Building 43 #2 Diesel Fuel 500

11 Generator Belly Tank Building 46 #2 Diesel Fuel 500

12 Generator Belly Tank Building 61 #2 Diesel Fuel 500

13 2,500 Gallon

DW AST

Building 46

#2 Diesel Fuel (Currently not in use and empty)

2,500

Elevator Reservoir

Building 46 Elevator

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SPCC ID Descr. Location Contents Volume (Gals)

15 4,000 Gallon DW AST Building 61 #2 Diesel Fuel 4,000

16 1,000 Gallon DW AST Building 61 Unleaded Gasoline 1,000

17 250 Gallon DW AST Building 61 #2 Diesel Fuel 250

18 2,500 Gallon DW AST Building 285

REMOVED 2018

#2 Diesel Fuel 2,500

19 2,500 Gallon DW AST Building 286 #2 Diesel Fuel

(Currently not in use and empty)

2,500

20 Generator Belly Tank Building 654 #2 Diesel Fuel 682

Elevator Reservoir

Building 654 Elevator

22 2,500 Gallon

DW AST

Building NS-1

#2 Diesel Fuel (Currently not in use and empty)

2,500

23 2,500 Gallon DW AST Building NS-44 #2 Diesel Fuel 2,500

24 5,000 Gallon DW AST Building NS-44 #2 Diesel Fuel 5,000

25 1,000 Gallon DW AST Building NS-44 #2 Diesel Fuel 1,000

26 250 Gallon DW AST Building NS-44 Unleaded Gasoline 250

27 Generator Belly Tank

Commercial Entrance Gate #2 Diesel Fuel 200

28 Generator Belly Tank Visitor Control Center #2 Diesel Fuel 850

29 Generator Belly Tank Radio Tower #2 Diesel Fuel 79

Total Storage (Gallons) 26,390

2.2 Evaluation of Discharge Potential

2.2.1 Distance to Navigable Waters and Adjoining Shorelines and Flow Paths

In the event of a spill or a release at FLETC Charleston, Adequate secondary containment is

-10-provided. Any uncontrolled spill escaping the confines of secondary containment would be mitigated by perimeter retention. However, this is an unlikely event since proper precautions are implemented. Trained response individuals are available to respond, and sufficient secondary containment is in place. The nearest water would be Cooper River, which borders the facility immediately to the north.

2.2.2 Discharge History

FLETC Charleston has had no reportable or recordable oil spill incidents within five (5) years prior to the effective date of this SPCC plan.

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PART 3: Discharge Prevention - General SPCC Provisions The following measures are implemented to prevent oil discharges during the handling, use, or transfer of oil products. Oil-handling employees have received training in the proper implementation of these measures.

3.1 Compliance with Applicable Requirements (40 CFR 112.7(a)(2))

FLETC Charleston maintains and uses spill response kits, spill pallets, and/or drain covers as part of its procedures to contain oil discharged in certain areas of the facility (i.e., overfills during unloading of oil products). The primary means of preventing oil discharges is the use of secondary containment, perimeter retention, and good housekeeping.

All 55-gallon oil storage drums are stored on spill pallets or in secondary containment and within proximity to spill kits. Drum storage areas are inspected informally daily and officially on a monthly basis. This is in accordance with accepted industry practice for drum storage and provides an effective means of verifying container integrity.

3.2 Facility Layout Diagram (40 CFR 112.7(a)(3))

Figure A-1 in Appendix A shows the general location of the facility on a U.S. Geological Survey topographic map. As required under 40 CFR 112.7(a)(3), Figure A-2 in Appendix A presents a layout of the facility and the location of storage tanks and drums.

3.3 Spill Reporting (40 CFR 112.7(a)(4))

The discharge notification form included in Appendix G will be completed upon immediate detection of a discharge and prior to reporting a spill to the proper notification contacts.

3.4 Potential Discharge Volumes and Direction of Flow (40 CFR 112.7(b))

In the event of a spill or release at the site, adequate secondary containment is provided. Any uncontrolled spill escaping the confines of the secondary containment would flow into the drainage system on the premises with a potential for discharge into the Cooper River. However, this is an unlikely event since proper precautions have been taken. Trained response individuals are available to respond, and secondary containment is in place.

