ATTACHMENT 8 - DFSP Pt. Loma SPCC Final.pdf

SITE SPECIFIC REPORT

Distribution limited to U.S. Government agencies and their contractors: Administrative/Operational Use; June 2018. Other request for this document shall be referred to the DLA Installation Operations for Energy (DLA).

SPILL PREVENTION, CONTROL AND

COUNTERMEASURE (SPCC) PLAN

DLA Installation Operations for Energy

Defense Fuel Support Point (DFSP) Point Loma Remediation System

San Diego, California

Amendment No. 1

Updated By:

APTIM Federal Services, LLC

August 2018

DSFP Pt. Loma Environmental Services SPE60323D5002 ATTACHMENT 8

SPCC Plan – DFSP Point Loma Remediation System

SPILL PREVENTION, CONTROL, AND COUNTERMEASURE (SPCC) PLAN

DFSP Point Loma Remediation System – Table of Contents

Title / Topic of Section Section – Page

SECTION 1: INTRODUCTION – SPCC Plan – DFSP Point Loma Remediation System

Purpose .................................................................................................................... Section 1 – Page 1 Regulatory Background ........................................................................................... Section 1 – Page 1 General Information ................................................................................................. Section 1 – Page 2 Location of Installation ............................................................................................ Section 1 – Page 2 Responsibilities ........................................................................................................ Section 1 – Page 3 Document Organization ........................................................................................... Section 1 – Page 5 Acronyms ................................................................................................................. Section 1 – Page 7 Professional Engineer Certification ......................................................................... Section 1 – Page 9 Management Approval of SPCC Plan ..................................................................... Section 1 – Page 9 Five-Year Plan Review ............................................................................................ Section 1 – Page 9 Certification of the Applicability of the Substantial Harm Criteria ......................... Section 1 – Page 11 Plan Amendments .................................................................................................... Section 1 – Page 13

SECTION 2: SPCC REGULATION – Citation-by-Citation Responses to SPCC Requirements

SPCC REGULATION – 40 CFR 112 (As amended 13 November 2009) .............. Section 2 – Page 1

SECTION 3: TABS A - D – Site-Specific and Container-Specific Assessments

Tab A: Groundwater Recovery Compound ............................................................. Section 3 – Page A-1 Tab B: SPAWAR Transfer Compound .................................................................... Section 3 – Page B-1 Tab C: Remediation Processing Compound ............................................................ Section 3 – Page C-1 Tab D: Recovery Systems and Pipelines ………………………………………... Section 3 – Page D-1

SPILL PREVENTION, CONTROL, AND COUNTERMEASURE (SPCC) PLAN

DFSP Point Loma Remediation System – Table of Contents

Title / Topic of Section Section – Page

SECTION 4: APPENDICES A - H – Supporting SPCC Plan Information

Appendix A: Condition Figure for DFSP Point Loma Remediation System .......... Section 4 – Page A-1 Appendix B: Container Inventory ............................................................................ Section 4 – Page B-1 Appendix C: Inspection Checklists .......................................................................... Section 4 – Page C-1 Appendix D: Emergency Response Action Plan ..................................................... Section 4 – Page D-1 Appendix E: Oil Spill Prevention Operating Procedures ......................................... Section 4 – Page E-1 Appendix F: Spill Rate, Quantity, and Pathway Estimation .................................... Section 4 – Page F-1 Appendix G: Reasonable Expectation of Reaching Navigable Waters ................... Section 4 – Page G-1 Appendix H: SPCC Plan Amendments (Reserved) ................................................. Section 4 – Page H-1

SECTION 1

INTRODUCTION

This Page Intentionally Blank

SPCC – Section 1 – Page i

INTRODUCTION – Section 1 Table of Contents

Title/Topic of Section Page

Purpose Regulatory Background General Information Location of Installation Responsibilities Acronyms Professional Engineer Certification Management Approval of SPCC Plan Five-Year Plan Review Certification of the Applicability of the Substantial Harm Criteria (EPA Form) Plan Amendments

SPCC – Section 1 – Page ii

SPCC – Section 1 – Page 1

INTRODUCTION

SPCC Plan – DFSP Point Loma Remediation System

Purpose

A Spill Prevention, Control, and Countermeasure (SPCC) Plan is a detailed, facility-specific, written description of how a facility’s operations comply with the requirements of the Oil Pollution Prevention regulation of Title 40, Code of Federal Regulations (CFR), Part 112. These requirements include measures such as secondary containment, facility drainage, dikes and barriers, sump and collection systems, retention ponds, curbing, tank corrosion protection systems, and liquid level devices.

Regulatory Background

The United States Coast Guard (USCG) and U.S. Department of Transportation (DOT) have regulatory jurisdiction over fuel and oil transportation-related facilities. Fueling, oiling, and maintenance of vessels falls under the jurisdiction of the USCG; fuel and oil storage and handling activities of transportation-related facilities such as railway and pipelines falls under the jurisdiction of the DOT. The U.S.

Environmental Protection Agency (EPA), under the Oil Pollution Prevention regulation of 40 CFR 112, regulates all other facilities that are not transportation-related.

Section 311(j)(1)(C) of the Clean Water Act required the President to issue regulations establishing procedures, methods, equipment, and other requirements to prevent discharges of oil from vessels and facilities and to contain such discharges. When the President delegated the authority to regulate non-transportation-related onshore facilities to EPA, EPA promulgated 40 CFR 112, published 11 December 1973, to protect the surface waters of the United States. EPA has amended this regulation several times.

