B08_Solicitation_Attachment4_SpillPreventionPlan.pdf

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MANAGEMENT APPROVAL

The management and staff at Yosemite National Park (park) are committed to the prevention of discharges of oil to navigable waters and the environment. Management and staff maintain the highest standards for Spill Prevention Control and Countermeasure (SPCC) through regular review, updating, and implementation of this SPCC Plan, Management and staff will commit adequate resources to carry out all provisions of this SPCC Plan.

Authorized Park Representative:

Don L. Neubacher

Print Name

Superintendent

Title

April 6, 2016

Date

SPILL PREVENTION, CONTROL AND COUNTERMEASURE

COMPLIANCE INSPECTION PLAN

REVIEW PAGE

In accordance with 40 CFR 112.5 (b), a review and evaluation of the Spill Prevention, Control and Countermeasure (SPCC) Plan is conducted at least once every five years. Completion of the review and evaluation will be recorded in the table below. The park will amend the SPCC Plan within six months of the review or evaluation to include more effective prevention and control technology if: 1) such technology will significantly reduce the likelihood of a spill event from the facility, and 2) if such technology has been field proven at the time of review. Any technical revisions of the SPCC Plan resulting from this review will be certified by a Professional Engineer (PE), and implementation of the amendments will occur within six months.

The SPCC Plan will also be amended and certified by a PE within six months after a change in the facility design, construction, operation, or maintenance that materially affects the facility's potential to discharge oil into or upon the navigable waters of the United States or adjoining shorelines.

In making an entry in the table below, the signatory is certifying that he or she has completed a review and evaluation of the SPCC Plan for the park on the date shown and has indicated in the column marked "Sections Containing Revisions" whether the SPCC Plan will be amended as a result. In this column, the sections of the SPCC Plan that will be revised are identified by section number. If revisions are not necessary as a result of the review, the notation "SPCC Plan will not be amended" will be provided.