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Table 3-1: Potential Discharge Volumes and Direction of Flow Source

SPCC ID Location Type of Failure Volume (Gallons)

Rate (Gallon/Hr)

Direction of Flow

Containment (Gallons)

Aboveground Storage Tanks (ASTs) and Drums

Building 1 Rupture; leak below product level

180 Gradual to instantaneous Double Wall Protection

DW

Building 1 Elevator Room

Rupture; leak

150 Gradual to

Perimeter Retention- within elevator room Perimeter Retention

Building 16

224 Gradual to

Building 26

220 Gradual to

Perimeter Retention-within building/structures

Spill Pallets

Building 39 Elevator Room

Rupture; leak

55 Gradual to

Perimeter Retention-within building/structures

Spill Pallet

Building 28

REMOVED 2018

2500 Double Wall

Elevator Room

Rupture; leak

Perimeter Retention- within elevator room

Retention, Spill Kit

Elevator Room

Rupture; leak

Perimeter Retention- within elevator room

Elevator Room

Rupture; leak

Perimeter Retention-within building/structures

Building 43

500 Gradual to

11 Building 46 Rupture;

leak 500 Gradual to instantaneous

Protection DW

Building 61

500 Gradual to

2,500 Gradual to

Elevator Room

Rupture; leak

Perimeter Retention- within elevator room

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Source

SPCC ID Loc Type of Failure Volume

(Gallons) Rate

(Gallon/Hr) Direction of

Flow Containment

(Gallons)

4,000 Gradual to

1,000 Gradual to

250 Gradual to

18 Building 285

REMOVED

2,500 Double Wall

19 Building 286

20 Building 654

682 Gradual to

Building 654 Elevator Room Rupture; leak

Gradual to

Perimeter

Retention- within elevator room

Perimeter Retention, Spill

Kit

22 Building NS-1

23 Building NS-44

24 Building NS-44

5,000 Gradual to

25 Building NS-44

1,000 Gradual to

26 Building NS-44

250 Gradual to

Commercial Entrance Gate

Rupture; leak

200 Gradual to

Visitor Control Center

Rupture; leak

850 Gradual to

29 Radio Tower Rupture; leak below product level

79 Gradual to instantaneous

Double Wall Protection

DW

Table Notes: Rate will vary – due to size of rupture, vacuum, etc. Perimeter Retention – implies retention in either ponds, storm sewer, or other measures. DW = Double Wall. In sec. con – means that any direction of flow is not applicable because the spill is retained within secondary containment.

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Overfill

A release of oil could potentially occur during filling operations, most likely at the aboveground tanks used for vehicle or equipment fueling. The maximum release of product would be less than 50 gallons as the pump rate is approximately 10 gallons/minute. Releases would be pool around the tanks on concrete or surrounding grounds and flow north. This scenario is highly unlikely as filling operations are continuously manned.

Release During Transfer

Another potential avenue of release could occur during the fueling of equipment via a hose failure during transfer of product (i.e., fueling equipment or vehicles). The maximum release would be less than 50 gallons as the pump rate is approximately 10 gallons/minute. Releases would pool around the tanks on concrete or surrounding pavement and flow north. This scenario is highly unlikely as these operations are continuously manned.

3.5 Containment and Diversionary Structures (40 CFR 112.7(c))

3.5.1 Drainage Control [112.7(e)(1)(I-v)]:

Drainage from diked storage areas does not apply to this facility:

The storm drains flow toward the north boundary of the property. Procedures are in place (Appendix J) to detain any spills in these areas and remove if necessary.

Final discharge of drainage:

There is no final discharge of drainage. All spillage from capture locations (secondary containment) will be removed from site by a contractor or the North Charleston Fire Department.

Facility drainage systems and equipment:

All drainage will be retained and then boomed with spill equipment. Spill cleanup kits that include absorbent material, booms, and other portable barriers are located adjacent to, and inside, nearby buildings for petroleum product storage/usage areas. This provides for their

-15-rapid deployment should a spill occur. Used cleanup materials are removed from the site by a professional contract company.

3.5.2 Bulk Storage Tanks/Secondary Containment [112.7(e)(2)(I-xi)]:

Tank compatibility with its contents:

All Aboveground Storage Tanks (ASTs) are constructed of steel or polyurethane plastic and are compatible with the contents that they hold.