EPA established the SPCC Plan requirements in extensive amendments to 40 CFR 112 published 17 July 2002.

EPA changed the deadline for amending and implementing SPCC Plans in amendments published 9 January 2003, 17 April 2003, 11 August 2004, 17 February 2006, 16 May 2007, and 19 June 2009. The deadline for amending and implementing SPCC Plans was 10 November 2011.

EPA published significant amendments on 26 December 2006. These amendments: 1) allow owners and operators of qualified facilities that store 10,000 gallons of oil or less and meet other qualifying criteria to self-certify their SPCC Plans in lieu of review and certification by a Professional Engineer; 2) provide an alternative to the general secondary containment requirement without requiring a determination of impracticability for facilities that have particular types of oil-filled equipment; 3) define and exempt particular vehicle fuel tanks and other on-board bulk oil storage containers used for motive power; 4) exempt mobile refuelers from the sized secondary containment requirements for bulk storage containers;

5) remove and reserve the SPCC requirements for animal fats and vegetable oils that are specific to onshore oil production facilities, onshore oil drilling and work-over facilities, and offshore oil drilling, production, or work-over facilities; and 6) extend the SPCC compliance dates for farms until EPA issues future amendments containing requirements for farms. These changes became effective on 26 February 2007.

This SPCC Plan (Amendment No. 1) is based upon 40 CFR 112 including all amendments published through July 2018 and the Naval Facilities Engineering Command Southwest (NAVFAC SW) Environmental Compliance Core’s template for the Naval Base Point Loma (NBPL) SPCC Plan, including correspondence with regulatory agencies (Naval Base Point Loma, Spill Prevention, Control, and Countermeasure Plan, NAVFAC SW, February 2018).

SPCC – Section 1 – Page 2

General Information

This SPCC Plan covers all oil storage and handling sites for the Defense Logistics Agency, Installation Operations for Energy (DLA) Defense Fuel Support Point (DFSP) Point Loma Remediation System with capacities 55 gallons or greater. This includes bulk storage containers (e.g., aboveground storage tanks [ASTs], drum storage areas, etc.). Oil storage and handling sites only include petroleum-based oils.

Hazardous substance storage and handling sites that are not oil-related (i.e., not regulated by 40 CFR 112) are not included in the scope of this Plan. The USCG and the Naval Supply Systems Command, Fleet Logistics Center (NAVSUP FLC) San Diego DFSP Point Loma terminal are separate operations with their own SPCC Plans (Naval Base Point Loma, Spill Prevention, Control, and Countermeasure Plan, NAVFAC SW, February 2018.

Refer to Appendix A for the location map of the DFSP Point Loma Remediation System facility.

All of the AST-related surveyed containers and equipment are adequately documented in this SPCC Plan, per the requirements of 40 CFR 112 (11/20/09). All bulk storage containers are thoroughly detailed in Section 3 write-ups. These write-ups document and depict five (5) ASTs. This NBPL SPCC Plan does not include oil-filled electrical transformers and switches which are present but owned and managed by a separate entity, NAVFAC SW. This SPCC Plan does not include the DFSP Point Loma bulk storage and distribution facility under the administrative control of the NAVSUP FLC San Diego.

Remediation System Capacities

Storage Type

Total Capacity

Capacity

Gallons Barrels

Aboveground Storage Tanks 36,755 875

Intra-Facility Pipelines 2,606 62

Installation Total 39,361 937

Location of Installation

DFSP Point Loma Remediation System is a government-owned, contractor-operated, light non-aqueous phase liquid (LNAPL) and total petroleum hydrocarbon (TPH)-impacted groundwater recovery and treatment facility under the administrative control of DLA. The primary function of DFSP Point Loma Remediation System is to recover LNAPL and TPH-impacted groundwater, separate the recovered LNAPL, and treat the groundwater for proper disposal. The sources and nature of the contaminants of potential concern (COPCs) at the site are fuel petroleum hydrocarbons, primarily from diesel fuel, marine and jet propellant 5, as well as minor amounts of aviation gasoline and motor gasoline. The tanks and piping that released the fuels have been demolished and/or removed from service as part of the planned military construction (MILCON) project P-401 and are no longer a source. Residual soil contamination exists between the former locations of tanks or pipelines that leaked, and LNAPL is present at the groundwater table. The residual contamination held in the soil is not migrating; LNAPL has the potential to migrate and diffuse into the groundwater if not remediated.

SPCC – Section 1 – Page 3

DFSP Point Loma Remediation System is composed of several LNAPL recovery and groundwater extraction systems and collection points placed within the approximately 50 acres of the DFSP Point Loma terminal and surrounding NBPL property; these collection points collectively occupy less than an acre. There are various extraction and recovery system components, including six vertical extraction wells, five horizontal extraction wells, and two deep horizontal collection trenches with sumps. The recovered LNAPL and groundwater are handled at three locations: the Space and Naval Warfare Systems Command (SPAWAR) Transfer Compound, the Groundwater Recovery Compound (Building 604), and the Remediation Process Compound (Upper Compound). The DFSP Point Loma Remediation System is located on the east side of the Point Loma Peninsula, about two miles inside the entrance to San Diego Bay. The DFSP Point Loma Remediation System lies approximately three miles southwest of the San Diego Airport and four miles west of downtown San Diego. It is located within the boundary of NBPL, from the northeast property boundary line extending south along Rosecrans Street approximately one-half mile.

Refer to Appendix A for the location map of the DFSP Point Loma Remediation System facility.