Review

Date Sections Containing Revisions

Revision Complete Date

Signature

TABLE OF CONTENTS

MANAGEMENT APPROVAL

CERTIFICATION BY PROFESSIONAL ENGINEER

REVIEW PAGE

TABLE OF CONTENTS

SPCC RULE CROSS-REFERENCE

1. INTRODUCTION

1.1. Applicability

1.1.1. Federal Regulatory Requirements

1.1.2. California Requirements

1.2. Definitions

1.3. Facility Information

1.3.1. Facility Location

1.3.2. SPCC Plan Roles and Responsibilities

1.3.3. Additional Park Information

1.4. SPCC Compliance Packet

2. OIL STORAGE INFORMATION

2.1. Oil Storage Operations

2.1.1. Gasoline

2.1.2. Diesel Fuel

2.1.3. Number 2 Fuel Oil (Heating Oil)

2.1.4. Number 1 Fuel Oil (Kerosene)

2.1.5. Bio-Diesel

2.1.6. Miscellaneous Oil Storage

2.2. Oil Storage Capacity

3. SPILL PREVENTION, CONTROL, AND COUNTERMEASURE

3.1. Past Spill History

3.2. Facility Drainage

3.2.1. Drainage from Oil Storage Tanks

3.2.2. Miscellaneous Oil Storage

3.3. Spill Response: Oil Spill Contingency Plan

3.3.1. Applicable Spill Response Regulations and Park Response Policy

3.3.2. Spill Response Command Structure

3.3.3. Spill Response and Cleanup Procedures

3.3.4. Internal and External Reporting Procedures

3.3.5. Arrangements with Local Authorities

3.3.6. Emergency Response Equipment and Materials

3.4. Fuel Delivery Loading / Unloading

3.4.1. Fuel Company Information

3.4.2. Park Staff

3.5. Inspections and Tests

3.5.1. UST Tests and Inspections

3.5.2. AST Tests and Inspections

3.5.3. Mobile and Portable AST Tests and Inspections

3.5.4. Other Integrity Testing

3.5.5. Other Observations

3.6. Site Security

3.7. Personnel Training

3.8. Recordkeeping

3.9. Amendments

APPENDICES

Certification of Applicability of Substantial Harm Criteria

SPCC Plan Compliance Packet

HOW TO USE THIS COMPLIANCE PACKET

FUEL TRANSFER PROCEDURES FOR PARK PERSONNEL FOR USTs AND ASTs

FUEL TRANSFER PROCEDURES FOR FUEL TRUCK DRIVERS

FUEL TRANSFER CHECKLIST

SECTION 4 - MONTHLY AST VISUAL INSPECTION LOG

SECTION 5 - ANNUAL INSPECTION LOG

SECTION 6 - MONTHLY DRUM STORAGE AREA VISUAL INSPECTION LOG

SECTION 7 - INSPECTION SAMPLES FROM CONTRACTOR

SECTION 8 - TRAINING LOG

SECTION 9 – SPILL RESPONSE AND CLEANUP PROCEDURES

SECTION 10 - SAMPLE SPILL NOTIFICATION MEMO

SECTION 11 - SAMPLE WARNING SIGN

SECTION 12 SPCC EMERGENCY PARK CONTACTS

SECTION 13 SPCC EMEGENCY OFF-SITE CONTACTS

SECTION 14 - CRITERIA FOR DETERMINING A REPORTABLE RELEASE

SECTION 15 - RELEASE REPORTING COMPLIANCE DOCUMENTATION LOG

SECTION 16 - INITIAL SPILL INFORMATION REPORT FORM

SECTION 17 - FEDERAL OIL SPILL REPORTING REQUIREMENTS

SPCC RULE CROSS-REFERENCE

The Spill Prevention, Control, and Countermeasure (SPCC) regulations (40 CFR 112) require that an SPCC Plan include information pertaining to each regulatory section, and that a cross reference mechanism describe where each section of the regulations is addressed within the SPCC Plan in the event that the plan is not organized in the same order as the regulations. To facilitate cross referencing by park employees, the table below includes the section number, section description, and regulatory citation.

Final SPPC Rule Description of Section Section Number

§ 40 CFR 112.7

General requirements for SPCC Plan for all facilities and oil types.

All

§ 40 CFR 112.7(a)

General requirements; discussion of facility’s conformance with rule requirements; deviations from SPCC Plan requirements; facility characteristics that must be described in the SPCC Plan; spill reporting information in the SPCC Plan; emergency procedures.

Sections 1.1, 1.3, and 3.3

§ 40 CFR 112.7(b) Fault analysis Section 3.1, § 40 CFR 112.7(c) Secondary containment. Section 3.2, Tables 1 to 3.

§ 40 CFR 112.7(d) Contingency planning Section 3.3

§ 40 CFR 112.7(e) Inspections, tests, and records. Section 3.5 and 3.8

§ 40 CFR 112.7(f) Employee training and discharge presentation procedures.

Section 2.1, 3.7, 3.8, and Appendix B

§ 40 CFR 112.7(g) Security (excluding oil production facilities). Section 3.6

§ 40 CFR 112.7(h) Loading/unloading (excluding offshore facilities). Section 3.4, Appendix B

§ 40 CFR 112.7(i) Brittle fracture evaluation requirements. Not Applicable

§ 40 CFR 112.7(j) Conformance with State requirements. Section 1.1.2.

§ 40 CFR 112.8

§ 40 CFR 112.12(a)

Requirements for onshore facilities (excluding production facilities).

Section 3.3

§ 40 CFR 112.8(a) § 40 CFR 112.12(a)

General and specific requirements. Section 3.3

§ 40 CFR 112.8(b) § 40 CFR 112.12(b)

Facility drainage. Section 3.2

§ 40 CFR 112.8(c) § 40 CFR 112.12(c)

Bulk storage containers. Sections 2.1

§ 40 CFR 112.8(d) § 40 CFR 112.12(d)

Facility transfer operations, pumping, and facilities process. Sections 3.4

§ 40 CFR 112.20 Facility response plans. Sections 3.3

1. INTRODUCTION

1.1. Applicability

1.1.1. Federal Regulatory Requirements

The purpose of this Spill Prevention, Control, and Countermeasure (SPCC) Plan is to establish procedures and commit resources to prevent the discharge of oil and hazardous substances in quantities that violate applicable water quality standards, cause a sheen upon or discoloration of the surface of navigable waters or adjoining shorelines, or cause sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines. The SPCC Plan also establishes countermeasures required to mitigate such discharges should they occur.