Corrosion protection of buried metallic storage tanks:

There are no buried metallic tanks at FLETC Charleston.

Corrosion protection of partially buried metallic tanks:

There are no known partially buried metallic tanks at FLETC Charleston.

Aboveground tank periodic integrity testing:

Tanks are routinely observed by facility personnel during operating hours. Formal inspections are made monthly to examine the exterior of the tanks and the containment areas. These inspections are documented using the report form, which can be found in Appendix C. Further discussion of the facility’s deviation from integrity testing is found in Section 4.2.6.

Control of leakage through internal heating coils:

No tanks that meet these criteria are present at FLETC Charleston.

Tank installation fail-safe engineered:

All AST tanks were fail-safe engineered as part of their installation. Any future upgrades or new AST tanks will be fail-safe engineered at that time.

Observation of disposal facilities for effluent discharge:

No such operations exist at FLETC Charleston.

Visible oil leak corrections from tank seams and gaskets:

Visible oil leaks are reported to maintenance either via regular inspections, reports through security, or other means. These leaks are reported to the management through a work order system, so that they can be fixed immediately. Measures will be taken to minimize and mitigate the leak while awaiting repair. On-site personnel will clean up any minor spills

-16-immediately. If the spill exceeds the capability of trained, on-site personnel or spill kit capacity, the North Charleston Fire Department will be notified.

Appropriate position of mobile or portable oil storage tanks:

There are no mobile or portable oil storage tanks on site.

3.5.3 Facility Transfer Operations [112.7(e)(3)(I-v)]:

Buried piping installation protection and examination is not applicable to this facility.

3.6 Practicability of Secondary Containment (40 CFR 112.7(d))

FLETC Charleston has determined that secondary containment is practicable at this site.

3.7 Inspections, Tests, and Records (40 CFR 112.7(e))

As required by the SPCC rule, FLETC Charleston performs the inspections, tests, and evaluations listed in the following table. Table 3-2 summarizes the various types of inspections and tests performed at the facility. The inspections and tests are described later in this section, and in the respective sections that describe different parts of the facility (e.g., Section 4.2.6 for bulk storage containers).

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Table 3-2: Inspection and Testing Program

Facility Component

Action

Frequency/Circumstances

Aboveground containers (includes AST fill ports)

Inspect outside of containers for signs of deterioration, leakage, or failure.

Daily (informal), Monthly, and whenever material repairs are made.

Spill containment pallets/Spill Kits

Inspect accountability and serviceability. Monthly

All aboveground valves, piping, and appurtenances

Assess general condition of items, such as flange joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, drain blanks, and metal surfaces.

Monthly

Buried piping NA NA

3.7.1 Daily Inspection

FLETC Charleston maintenance contractors are in and around the oil storage areas of the facility daily. During the performance of normal activities, these personnel will informally conduct a visual inspection. This daily visual inspection involves: (1) looking for tank/piping damage or leakage or stained or discolored asphalt or soils; (2) observing oil unloading activities by outside vendors;

and (3) employment of oil spill prevention measures as appropriate.

3.7.2 Monthly Inspection

The checklist provided in Appendix C is used for Monthly inspections by designated personnel.

The monthly inspections cover the following key elements:

Observing the exterior of aboveground storage tanks, pipes, and other equipment for signs of deterioration, leaks, corrosion, and thinning.

Observing the exterior of portable containers (drums) for signs of deterioration or leaks.

Observing the tank fill ports and discharge pipes/hoses for signs of poor connection that could cause a discharge, and tank vents for obstructions and proper operation.

Verifying the proper functioning of overfill prevention systems.

Checking the inventory of spill response materials and restocking as needed.

Verifying that ASTs do not exceed 80% capacity.

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All problems regarding tanks, piping, containment, or response equipment must immediately be reported to the Environmental Protection Specialist. Visible oil leaks from tank walls, piping, or other components must be repaired as soon as possible to prevent a larger spill or a discharge to storm/sanitary sewer drains. Pooled oil shall be removed immediately upon discovery.

Written Monthly inspection records are provided to the Environmental Protection Specialist and maintained at the facility for a period of three years.