Responsibilities

The responsibility for implementing this SPCC Plan lies with DLA, and the ultimate responsibility for all actions on NBPL lie with the NBPL Commanding Officer (CO). The Installation Environmental Program Manager provides oversight and ensures that the Plan is being implemented by tank owners/operators and other tenant command activities involved in storage and handling of petroleum, oil and lubricant (POL) products. Through the Navy Regional command structure, a chain of command has been established to ensure compliance with the various components of the Plan. The following section describes NAVFAC SW, Navy Regional, DLA, and DFSP Point Loma Remediation System contractor personnel who share the responsibility for implementing this SPCC Plan.

SPCC Program Manager: The NBPL Installation Environmental Program Manager is a NAVFAC SW employee who reports to the NBPL CO and has environmental oversight responsibilities of NBPL and its tenants. The NBPL Installation Environmental Program Manager is also designated as the SPCC Program Manager and is directly responsible for ensuring the implementation of this Plan. The SPCC Program Manager’s responsibilities with respect to SPCC Plan are to:

Ensure that site surveys are conducted at least once every five years to determine if site modifications are required to remain in compliance with SPCC guidelines;

Review all plans related to oil storage, handling, or transfer facilities for new construction, maintenance, or remodeling, in order to determine if an SPCC Plan amendment or additional SPCC documentation is required;

Recommend facility modifications to achieve compliance with the SPCC guidelines so as to ensure project submittals as soon as possible, but no later than six months after any change in design, construction, operation, or maintenance occurs (this responsibility is also generated by DLA and DFSP Point Loma Remediation System supervisors);

Develop procedures and train security personnel on how to deal with vehicles entering the installation with shifting or leaking loads of oil products, and ensure personnel are familiar with hazardous material vehicle markings;

Ensure that the SPCC Plan is current and responsive to the activities and operations performed at the DFSP Point Loma Remediation System;

Ensure that training, as required by 40 CFR 112, is conducted; and Develop inspection logs.

SPCC – Section 1 – Page 4

Security Department: The responsibilities of the NBPL Security Department with respect to this SPCC Plan include inspection of security systems, such as land and water access control, locked storage areas, lighting, fencing, and traffic control, to ensure that spills do not result from vandalism or unauthorized entry.

Federal Fire Department (FFD): The Fire Department is responsible for responding to spills that Facility personnel cannot handle. Specific responsibilities include:

- Implement the Incident Command System (ICS) as required;

- The FFD will act as the Incident Commander (IC) during the initial spill response and control phases of the spill management process and will transfer IC duties to the Response Team once initial spill response is complete;

- The FFD will direct the spill response with members of the Response Team, as needed;

- Provide equipment and manpower to rescue personnel and provide first aid;

- Ensure that all firefighters are aware of safety considerations associated with spill response duties;

- Ensure that all Federal Fire Department personnel have received appropriate training;

- Work with site personnel on evacuating personnel and establishing an exclusion zone, if required;

- Provide information on potential fire and explosion hazards related to spilled materials;

and

- Request the services of the Response Team and direct the various support agencies, as required, to mitigate the incident.

DFSP Point Loma Remediation System Operational Supervisors (Contractor): The responsibilities of DFSP Point Loma Remediation System contractor supervisors with respect to this SPCC Plan include:

Identify the number and types of personnel needing training, and coordinate this requirement through their training coordinator. New DFSP Point Loma Remediation System employees should be trained within three months from the date of employment;

Visually inspect vehicles that contain fuel oil entering the DFSP Point Loma Remediation System, for leaks and any obvious mechanical deficiencies which could cause a spill event or accident; and Coordinate, with DLA and the NBPL environmental office in the development of safety, security, facility inspection logs, and regulatory reporting requirements for the operations, equipment, and facilities under the supervisor's cognizance; and Perform the assigned inspections identified in the SPCC inspection logs, and initiate corrective actions for any deficiencies found during inspections.

Tank inspections, repairs, and general maintenance are the responsibility of the contractor site operators, as are spills resulting from tank or drum leaks. If a leak or spill occurs during tank filling or pumping out, it is the responsibility of the truck operator to initiate emergency procedures including initial spill notification.

SPCC – Section 1 – Page 5

Document Organization

This guidance document consists of four main components:

Section 1 is an introduction that describes the purpose, regulatory background, and command organization of the guidance document, and includes spaces for the required registered Professional Engineer (PE) certification and management approval. Certification of the applicability of the substantial harm criteria (used to determine if a Facility Response Plan is required) and guidance on documenting plan amendments and five-year plan reviews are also included.

Section 2 sequentially lists responses to the SPCC requirements of 40 CFR 112 and references pages where pertinent information is located in the Plan.

Section 3 lists site-specific and container-specific assessments grouped into four tabs. Tabs correspond to a tank/container location or type where segregation is preferred.

Section 4 includes several appendices that provide supplemental SPCC Plan information pertaining to the DFSP Point Loma Remediation System. Appendices include:

Appendix A – Facility Map of the DFSP Point Loma Remediation System: provides a map showing all of the locations that pertain to DFSP Point Loma Remediation System, including a facility diagram of the DFSP Point Loma showing the area tanks, drainage, boundaries and a Tank Facility Piping Layout. Specific facility diagrams for the Groundwater Recovery Compound, SPAWAR Transfer Compound, and Remediation Process Compound, are shown in Section 3.

Appendix B – Container Inventory: provides a comprehensive list of all containers and oil-filled electrical equipment at the DFSP Point Loma Remediation System.