The tanks in Yosemite National Park that are regulated under the SPCC rule (40 CFR 112), and are therefore partially or fully covered under this SPCC Plan, include the following types of oil storage managed by the National Park Service (NPS):

Aboveground Oil Storage Tanks (AST) - Table 1 (55 gallons or larger in size)

Underground Oil Storage Tanks (UST) - Table 2 (55 gallons or larger in size)

Miscellaneous Portable Aboveground Oil Storage Areas - Table 3 (55 gallons or larger in size)

USTs regulated under 40 CFR 280 are not required to be fully covered under this SPCC Plan; however, aspects of these USTs are covered under portions of this SPCC Plan as required per regulation.

Specifically, the park operates one diesel UST which is applicable to this plan's discussions related to loading and unloading activities only. This tank is otherwise managed under 40 CFR 280 and the governing state agency.

For SPCC planning regulations to apply, a facility involved in the handling and/or consumption of oil must meet the following three criteria:

1. The facility must be non-transportation-related;

2. The facility must have an aggregate aboveground storage capacity greater than 1,320 gallons stored in 55-gallon containers or larger or a total underground storage capacity greater than 42,000 gallons; and

3. There must be a reasonable expectation of a discharge to navigable waters or adjoining shore lines of the United States (US).

The park fits this description because:

It meets the definition of a non-transportation facility, which includes public facilities that use, store, or consume oil or oil products;

The aggregate aboveground storage capacity is greater than 1,320 gallons; and

A spill at the park facilities could reasonably be expected to discharge into navigable waters.

Yosemite National Park is home to the Hetch Hetchy Reservoir, Lake Eleanor, and Tenaya Lake;

as well have numerous smaller lakes. The Tuoulumne River and the Merced River flow through Yosemite National Park, both rivers are designated Wild and Scenic in accordance with Public Law 90-542; 16 U.S.C. 1271 et seq.

In addition to the specific elements required under 40 CFR 112.7, this SPCC Plan and attachments address the following requirements of 40 CFR 112:

Operating procedures park staff implement to prevent oil spills;

Control measures installed or available to prevent a spill from entering navigable waters or adjoining shorelines; and

Countermeasures to contain, cleanup, and mitigate the effects of oil spills that impact navigable waters or adjoining shorelines of the US.

There are also several other ASTs, USTs, and containers located on park property that are not covered under this SPCC Plan. They are not included as part of this SPCC Plan because these tanks are managed, operated, and repaired by operators through a lease, concessionaire contract, memorandum of understanding (MOU), or other such agreement. The operators of these ASTs, USTs, and containers are responsible for addressing these oil sources under their own SPCC Plan. Due to the size of the park, an inventory of these tanks was not collected during the development of this SPCC Plan.

This SPCC Plan is not required to be filed with the US Environmental Protection Agency (EPA).

However, in the event that EPA inspectors request to see the SPCC Plan, a copy will be available for on-site review. The master copy of the SPCC Plan will be maintained at facilities management administrative building (aka “NPS Warehouse”) in El Portal, with the SPCC Coordinator. An additional copy of the SPCC Plan will be maintained at each maintenance office within the park, and at each fire station.

Park operations do not trigger "substantial harm" storage and handling criteria specified within 40 CFR

112.20. Therefore, park personnel are not required to prepare and submit a Facility Response Plan. To substantiate this assertion, a "Certification of Substantial Harm Determination Form" for the park is included as Appendix A.