3.7.3 Annual Inspection

FLETC Charleston designated personnel perform a more thorough inspection of facility equipment on an annual basis. This annual inspection complements the monthly inspection described above and is performed using the checklist provided in Appendix C of this Plan.

The annual inspection is preferably performed after a large storm event in order to verify the imperviousness and/or proper functioning of drainage control systems.

Written annual inspection records are provided to the Environmental Protection Specialist and maintained at the facility for a period of three years.

3.7.4 Periodic Integrity Testing

Other than the monthly and annual inspections by facility personnel, none of the storage tanks requires periodic integrity testing. Integrity testing is only required if a leak is detected, or the AST undergoes a major modification.

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3.8 Personnel, Training, and Discharge Prevention Procedures

(40 CFR 112.7(f))

In the event a petroleum product spill at the site cannot be contained and cleaned up, the North Charleston Fire Department shall be notified. The North Charleston Fire Department will be responsible for directing the spill response team during confinement, containment, and clean-up of the spill.

In the event a petroleum product spill occurs at the site, the Environmental Protection Specialist or his designate will assist the North Charleston Fire Department and/or the local emergency team. He is selected for this role because of his extensive knowledge of the site and the types of material stored and used on-site.

The facility has implemented an employee/contractor training program for selected personnel to ensure they are sufficiently trained to respond to a spill emergency during site operations.

All key personnel are trained in the aspects of this plan, the proper use of personal protective equipment (PPE), and all reporting/recordkeeping procedures. All non-key personnel are instructed in personal safety measures to be implemented while at the site and awareness of the objectives of the SPCC plan.

3.9 Security (40 CFR 112.7(g))

Access to the site can be gained from the access point off Bainbridge Avenue, next to the Visitors Center. The site is monitored by a security force at all times. The entirety of the site is fenced and may only be accessed after passing through the access point. One bulk storage container exists outside the fenced area, outside the Visitor Center, which is patrolled by the security service.

3.10 Tank Truck Unloading Requirements (40 CFR 112.7(h))

Fueling activities are performed on-site. All unloading and transport of vehicles to fill tanks shall meet minimum requirements and regulations established by the Department of Transportation.

Tanks shall be attended while fueling is performed to provide oversight of the filling process, visible detection of spills, leaks from seams, gaskets, or valves and to prevent overflows.

Environmental Protection Specialist or its designate shall make periodic inspections of the fueling area for signs of minor spills. If spills are present, any exposed soil shall be removed and disposed of in accordance with local, state and federal regulations. The Environmental Protection Specialist or their designate shall investigate the origin of the spill, record the information, and remedy the cause.

All personnel involved in the fueling process shall be trained in the prevention and prompt containment/cleanup of spills in accordance with this plan.

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3.10.1 Secondary Containment (40 CFR 112.7(h)(1))

FLETC Charleston has ensured adequate equipment has been procured and is stored on-site for selected personnel to effectively respond to an emergency spill. The storage locations for the spill response equipment are clearly marked. Selected personnel are trained in the proper use of the equipment and spill response procedures.

The type of emergency equipment/materials necessary for an accidental spill response may include items such as disposable coveralls, chemical resistant gloves, chemical resistant boots, splash goggles/face shield, absorbent, fire extinguisher, drum bung wrench, empty drums for collection, pliers, wrenches, tape seals, and plugging material.

Emergency spill response equipment is located throughout the facility and in close proximity to all locations containing bulk petroleum storage.

3.10.2 Loading/Unloading Procedures (40 CFR 112.7(h)(2) and (3))

FLETC Charleston performs no truck or tank car loading/unloading activities as part of their operations. All truck unloading activities are completed by outside delivery companies. FLETC Charleston requires all such contracted delivery companies comply with DOT regulations in 49 CFR Part 177. In addition, all unloading performed by contracted companies must have prior authorization by management and be supervised during all unloading activities. Access to unloading points is restricted to only authorized personnel.

There are no warning signs to prevent vehicular departure before disconnecting flexible or fixed transfer lines at any of the unloading areas. For the diesel unloading points, it has been determined that there is no need for such warnings since unloading is infrequent and since it is performed by a professional contracted service supervised by FLETC personnel.