Appendix C - Inspection Checklists: provides checklists for the routine inspection of ASTs, 55 gallons or larger at the DFSP Point Loma Remediation System.

Appendix D - Emergency Response Action Plan: See Red Plan in the NBPL Integrated Contingency Plan: identifies where to find spill response procedures to be followed in the event of an emergency or a discovered release at DFSP Point Loma Remediation System.

Appendix E - Oil Spill Prevention Operating Procedures: provides procedures to be followed when filling, emptying or operating POL containers.

Appendix F - Spill Rate, Quantity, and Pathway Estimation: provides the general methodology employed in making estimates of the rates of flow and quantities for various kinds of potential spills.

Appendix G - Reasonable Expectation of Reaching Navigable Waters: provides the general methodology in making determinations on whether a given oil storage container may pose a reasonable expectation of reaching navigable waters, in the event a spill or release were to occur.

Appendix H – SPCC Plan Amendments: Reserved.

SPCC – Section 1 – Page 6

SPCC – Section 1 – Page 7

Acronyms

The following acronyms are used in this document:

API

APSA

American Petroleum Institute Aboveground Petroleum Storage Act

AST - Aboveground Storage Tank BS - Bayside CA - California CFR - Code of Federal Regulations

CO

COPC

Commanding Officer Contaminants of Potential Concern

CUPA - Certified Unified Program Agency DOT - U.S. Department of Transportation DoD - Department of Defense DR - Drive DFSP - Defense Fuel Support Point DLA - Defense Logistics Agency, Installation Operations for Energy EPA - U.S. Environmental Protection Agency ERAP - Emergency Response Action Plan FITC - Fleet Intelligence Training Center FOR - Fuel, Oil Reclamation GPM - Gallons per Minute H - Height HAZMAT - Hazardous Materials

HDPE

HMI

High Density Polyethylene Human Machine Interface

HW - Hazardous Waste ICP - Integrated Contingency Plan L - Length LNAPL Light Non-aqueous Phase Liquid NA - Not Applicable NAPL - Non-aqueous Phase Liquids NAVFAC - Naval Facilities Engineering Command

NAVFAC ESC

NAVSUP FLC

Naval Facilities Engineering Service Center Naval Supply Systems Command, Fleet Logistics Center San Diego

NOAA - National Oceanic Atmospheric Administration NBPL - Naval Base Point Loma OPNAVINST - Office of the Chief of Naval Operations Instruction OWS - Oil Water Separator

PE

PLC

Professional Engineer Programmable Logic Controller

POL - Petroleum, Oil, Lubricant PVC - Polyvinyl Chloride PW - Public Works Red Plan First Responder Plan of Action RO Reverse Osmosis SS - Seaside SPCC - Spill Prevention, Control, and Countermeasure SPAWAR - Space and Naval Warfare Systems Command

SPCC – Section 1 – Page 8

SW - Southwest TPH - Total Petroleum Hydrocarbons TS - Topside USCG - United States Coast Guard W - Width

SPCC – Section 1 – Page 10

SPCC – Section 1 – Page 11

Certification of the Applicability of the Substantial Harm Criteria (EPA Form)

Facility Name: DFSP Point Loma Remediation System Facility Address: DLA Contractor (APTIM Federal Services, LLC) 199 Rosecrans Street, Building 604 Naval Base Point Loma, San Diego, CA 92106

1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons?

Yes No X

2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation within any aboveground oil storage tank area?

Yes No X

3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? For further description of fish and wildlife and sensitive environments, see Appendices I, II, and III to DOC/NOAA's "Guidance for Facility and Vessel Response Plans: Fish and Wildlife and Sensitive Environments".

Yes No X

4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance such that a discharge from the facility would shut down a public drinking water intake?2

2 For the purposes of 40 CFR part 112, public drinking water intakes are analogous to public water systems as described at 40 CFR 143.2(c).

Yes No X

5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a reportable oil discharge in an amount greater than or equal to 10,000 gallons within the last five years?

Yes No X

Certification: I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate, and complete.

Signature:

Name (print):

Title:

Date

SPCC – Section 1 – Page 12

SECTION 2

SPCC REGULATION – 40 CFR 112 (As amended 13 November 2009)

Citation-by-Citation Responses to SPCC Requirements

SPCC - Section 2 - Page i

SPCC REGULATION – 40 CFR 112 – Section 2 Table of Contents

Section Title / Topic of Section Page

Preface

PART 112 – OIL POLLUTION PREVENTION

Subpart A – Applicability, Definitions, and General Requirements For All Facilities and All Types of Oils

§ 112.1 General Applicability § 112.2 Definitions § 112.3 Requirement to Prepare and Implement a Spill Prevention, Control, and

Countermeasure Plan § 112.4 Amendment of Spill Prevention, Control, and Countermeasure Plan by Regional

Administrator § 112.5 Amendment of Spill Prevention, Control, and Countermeasure Plan by Owners or