1.1.2. California Requirements

The California Aboveground Petroleum Storage Act (APSA) tank facility requirements are applicable, as Yosemite National Park stores more than 1,320 gallons of petroleum-based oils on-site. The APSA tank facility requirements are found in California Health and Safety Code, Chapter 6.67, Section 25270.3, and mirror requirements for an SPCC facility under 40 CFR Part, with the additional administrative requirement of notification and fees to a local Unified Program Agency (UPA).

1.2. Definitions

Following are definitions relevant to this SPCC Plan. Definitions are based on federal regulations (40 CFR 112 and 40 CFR 280).

Abovegrouud Storage Tank (AST): Any tank that is used to contain an accumulation of regulated substances (including oil), with 90% or more of its volume (including the tank's pipes) existing above the surface of the ground. A tank situated on or above the surface of a floor in an underground area that may be readily inspected (i.e., a basement) is an AST.

Barrel: A standard barrel (abbreviated bbl) of crude oil or other petroleum product is 42 US gallons.

Facility: Any mobile or fixed onshore or offshore building, property, parcel, lease, structure, installation, equipment, pipe, or pipeline (other than a vessel or a public vessel) used in oil well drilling operations, oil production, oil refining, oil storage, oil gathering, oil processing, oil transfer, oil distribution, and oil waste treatment, or in which oil is used in another capacity, as described in Appendix A of 40 CFR 1121.

The boundaries of a facility depend on several site-specific factors, including but not limited to, the ownership or operation of buildings, structures, and equipment on the same site and types of activity at the site. Contiguous or non-contiguous buildings, properties, parcels, leases, structures, installations, pipes, or pipelines under the ownership or operation of the same person may be considered separate facilities.

Oil: Oil of any kind or in any form, including, but not limited to fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and, other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse; and oil mixed with wastes other than dredged spoil.

Discharge: Any spilling, leaking, pumping, pouring, emitting, emptying, or dumping of oil. This excludes discharges in compliance with a permit under section 402 of the Clean Water Act. For purposes of 40 CFR 113, the term "discharge" shall not include any discharge of oil that is authorized by a permit issued under section 13 of the River and Harbor Act of 1899 (33 U.S.C. 407).

Navigable Waters: Waters of the US, including territorial seas. These include all waters currently or previously used for interstate commerce, as well as interstate wetlands and intrastate lakes, rivers, streams, and intermittent streams. As applied, the definition is very broad and includes most inland water bodies and US coastal areas even if they are small and are not used for shipping. The full definition of navigable waters is found at 40 CFR 112.2, Navigable Waters.

Underground Storage Tank (UST): Any tank that is used to contain an accumulation of regulated substances (including oil), with 10% or more of its volume (including the tank's pipes) existing beneath the surface of the ground. A tank in situated on or above the surface of a floor in an underground area that may be readily inspected (i.e., a basement) is not a UST.

1.3. Facility Information

1.3.1. Facility Location

Yosemite National Park spans the eastern portions of Tuolumne County, Mariposa County, and Madera County in the central eastern portion of the State of California. The park covers an area of 747,956 acres and reaches across the western slopes of the Sierra Nevada mountain chain. The park has several entrances. The west entrance is located on Highway 140, approximately 30 miles east of the town of Mariposa. The south entrance is located on Highway 41, approximately 20 miles north of the town of Oakhurst. There are two north entrances is located off of Highway 120, also known as Tioga Road, approximately 30 miles west of the town of Groveland. Finally, there is one entrance, opened only seasonally on the east side of the park, on Highway 120, 10 miles west of the town of Lee Vining.

1.3.2. SPCC Plan Roles and Responsibilities

The management of this SPCC Plan for Yosemite National Park follows an approach that optimizes the utilization of existing park staff. According to federal regulations, a person must be designated to be accountable for discharge prevention and responsible for reporting to line management. The prevention portion of this SPCC Plan, which includes portions of the plan related to items such as oil storage inspections and annual training, will be completed by the park's existing maintenance division. The aspects of the SPCC Plan related to a spill response situation (control and countermeasures) will be handled through the trained personnel on the fire teams located at various districts throughout the park.