FLETC Charleston does not own or operate a fleet of fueling vehicles which load/unload on a routine basis. Fuel unloading is infrequently performed. These companies are responsible for identifying any leakage or drainage from their vehicle(s) or equipment before leaving any loading/unloading site.

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Table 3-3: Fuel Transfer Procedures

Stage Tasks Prior to loading/ unloading

Visually check all hoses for leaks and wet spots.

Verify that sufficient volume (ullage) is available in the storage tank or truck.

Secure the site vehicle or mobile equipment with wheel chocks, if applicable.

Ensure that the site vehicle’s parking brakes are set.

Turn off cell phone.

During loading/ unloading

Personnel must stay with the site vehicle or equipment at all times during loading/unloading activities.

Periodically inspect all systems, hoses and connections.

Ensure that equipment being refueled is shut off.

Monitor the liquid level in the receiving container to prevent overflow.

Use a drip pan.

After loading/ unloading

Ensure that all transfer hoses are drained to remove the remaining fuel before moving them away from the connection. Use a drip pan.

Cap the end of the hose and other connecting devices before moving them to prevent uncontrolled leakage.

Remove wheel chocks, if used.

Inspect all dispensing equipment prior to departure. If necessary, tighten, adjust, or replace caps, valves, or other equipment to prevent fuel leaking or report unsafe or unusual conditions to the Environmental Protection Specialist.

3.11 Brittle Fracture Evaluation (40 CFR 112.7(i))

Brittle fracture evaluation relates to field-constructed ASTs undergoing repair, alteration or change in service that may fail or have failed or discharged due to brittle fracture. The field- constructed ASTs are evaluated for risk of such failure. This site does not have field- constructed ASTs.

3.12 Conformance with State and Local Applicable Requirements (40 CFR

112.7(j))

South Carolina has no state requirement beyond federal requirements regarding SPCC plans.

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PART 4: Discharge Prevention – SPCC Provisions for Onshore Facilities (Excluding Production Facilities)

4.1 Facility Drainage (40 CFR 112.8(b))

The most probable spill scenario would be the rupture of a 55-gallon drum. Since 55-gallon drums are stored on pallets and with perimeter retention, the likelihood of an uncontrolled spill is minimal.

In the unlikely scenario of an uncontrolled spill escaping to the confines of secondary containment and perimeter retention, said spill could possibly flow into natural drainage contours on the perimeter of the facility and ultimately could be discharged at the north end of the property into the Cooper River.

In the event of a fuel spill in any containment area, the fuel will be pumped from the containment area into a tanker truck or other tanks as soon as possible. Any soiled spill absorbent or mats shall be removed and disposed of in accordance with local, state, and federal rules and regulations.

Table 3-1 presents expected volume, discharge rate, general direction of flow in the event of equipment failure and means of secondary containment for different parts of the facility where oil is stored, used, or handled.

As described in Section 2.2.1, site drainage, both storm sewer and topographical runoff, flows naturally to the north of the site. None of the drainage points flow directly into a navigable waterway.

4.2 Bulk Storage Containers (40 CFR 112.8(c))

Table 2-1 (Oil Containers) identifies the type, volume, and content of bulk storage containers at FLETC Charleston.

Vehicle repairs are always a concern for spill prevention plans because of the presence of petroleum products and other materials that can accidentally be discharged. Minimum vehicle maintenance or repairs are performed on site.

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4.2.1 Construction (40 CFR 112.8 (c)(1))

All ASTs are constructed of steel with fiberglass or concrete casings, thus corrosion protection is inherent. The design and construction of all bulk storage containers are compatible with the characteristics of the oil product they contain and with temperature and pressure conditions.

4.2.2 Secondary Containment (40 CFR 112.8(c)(2))

See Section 3.10.1 for a full description of secondary containment for the bulk storage tanks.

4.2.3 Drainage of Diked Areas (40 CFR 112.8(c)(3))

As there are no diked areas at FLETC Charleston, this section does not apply to this facility.

4.2.4 Corrosion Protection (40 CFR 112.8(c)(4))

Corrosion protection is intrinsic to all ASTs based on their construction.