Operators § 112.6 Qualified Facility Plan Requirements § 112.7 General Requirements for Spill Prevention, Control, and Countermeasure Plans § 112.7(a) General Plan Requirements § 112.7(a)(1) General Requirements § 112.7(a)(2) Deviations from Plan Requirements § 112.7(a)(3) Facility Characteristics That Must be Described in the Plan § 112.7(a)(4) Spill Reporting Information in the Plan § 112.7(a)(5) Emergency Procedures § 112.7(b) Fault Analysis § 112.7(c) Secondary Containment § 112.7(d) Deviations from Secondary Containment Requirements (Contingency Planning) .. 4 § 112.7(e) Inspections, Tests, and Records § 112.7(f) Employee Training and Discharge Prevention Procedures § 112.7(g) Security (Excluding Oil Production Facilities) § 112.7(h) Loading/Unloading (Excluding Offshore Facilities) § 112.7(i) Brittle Fracture Evaluation § 112.7(j) State Rules § 112.7(k) Qualified Oil-Filled Operational Equipment

Subpart B – Requirements for Petroleum Oils and Non-Petroleum Oils, Except Animal Fats and Oils and Greases, and Fish and Marine Mammal Oils; and Vegetable Oils (Including Oils from Seeds, Nuts, Fruits, and Kernels)

§ 112.8 Spill Prevention, Control, and Countermeasure Plan Requirements for Onshore Oil Production Facilities (Excluding Production Facilities)

§ 112.8(a) General Requirements – Onshore Facilities (Excluding Production Facilities) § 112.8(b) Facility Drainage § 112.8(b)(1) Diked Storage Area Drainage § 112.8(b)(2) Diked Storage Areas – Valves Used; Inspection of Retained Stormwater § 112.8(b)(3) Drainage Into Secondary Containment; Areas Subject to Flooding § 112.8(b)(4) Diversion Systems § 112.8(b)(5) Facility Drainage Systems/Lift Stations § 112.8(c) Bulk Storage Containers

SPCC - Section 2 - Page ii

SPCC REGULATION – 40 CFR 112 – Section 2 Table of Contents

Section Title / Topic of Section Page

§ 112.8(c)(1) Construction of and Materials Used for Containers § 112.8(c)(2) Secondary Containment – Bulk Storage Containers § 112.8(c)(3) Drainage of Rainwater § 112.8(c)(4) Completely Buried Tanks; Corrosion Protection § 112.8(c)(5) Partially Buried or Bunkered Tanks; Corrosion Protection § 112.8(c)(6) Integrity Testing § 112.8(c)(7) Leakage; Internal Heating Coils § 112.8(c)(8) Good Engineering Practice – Alarm Systems

§ 112.8(c)(9) Effluent Disposal Facilities § 112.8(c)(10) Correction of Tank Deficiencies § 112.8(c)(11) Mobile Containers § 112.8(d) Facility Transfer operations, Pumping, and Facility Process § 112.8(d)(1) Buried Piping – Facility Transfer Operations, Pumping, and Facility Process

(Onshore) (Excluding Production Facilities) § 112.8(d)(2) Terminal Connections § 112.8(d)(3) Pipe Supports § 112.8(d)(4) Inspection of Aboveground Valves and Piping § 112.8(d)(5) Vehicular Traffic § 112.9 Spill Prevention, Control, and Countermeasure Plan Requirements for Onshore Oil

Production Facilities § 112.10 Spill Prevention, Control, and Countermeasure Plan Requirements for Onshore Oil

Drilling and Workover Facilities § 112.11 Spill Prevention, Control, and Countermeasure Plan Requirements for Offshore Oil

Drilling, Production, or Workover Facilities

Subpart C – Requirements for Animal Fats and Oils and Greases, and Fish and Marine Mammal Oils;

and for Vegetable Oils, Including Oils from Seeds, Nuts, Fruits and Kernels

§ 112.12 Spill Prevention, Control, and Countermeasure Plan Requirements for Onshore Facilities (Excluding Production Facilities)

SPCC - Section 2 - Page 1

SPCC REGULATION – 40 CFR 112

Citation-by-Citation Responses to SPCC Requirements

Preface

The following section sequentially lists responses to the SPCC requirements of 40 CFR 112, as amended 13 November 2009 (effective 14 January 2010), and references pages where pertinent information is located in the Plan. Adhering to this sequential format allows Plan users to locate regulatory-specific information within the Plan rapidly.

Part 112 – OIL POLLUTION PREVENTION

§ 112.1 ~ General Applicability

The SPCC requirements are applicable to DLA’s DFSP Point Loma Remediation System because the aggregate aboveground oil storage capacity (including all containers and operating equipment 55 gallons or greater in capacity) exceeds 1,320 gallons and the facility is a non-transportation-related facility engaged in the recovery of LNAPL and treatment of TPH-contaminated groundwater which due to its location could reasonably be expected to discharge oil (recovered LNAPL) in or upon the navigable waters of the United States should a catastrophic event, system failure or other occurrence result in a spill.

Potentially, the navigable waters of the United States could be impacted if a discharge occurred is the San Diego Bay, located east of the system. The shortest route to the bay is approximately 575 feet.

§ 112.2 ~ Definitions

Not applicable; no response required.

§ 112.3 ~ Requirement to Prepare and Implement a Spill Prevention, Control, and Countermeasure Plan

This Plan was prepared in accordance with § 112.7. A licensed Professional Engineer reviewed and certified the Plan adequate for DFSP Point Loma Remediation System on April 13, 2018. Refer to Section 1, Page 9 for the Professional Engineer Certification. The authority to commit resources for implementation of this Plan lies with the owner, DLA. Refer to Section 1, Page 9 for Management Approval of SPCC Plan.

§ 112.4 ~ Amendment of Spill Prevention, Control, and Countermeasure Plan by Regional Administrator

DFSP Point Loma Remediation System has neither discharged more than 1,000 gallons of oil in a single event, nor discharged more than 42 gallons of oil in each of two events in any 12-month period into a navigable waterway, since inception. Therefore, no report to EPA Regional Administrator, state, or local authorities, is required.