The specific key responsibilities for the park to properly implement this SPCC Plan are provided in the discussion that follows.

The Chief of the Facilities Management Division and the Chief Safety & Occupational Health Manager will serve as the overall SPCC Plan Co-Coordinators for Yosemite National Park. To implement this SPCC Plan, SPCC Plan Coordinators will be responsible for the following:

• Obtaining all applicable signatures for the SPCC Plan; SAFETY

• Distributing, posting, and collecting (upon completion) the applicable inspection forms from the

Compliance Packet in Appendix B;SAFETY

• Coordinating and conducting annual SPCC training;SAFETY

• In coordination with the park’s Division of Visitor and Resource Protection: Determining the responsibilities and procedures for the park’s Emergency Communication Center in regards to oil spill response procedures and initial notifications;SAFETY and STRUCTURAL FIRE

• In coordination with the park’s Division of Visitor and Resource Protection: Maintaining a list of park employees who are trained and qualified as emergency responders for incidents involving oil spills;SAFETY

• Maintaining SPCC records for a minimum of three years;SAFETY

• As necessary, contacting the appropriate agencies and making initial and follow-up notifications in coordination with Department of the Interior (DOI) Solicitor's Office and/or NPS Attorney- Advisor;SAFETY

• Acting as site liaison with government agencies in coordination with DOI and the NPS;SAFETY

• Performing spill reporting, as necessary, following the procedures provided in this SPCC

Plan;SAFETY

• Ensuring routine monthly, quarterly and annual inspections are being completed by verifying on a quarterly basis for the first year, then at a park-determined interval (e.g., annually) each year thereafter; and

• Coordinating any SPCC amendments or required five-year reviews for the SPCC Plan.

The role of Assistant SPCC Coordinators for the park will be assigned to the Branch Chiefs of the four branches of the park’s Facility Management Division: Utilities, Buildings & Grounds, Roads & Trails, and Design & Engineering. The Assistant SPCC Coordinators will be responsible for operating and maintaining the oil storage containers within their assigned responsibilities on the park grounds. The Assistant SPCC Coordinators will implement the portion of this plan related to spill prevention, primarily through routine inspections and preventive maintenance. Responsibilities for the Assistant SPCC Coordinators will include the following:

• Attending annual SPCC training;

• Ensuring the attendance of all oil-handling employees (beyond the level of simply dispensing fuel to park fleet vehicles) at annual SPCC training;

• Ensuring that routine monthly and annual inspections are performed on the respective oil storage containers listed by in Tables 1-3 (completed forms are to be turned in to the designated SPCC Coordinator);

• Coordinating or providing loading/unloading oil transfer oversight for transfers completed by outside fuel vendors;

• Coordinating maintenance to tank system components as needed;

• Notifying the park Emergency Communications Center of any observed oil spills in order to start the emergency spill response procedure;

• Providing support to the emergency oil/spill response team as needed.

MGrissom Highlight

The park will utilize the Incident Command System (ICS) to respond to oil spills. The Incident Commander (IC) will generally be the senior Fire Official on scene. The IC will establish the command structure, and request additional resources as needed. Responsibilities of the IC will include the following:

Leading the efforts of the Oil Spill Response Team (OSRT). The OSRT is composed of those who are trained and qualified as emergency responders for incidents involving oil.

Ensuring that initial notifications have been completed and that the area is secure;

Coordinating emergency response efforts with other responding organizations as necessary;

Implementing the appropriate spill response operations and ensuring the use of appropriate personal protective equipment;

Ensuring the proper permitting and disposal of contaminated material;

Completing the Initial Spill Information Report in Section 15 of the Compliance Packet and providing it to the SPCC Coordinator for spill reporting purposes;

Following the procedures provided for this park' s oil spill contingency plan for NPS tanks (Section 3.3 of this SPCC Plan)

A list of the other responsible facility personnel is located on the Emergency Contact List provided as Section 13 of the Compliance Packet.