4.2.5 Partially Buried and Bunkered Storage Tanks (40 CFR 112.8(c)(5))

This section is not applicable since there are no partially buried or bunkered storage tanks at FLETC Charleston.

4.2.6 Inspections and Tests (40 CFR 112.8(c)(6))

Formal inspections of the Aboveground Storage Tanks (ASTs) shall be performed on a Monthly basis. Sample inspection forms are located in Appendix C. Upon completion, the forms should be placed in the Environmental Office and maintained for a period no less than three years.

4.2.7 Heating Coils (40 CFR 112.8(c)(7))

Not Applicable.

4.2.8 Overfill Prevention Systems (40 CFR 112.8(c)(8))

All ASTs are remotely monitored. All fill ports for the ASTs provide limited overfill prevention during filling. General secondary containment is provided in the event of overfills, as described in this Plan. Either site personnel or delivery personnel are present throughout filling operations to monitor the product level.

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4.2.9 Effluent Treatment Facilities (40 CFR 112.8(c)(9))

Storm water is not pretreated prior to discharge to the storm sewer system. All other facility process wastewaters are directly discharged to the sanitary sewer system for treatment by the City of Charleston Publicly Owned Treatment Works (POTW).

4.2.10 Visible Discharges (40 CFR 112.8(c)(10))

Visible discharges from any oil storage tank, container, or appurtenance – including seams, gaskets, piping, pumps, valves, rivets, and bolts – are quickly corrected upon discovery.

Oil is promptly removed from any secondary containment and discarded through a contracted recycling vendor.

4.2.11 Mobile and Portable Containers (40 CFR 112.8(c)(11))

Small portable oil storage containers are stored in the back of Building 26 and Building 39. where secondary containment is provided by spill pallets. Any spilled or leaked material is quickly contained and cleaned up using spill kits and appropriate cleaning products.

4.3 Transfer Operations, Pumping, and In-Plant Processes

(40 CFR 112.8(d))

All oil product transfers are addressed in Section 3.10 above.

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Part 5: Discharge Response This section describes the response and cleanup procedures in the event of an oil discharge. The uncontrolled discharge of oil to groundwater, surface water, or soil is prohibited by state and federal laws. Immediate action must be taken to control, contain, and recover discharged product.

In general, the following steps are taken:

< Potential ignition sources are eliminated, if possible.

< If possible and safe to do so, identify and shut down source of the discharge to stop the flow.

< Contain the discharge with sorbents, berms, fences, trenches, sandbags, or other material.

< Contact the Environmental Protection Specialist or their alternate.

< Contact the local fire department and/or emergency response contractor if the discharge exceeds site personnel or equipment capabilities; and < Collect and dispose of recovered products according to regulation.

For the purpose of establishing appropriate response procedures, this SPCC Plan classifies discharges as either “minor” or “major,” depending on the volume and characteristics of the material released.

A list of Emergency Contacts is provided in Appendix F. The list is also posted at prominent locations throughout the facility. Discharge response material kept at the facility is addressed in Appendix H. A specific contingency plan for response to oil spill incidents is at Appendix J.

5.1 Response to a Minor Discharge

A “minor” discharge is defined as one that poses no significant harm (or threat) to human health and safety or to the environment. Minor discharges are generally those where:

< The quantity of product discharged is small (e.g.,, may involve less than 10 gallons of oil).

< Discharged material is easily stopped and controlled at the time of the discharge.

< Discharge is localized near the source.

< Discharged material is not likely to reach water.

< There is little risk to human health or safety; and < There is little risk of fire or explosion.

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Minor discharges can usually be cleaned up by FLETC Charleston’s trained O&M contractor. The following guidelines apply:

< Immediately notify the Environmental Protection Specialist or alternate.

< Contain the discharge with discharge response materials and e q u ip m e n t .

Place discharge debris in properly labeled waste containers.

< The Environmental Protection Specialist will complete the discharge notification form (Appendix G) and attach a copy to this SPCC Plan.

< If the discharge involves more than 10 gallons of oil and the oil is released off- site

(i.e., through the storm/sanitary sewer, surface water, or groundwater), the Environmental Protection Specialist will contact the NRC, SC DHEC Lowcountry Office, and North Charleston Fire Department.