§ 112.5 ~ Amendment of Spill Prevention, Control, and Countermeasure Plan by Owners or Operators

DLA must amend this Plan within six months when there is a change in facility design, construction, operation, or maintenance that could affect the potential for discharge. The SPCC Program Manager /

SPCC - Section 2 - Page 2

NBPL IEPM must also conduct a complete review and evaluation of this Plan every five years and state (i.e., document in writing) whether or not a revision or amendment is necessary. Five-Year Plan review tracking is shown on Section 1, Page 9.

Non-technical changes made by the installation will not require certification by a PE. Any technical changes (typically made by the PE or an agent of the PE) would require certification by the PE.

Therefore, PE certification is only needed when technical changes to the Plan have occurred. This Plan has been amended (SPCC Plan Amendment Number 1), because additional treatment equipment and piping was installed at the facility that affects the potential for discharge. The amendment to this Plan is technical and requires certification by a PE. For both non-technical and technical amendments, refer to Section 1, Page 13, where listing and certifications of amendments are shown, as applicable.

§ 112.6 ~ Qualified Facility Plan Requirements

Not applicable; the aggregate aboveground storage capacity of the DFSP Point Loma Remediation System exceeds 10,000 gallons thus DFSP is not a “Qualified Facility.”

§ 112.7 ~ General Requirements for Spill Prevention, Control, and Countermeasure Plans

This Plan was prepared in accordance with good engineering practices, in writing, following the sequence specified in § 112.7. The Plan has the full approval of management at a level of authority to commit the necessary resources to implement the Plan. Refer to Section 1, Page 9 for the Management Approval of this SPCC Plan.

§ 112.7(a) ~ General Plan Requirements

Not applicable; no response required.

§ 112.7(a)(1) ~ General Requirements

Not applicable; no response required.

§ 112.7(a)(2) ~ Deviations from Plan Requirements

DFSP Point Loma Remediation System may deviate from some of the requirements of 40 CFR 112, providing the reason for nonconformance can be adequately explained, and equivalent environmental protection is provided.

There is a deviation written in this Plan for the requirements of Part 112. The deviation consists of complying with the 40 CFR 112.8(c)(6) for the integrity testing requirements for aboveground storage containers using a monitoring and inspection program for visual integrity. Reasons for the deviation and supplemental testing methods are described further under the response to §112.8(c)(6).

§ 112.7(a)(3) ~ Facility Characteristics That Must be Described in the Plan

A facility diagram (Figure A-1) depicting the DFSP Point Loma Remediation System location has been included in Section 4, Appendix A. The facility diagram is designed to be used in conjunction with more detailed individual site maps included in Section 3, that depict the inspected Groundwater Recovery Compound, Space and Naval Warfare Systems Command (SPAWAR) Transfer Compound, Remediation Process Compound in greater

SPCC - Section 2 - Page 3 detail.

Discharge prevention measures including procedures for routine handling of LNAPL (recovery, storage, unloading, and facility transfers, etc.) are covered in Section 3 of this Plan, as well as Appendix E – Oil Spill Prevention Operating Procedures.

The discharge or drainage controls such as secondary containment around containers and other structures, equipment, and procedures for the control of a discharge are discussed individually for sites and containers in Section 3, as well as Appendix C – Inspection Checklists.

Countermeasures for discharge discovery, response, and cleanup (both the facility’s capability and those that might be required of a contractor) are found in the NBPL Integrated Contingency Plan (ICP). First responders required actions are summarized in the “Red Plan” portion of the ICP.

Methods of disposal of recovered materials are in accordance with applicable federal, state, and local requirements. Treated groundwater is disposed of via the permitted sanitary sewer connection (Connection 220), or reused at the facility.

Contact lists and phone numbers for the facility response team, National Response Center, cleanup contractors for response, and all appropriate federal, state, and local agencies that must be contacted in case of a spill are provided in the NBPL ICP Red Plan. Refer to Section 4, Appendix D.

§ 112.7(a)(4) ~ Spill Reporting Information in the Plan

In the event of a discharge, information and procedures for reporting the discharge must be readily available. This information and these procedures have already been developed and documented in the NBPL ICP, and summarized in the Red Plan portion of the ICP. (The Red Plan is designed to be utilized for initial response actions.) The reporting procedures can be found in the Oil and Hazardous Substance Discharge Telephone Report Sheet, which is included on page 28 of the Red Plan. This report sheet fulfills the requirements of § 112.7(a)(4). A copy of the NBPL ICP Red Plan is retained on site in Building 604.

§ 112.7(a)(5) ~ Emergency Procedures

Procedures that are to be followed in the event of a discharge must be described so that they are readily usable in an emergency. These procedures have already been developed and documented in the NBPL ICP, and summarized in the Red Plan. Refer to Section 4, Appendix D.

This Red Plan fulfills the requirements of § 112.7(a)(5), and contains procedures, checklists, phone numbers, general information, and maps. The full Emergency Response Action Plan (ERAP) (not included in this SPCC Plan) provides further detail on emergency response actions, beyond initial response.

§ 112.7(b) ~ Fault Analysis

For fault analysis information, including information on potential spill direction, rate of flow, and total quantity of oil that can be discharged for each type of major equipment failure for a specific

SPCC - Section 2 - Page 4 site or container, refer to Section 3 of this Plan.