1.3.3. Additional Park Information

The following is a summary of park information:

Facility Name: Yosemite National Park

Mailing Address: PO Box 577 Yosemite, CA 95338

Operator (Managing Agency): National Park Service Department of the Interior Washington, DC

Latitude/Longitude: 37.748751 N, 119.587206 W – Yosemite Valley

Phone Number: (209) 372-0200

Counties: Tuolumne County, CA Mariposa County, CA Madera County, CA

SPCC Co-Coordinators: Chief of Facilities Management Safety & Occupational Health Manager

Alternate SPCC Coordinators: Chief, Utilities Branch Chief, Roads & Trails Branch Chief, Buildings & Grounds Branch Chief, Design & Engineering Branch

Incident Command System (ICS) Coordinator: Chief Ranger

MGrissom Highlight

1.4. SPCC Compliance Packet

To assist park employees with their compliance obligations, a SPCC Compliance Packet is attached to this SPCC Plan as Appendix B. The purpose of the SPCC Compliance Packet is to simplify the compliance process for park employees. The SPCC Compliance Packet contains flow diagrams, forms, checklists, and other information that park employees will use to implement the SPCC Plan. Park employees will use the SPCC Compliance Packet documentation to perform inspections, keep records of training, and determine if a spill should be reported to a regulatory agency.

2. OIL STORAGE INFORMATION

2.1. Oil Storage Operations

Gasoline, diesel, heating oil, used oil, motor (engine) oil hydraulic oil, transmission fluid, two-cycle oil, unleaded gasoline, lubricating oil, and paint thinner are all used and stored at the park as described below.

Text descriptions of SPCC-regulated tanks are provided below.

2.1.1. Gasoline

Gasoline is used at the park to fuel park vehicles and equipment. Gasoline is not typically stored at park operated facilities, and instead, by management direction, staff is encouraged to use government fleet fueling cards at commercial and concessionaire gas station facilitations. When remote fueling of gasoline powered vehicles and equipment is required, portable vehicle mounted ASTs are used, and are addressed in this SPCC plan.

2.1.2. Diesel Fuel

Diesel fuel is typically used to power generators and emergency heating at the park.

2.1.3. Number 2 Fuel Oil (Heating Oil)

Number 2 Fuel Oil (Heating Oil) is not stored at park operated facilities in quantities greater than 55 gallons.

2.1.4. Number 1 Fuel Oil (Kerosene)

Number 1 Fuel Oil (Kerosene) is not stored at park operated facilities in quantities greater than 55 gallons.

2.1.5. Bio-Diesel

Bio-Diesel is not stored at park operated facilities in quantities greater than 55 gallons.

2.1.6. Miscellaneous Oil Storage

Miscellaneous oil is stored in 55-gallon drums, 150-gallon totes, and 275-gallon totes at various maintenance areas throughout the park. A list of these drum storage areas and their respective secondary containment measures is provided in Table 3. All drum storage areas have passive secondary containment already in place or active spill containment measures that have been determined to adequately provide secondary containment.

2.2. Oil Storage Capacity

The total oil storage capacity at park facilities is approximately 30,095 gallons, all of which is covered by this SPCC plan. This total quantity includes the oil storage inventory provided in Tables 1-3 of this SPCC Plan. Table 1 provides an inventory of the ASTs greater than 55 gallons in size. Table 2 provides an inventory of the USTs covered under the SPCC rule and managed in this SPCC Plan. Table 3 provides an inventory of the drum storage areas within the park.

Site maps showing the location of the tanks and miscellaneous oil storage are also included in Appendix C. Tables 1-3 also describe the oil storage container construction for NPS containers throughout the park.