IT SHOULD BE NOTED THAT FAILURE TO NOTIFY THE EPA NRC WITHIN 15

MINUTES OF A SPILL EXCEEDING THE REPORTABLE QUANTITY (10

Gallons or more) CAN RESULT IN SIGNIFICANT FINES.

5.2 Response to a Major Discharge

A “major” discharge is defined as one that cannot be safely controlled or cleaned up by facility personnel, such as when:

< The discharge is large enough to spread beyond the immediate discharge area

(beyond 55 gallons).

< The discharged material enters water.

< The discharge requires special equipment or training to clean up.

< The discharged material poses a hazard to human health or safety; or < There is a danger of fire or explosion.

In the event of a major discharge, the following guidelines apply:

< All personnel must immediately evacuate the discharge site via designated exit routes and move to designated staging areas at a safe distance from the discharge. Exit routes are identified on fire evacuation diagrams located throughout the facility.

< If the Environmental Protection Specialist is not present at the facility, t h e senior on-site person has authority to initiate notification and response. Certain notifications are dependent on the circumstances and type of discharge.

< The Environmental Protection Specialist (or senior on-site person) must call for medical assistance if personnel are injured.

< The Environmental Protection Specialist (or senior on-site person) must notify the Fire Department or Police Department.

< The Environmental Protection Specialist (or senior on-site person) must call the spill response and cleanup contractor listed in the Emergency Contacts list in Appendix F.

< The Environmental Protection Specialist (or senior on-site person) m u s t immediately contact SC DHEC and the National Response Center (888-424- 8802).

< Environmental Protection Specialist (or senior on-site person) must record the

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< The Environmental Protection Specialist (or senior on-site person) coordinates cleanup and obtains assistance from the fire department or outside cleanup contractor as necessary.

If the Environmental Protection Specialist is not available at the time of the discharge, then the next highest person in seniority assumes responsibility for coordinating response activities.

5.3 Waste Disposal

Wastes resulting from a minor discharge response will be containerized in impervious bags, drums, or buckets. Oil spill wastes resulting from a major discharge response will be containerized in drums, bulk bags, or roll-offs. The Environmental Protection Specialist will characterize the waste for proper disposal and ensure that it is removed from the facility by a licensed waste hauler.

5.4 Discharge Notification

Any size discharge (i.e., one that creates a sheen, emulsion, or sludge) that affects or threatens to affect navigable waters must be reported immediately to the National Response Center (1- 800-424-8802). The Center is staffed 24 hours a day.

A summary sheet is included in Appendix G to facilitate reporting. The person reporting the discharge must provide the following information:

Name, location, organization, and telephone number Name and address of the party responsible for the incident Date and time of the incident Location of the incident Source and cause of the release or discharge Types of material(s) released or discharged.

Quantity of materials released or discharged.

Danger or threat posed by the release or discharge.

Number and types of injuries (if any) Media affected or threatened by the discharge (i.e., water, land, air) Weather conditions at the incident location Any other information that may help emergency personnel respond to the incident.

Contact information for reporting a discharge to the appropriate authorities is listed in Appendix G.

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In addition to the above reporting, 40 CFR 112.4 requires that information be submitted to the United States Environmental Protection Agency (EPA) Regional Administrator and the District Office of the EPA (see contact information in Appendix G) whenever the facility discharges (as defined in 40 CFR 112.1(b)) more than 1,000 gallons of oil in a single event, or discharges (as defined in 40 CFR 112.1(b)) more than 42 gallons of oil in each of two discharge incidents within a 12-month period. The following information must be submitted to the EPA Regional Administrator and to SC DHEC within 30 days:

< Name of the facility;

< Name of the owner/operator;

< Location of the facility;

< Maximum storage or handling capacity and normal daily throughput;

< Corrective action and countermeasures taken, including a description of equipment repairs and replacements;

< Description of facility, including maps, flow diagrams, and topographical maps;

< Cause of the discharge(s) to navigable waters, including a failure analysis o f the system and subsystem in which the failure occurred;

< Additional preventive measures taken or contemplated to minimize possibility of recurrence; and < Other pertinent information requested by the Regional Administrator.

A standard report for submitting the information to the EPA Regional Administrator and to SC DHEC is included in Appendix I of this Plan.