Section 4, Appendix F contains the fault analysis criteria for Spill Rate, Quantity, and Pathway Estimation.

§ 112.7(c) ~ Secondary Containment

Bulk storage containers within the DFSP Point Loma Remediation System are generally either double-walled or have secondary containment large enough to hold the largest container plus sufficient freeboard to allow for precipitation. In the site-specific write-ups in Section 3, the secondary containment structures of unsheltered single-walled ASTs have been checked to ensure containment of 100 percent of the contents of the largest tank plus additional freeboard to accommodate the 3.5 inches (24 hour) precipitation of the historical San Diego, California 25-year storm event.

For secondary containment information for a specific site or container, refer to Section 3 of this Plan. Specifically, refer to the “Secondary Containment” heading in Table 3-1 for the container in question. For inspection and operational information, refer to Section 4, Appendix C and Appendix E, respectively.

§ 112.7(d) ~ Deviations from Secondary Containment Requirements (Contingency Planning)

DFSP Point Loma Remediation System currently has no deviations from the secondary containment requirements; however, future operations may deviate from secondary containment requirements if containment structures or pieces of equipment are determined to be not practicable.

A clear explanation of why such measures are not practicable will be provided in a Plan amendment, should this become necessary. However, the reason for nonconformance must be justified, and alternate methods of ‘equivalent environmental protection’ must be provided. Any such deviations will be documented and included in a technical amendment at the time of implementation.

§ 112.7(e) ~ Inspections, Tests, and Records

Records of inspections and tests of bulk storage containers, signed by the appropriate supervisor or inspector, must be kept with the Plan for at least three years. Records of inspections and tests kept under usual and customary business practices (including construction records, inspection history, and repair / alteration history) are also acceptable.

The site (Appendix A-1) maintains inspections, tests, and records including the location of inspection records at the site office. General inspection checklist examples can be found in Section 4, Appendix C.

§ 112.7(f) ~ Employee Training and Discharge Prevention Procedures

Oil-handling personnel must be adequately trained at least annually. All DFSP Point Loma Remediation System contractor employees whose jobs involve the storage or handling of POLs will receive appropriate spill control training as required by 40 CFR 112. Initial and follow-up training requirements are listed below:

The operation and maintenance of equipment to prevent the discharge of oil.

SPCC - Section 2 - Page 5

Discharge procedure protocol.

Applicable pollution control laws, rules, and regulations, typically.

General facility operation, maintenance, and inspection procedures.

Contents of the SPCC Plan.

Contents of the NBPL ICP and Red Plan.

Discussion of any recent discharges, failures, or malfunctions, and lessons learned as a result.

Discussion of any recently developed precautionary measures.

DFSP Point Loma Remediation System Contractor Supervisors provide onsite training to operators of the tanks on a monthly basis. Procedures for handling POL containers are included in Section 4, Appendix E “Oil Spill Prevention Operating Procedures” of this Plan.

§ 112.7(g) ~ Security (Excluding Oil Production Facilities)

NBPL Base Security provides 24-hour surveillance to ensure perimeter and internal security, greatly reducing the likelihood of leaks or spills caused by unauthorized tampering or vandalism.

Furthermore, all areas at DFSP Point Loma Remediation System that store significant amounts of recovered LNAPL or fuel-related materials are secured by fencing. The following additional security precautions shall be observed, as practical:

All unattended valves under positive pressure are either locked in the closed position or enclosed in a locked area when not required to be open.

All unattended storage areas are locked. Storage areas opening only into attended work areas will be considered attended.

All outside storage areas are adequately lighted to discourage vandalism and to aid in the early detection and cleanup of spills.

As indicated in Section 1 of this Plan, the responsibilities of DFSP Point Loma Remediation System contractor operators with respect to this SPCC Plan include:

Inspection of security systems, such as land and water access control, locked storage areas, lighting, fencing, and traffic control, to ensure that spills do not result from vandalism or unauthorized entry.

Visual inspection of vehicles that contain fuel oil entering DFSP Point Loma Remediation System sites, for leaks and any obvious mechanical deficiencies that could cause a spill event or accident.

DFSP Point Loma Remediation System contractor operators receive training in inspection procedures to be followed, and routine spill and equipment patrols ensure adequate precautions are in place.

For security information for a specific site or container, refer to Section 3 of this Plan. Specifically, refer to the “Security” heading for the site in question. [Security measures, such as fencing or lighting, may be site-specific features, container-specific features, or both.]

§ 112.7(h) ~ Loading/Unloading (Excluding Offshore Facilities)

One truck-loading pad was installed in 2016 to capture spills during loading of recovered LNAPL.

The truck-loading pad is located south of the upper treatment pad within the Remediation Processing Compound. Refer to Section 3 of this Plan for more site-specific information.

SPCC - Section 2 - Page 6

§ 112.7(i) ~ Brittle Fracture Evaluation

There are no field-constructed tanks in the DFSP Point Loma Remediation System.

§ 112.7(j) ~ State Rules

There are not more stringent applicable state rules, regulations, and guidelines pertaining to discharge prevention and containment procedures than those found in Part 112; there are no additional requirements for California or for San Diego County, i.e., California adopted the federal regulation in regards to the state SPCC Plan requirements. The County of San Diego acts as the Certified Unified Program Agency (CUPA) who will be inspecting under the Aboveground Petroleum Storage Act (APSA) program.