Table 1: Yosemite National Park

Oil Storage Tank Inventory (ASTs)

Location AST ID Capacity

(gallons)

Contents Construction Material

Secondary Containment

Use

EL Portal Wastewater Treatment Facility EP-AST-1 4,000 Diesel Concrete Vault Secondary Catch Heating / Generator Fuel

Yosemite Valley Sub Station YV-AST-1 4,100 Diesel Steel Secondary Cath Generator Fuel

Total 8,100

Table 2: Yosemite National Park Oil Storage Tank Inventory (USTs)

Location UST ID Capacity

(gallons)

Contents Construction Material

Secondary Containment

Leak Detection / Overfill

Protection

Corrosion Protection

Use

Wawona Wastewater Treatment Facility

WA-UST-2 4,000 Diesel Steel / Fiberglass

Double-walled Interstitial Monitor 95% Flapper Valve

Sacrificial Anode

Heating / Generator Fuel

Yosemite Valley Housekeeping Camp

YV-UST-2 500 Diesel Steel / Fiberglass

Double-walled Interstitial Monitor 95% Flapper Valve

Sacrificial Anode

Generator Fuel

Yosemite Creek Lift Station

YV-UST-3 1,000 Diesel Steel / Fiberglass

Double-walled Interstitial Monitor 95% Flapper Valve

Sacrificial Anode

Generator Fuel

Yosemite Village Lift Station

YV-UST-4 1,000 Diesel Steel / Fiberglass

Double-walled Interstitial Monitor 95% Flapper Valve

Sacrificial Anode

Generator Fuel

Yosemite Village Clinic YV-UST-7 2,000 Diesel Steel / Fiberglass

Double-walled Interstitial Monitor 95% Flapper Valve

Sacrificial Anode

Heating / Generator Fuel

Yosemite Valley Wawona Tunnel Generator

YV-UST-8 560 Diesel Steel / Fiberglass

Double-walled Interstitial Monitor 95% Flapper Valve

Sacrificial Anode

Generator Fuel

El Portal Maintenance Facility

EP-UST-2 10,000 Diesel Concrete Vault

Double-walled Interstitial Monitor 95% Flapper Valve

Sacrificial Anode

Vehicle Fueling

Total 19,060

Table 3 Part 1: Yosemite National Park SPCC Regulated – Miscellaneous Oil Storage (Drum Storage Areas)

Location Container Type No.

Total

Capacity (gal)

Contents Floor /

Ground Material

Secondary Containment Type

Use

Hodgon Meadows Roads Locker #1

55 gallon drums 4 220 Asphalt Tack Oil

Metal Floor

Raised Metal Floor Plus Spill Kit

Equipment maintenance

Hodgon Meadows Roads Locker #1

55 gallon drums 2 110 Chevron Torque Fluid

Metal Floor

Raised Metal Floor Plus Spill Kit

Equipment maintenance

Hodgon Meadows Roads Locker #1

5 gallon pails 8 40 Synthetic Hydraulic Fluid

Metal Floor

Raised Metal Floor Plus Spill Kit

Equipment maintenance

Hodgon Meadows Roads Locker #1

55 gallon steel drum

1 55 Gear Oil Metal Floor

Raised Metal Floor Plus Spill Kit

Equipment maintenance

Hodgon Meadows Roads Locker #1

1 gal plastic containers

15 15 Engine Oil Metal Floor

Raised Metal Floor Plus Spill Kit

Equipment maintenance

Hodgon Meadows Roads Building 55 gallon steel drum

1 55 Diesel Fuel Wood Floor

Secondary Catch Containment

Emergency generator use

Tuolumne Meadows Waste Water Treatment Plant

150 gallon tote 1 150 Diesel Fuel Concrete Secondary Catch Containment

Emergency generator use

Tuolumne Meadows Waste Water Treatment Plant

150 gallon tote 1 150 Diesel Fuel Concrete Secondary Catch Containment

Emergency generator use

El Portal Waste Water Treatment Plant

55 gallon drum 1 55 Used Oil Concrete Containment Pallets Plus Spill Kit

Waste oil stored for disposal

Table 3 Part 2: Yosemite National Park SPCC Regulated – Miscellaneous Oil Storage (Drum Storage Areas)

Location Container Type No.