§ 112.7(k) ~ Qualified Oil-Filled Operational Equipment

The owner or operator of a facility with oil-filled operational equipment that meets the qualification criteria in paragraph (k)(1) of this sub-section may choose to implement for this qualified oil-filled operational equipment the alternate requirements as described in paragraph (k)(2) of this sub-section in lieu of general secondary containment required in paragraph (c) of this section.

In the case of DLA for the DFSP Point Loma Remediation System, this system does meet the qualification criteria in paragraph (k)(1) for oil-filled operational equipment and thus does not need to have secondary containment for the qualified oil-filled operational equipment (there are no oil-filled operational equipment in this system). Instead, the owner or operator of the NBPL facility with qualified oil-filled operational equipment will perform monthly inspections or monitoring to detect equipment failure and/or discharge. In the case of electrical oil-filled equipment such as transformers and switches, NAVFAC SW Public Works inspects and monitors all of their equipment monthly.

Also, this SPCC Plan functions as a separate document, but is also an annex to the NBPL ICP which outlines a written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful.

There is no qualified oil-filled operational equipment in the DFSP Point Loma Remediation System.

§ 112.7(l) Qualification Criteria—Reportable Discharge History:

Not applicable; no response required.

§ 112.8 ~ Spill Prevention, Control, and Countermeasure Plan Requirements for Onshore Oil Production Facilities (Excluding Production Facilities)

The DFSP Point Loma Remediation System is an onshore facility engaged in recovering, storing, and transferring LNAPL. Consequently, the requirements of § 112.8 are applicable to the DFSP Point Loma Remediation System.

SPCC - Section 2 - Page 7

§ 112.8(a) ~ General Requirements – Onshore Facilities (Excluding Production Facilities)

DFSP must follow the general requirements of § 112.7, and must follow the specific discharge and prevention procedures of § 112.8.

§ 112.8(b) ~ Facility Drainage

In addition to the following § 112.8 (b) requirements, refer to the Construction Storm Water Permit covering DFSP Point Loma Remediation System installation activity for allowable storm water draining and the construction Storm Water Pollution Prevention Plan.

§ 112.8(b)(1) ~ Diked Storage Area Drainage

Diked secondary containment areas must not automatically empty when rainwater accumulates. Captured rainwater must be inspected prior to emptying to ensure no POL will be discharged. Secondary containment dikes, berms, curbing, or walls that have holes or pipes installed to allow for easy drainage of captured rainwater must be fitted with valves (refer to § 112.8(b)(2)). Secondary containment without drainage holes or pipes may use pumps, ejectors, or other means to remove captured rainwater, provided they are manually activated.

No secondary containment of the DFSP Point Loma Remediation System currently has holes or pipes for easy drainage; all containment drainage must be manually activated.

For secondary containment drainage for a specific site or container, refer to Section 3 of this Plan. For secondary containment inspection and after storm event procedures refer to Section 4, Appendix C.

§ 112.8(b)(2) ~ Diked Storage Areas – Valves Used; Inspection of Retained Stormwater

Secondary containment dikes, berms, curbing, or walls that have holes or pipes installed to allow for easy drainage of captured rainwater must be fitted with watertight manual open-and-closed valves. Lockable valves are highly preferable, since they will greatly improve the likelihood that the condition of the captured rainwater is inspected before emptying, and that the valve is closed upon completion of emptying.

Diked secondary containment areas at the DFSP Point Loma fuel terminal adhere to these requirements. No secondary containment of the DFSP Point Loma Remediation System currently has holes or pipes for easy drainage; all containment drainage must be manually activated.

For secondary containment drainage for a specific site or container, refer to Section 3 of this Plan. For secondary containment inspection and after storm event procedures refer to Section 4, Appendix C.

§ 112.8(b)(3) ~ Drainage Into Secondary Containment; Areas Subject to Flooding

Facility drainage from undiked areas with a potential for discharge must be designed to flow into catchment basins, ponds, or lagoons. Examples of undiked areas include areas where

SPCC - Section 2 - Page 8 single-walled piping is located outside containment walls, or where tank truck discharges may occur outside loading areas.

There are no undiked areas with a potential for discharge in the DFSP Point Loma Remediation System. All below-grade piping is double-walled.

§ 112.8(b)(4) ~ Diversion Systems

In instances where facility drainage from undiked areas with a potential for discharge is not designed to flow into a catchment, the final discharge of all ditches inside the facility should be equipped with a diversion system.

There are no undiked areas with a potential for discharge in the DFSP Point Loma Remediation System. All below-grade piping is double-walled.

§ 112.8(b)(5) ~ Facility Drainage Systems/Lift Stations

Redundancy in “lift” pumps is required where pump transfer is needed to facilitate continuous treatment of drainage waters in multiple treatment units.

The Facility drainage system is not equipped with lift stations and is under the jurisdiction of NBPL. The four sedimentation basins in place at the tank facility complex are not equipped with lift stations.

The DFSP Point Loma Remediation System does not have lift stations nor sediment basins.

§ 112.8(c) ~ Bulk Storage Containers

§ 112.8(c)(1) ~ Construction of and Materials Used for Containers

Oil storage containers at the DFSP Point Loma Remediation System are compatible with the oil being stored. Generally, welded steel drums conform to DOT specifications and ASTs conform to UL standard 142 specifications are used for storing the TPH-impacted groundwater and recovered LNAPL. Operating equipment, such as utility owned transformers or electrical switches, are typically constructed of welded steel.

§ 112.8(c)(2) ~ Secondary Containment – Bulk Storage Containers

Bulk storage containers at DFSP Point Loma Remediation System are generally…