Total

Capacity (gal)

Contents Floor /

Ground Material

Secondary Containment Type

Use

El Portal Waste Water Treatment Plant

5 gallon buckets 12 60 Gear Oil Concrete Containment Pallets Plus Spill Kit

Equipment maintenance

El Portal Maintenance Machine Shop

275 gallon totes 2 550 Motor Oils Concrete Containment Pallets Plus Spill Kit

Vehicle and equipment maintenance

El Portal Maintenance Machine Shop

55 gallon drums 5 275 Motor Oils Concrete Containment Pallets Plus Spill Kit

Vehicle and equipment maintenance

El Portal Maintenance Machine Shop

55 gallon drums 3 165 Hydraulic Fluids

Concrete Containment Pallets Plus Spill Kit

Vehicle and equipment maintenance

El Portal Maintenance Machine Shop

55 gallon drums 3 165 Gear Oils Concrete Containment Pallets Plus Spill Kit

Vehicle and equipment maintenance

Wawona District Road Storage 55 gallon drum 2 110 Motor Oil Dirt Floor Containment Pallets Plus Spill Kit

Vehicle maintenance

Wawona District Road Storage 55 gallon drum 2 110 Gear Oil Dirt Floor Containment Pallets Plus Spill Kit

Vehicle maintenance

Wawona District Road Storage 55 gallon drum 1 55 Hydraulic Fluid Dirt Floor Containment Pallets Plus Spill Kit

Vehicle maintenance

Wawona Wastewater and Water Treatment Plan

55 gallon drum 1 55 Used Oil Concrete Containment Pallets Plus Spill Kit

Waste oil stored for disposal

Total 2,395

3. SPILL PREVENTION, CONTROL, AND COUNTERMEASURE

3.1. Past Spill History

No spills from NPS oil storage containers at the park had occurred within the five-year period before this SPCC Plan was developed.

A spill report form is included in Section 15 of the Compliance Packet. This form will be used to document any spills that may occur in the future.

3.2. Facility Drainage

3.2.1. Drainage from Oil Storage Tanks

This SPCC Plan must consider all potential sources of a release. A release of oil could take place at the following locations, for any of the following reasons:

Tank or associated piping, if in poor condition or if a rupture occurs;

Fill pipe, during delivery due to rupture or overfill;

Fuel delivery hose, due to rupture or leaks at joints to truck or fill pipe; and Fuel delivery truck, due to leaking or rupture.

A release of oil in any of these situations may be significant. In some cases, the land is flat and/or low and oil would pool or infiltrate into the ground where the tank is located instead of flowing in a specific direction to a receptor.

The most likely opportunity for a spill to occur is during the fuel delivery process. This includes instances of potential equipment failure of commercial tank trucks delivering oil to park-owned tanks. Therefore, this SPCC Plan provides inspection and assurance processes for fuel deliveries.

3.2.2. Miscellaneous Oil Storage

At numerous maintenance areas around the park, miscellaneous oil is stored within 55-gallon steel drums.

In most cases, the drums are either placed on secondary containment pallets, or in the oil room, which provides a secondary containment area (sunken room). Other drums either rely on a trench drain that leads to an oil-water separator containment system or active containment measures using absorbent materials to sufficiently control potential releases. See Table 3 for the secondary containment measure used for each of the park's drum oil storage areas. Absorbent materials are stored centrally at each of the park's oil storage locations.

3.3. Spill Response: Oil Spill Contingency Plan

Diversionary structures or secondary containment are in place where practicable. Considering the oil storage at the Park, the most likely occurrence of an oil spill would be during fuel delivery. Secondary containment could not be constructed for every location where a fuel delivery truck parks during filling procedures. Therefore, the Park has developed and implemented an Oil Spill Contingency Plan (Contingency Plan) as part of this Plan that meets EPA’s requirements. Where diversionary structures or secondary containment are not practicable, this Contingency Plan ensures that manpower, equipment, and materials are in place to expeditiously control and remove any harmful quantity of oil which has the potential to be discharged from the Park.

This Contingency Plan, as part of the park SPCC Plan, meets requirements specified in 40 CFR 112.7 (d) (2). In adopting this Contingency Plan, park management is making a written commitment of manpower, equipment, and materials required to expeditiously control and remove any harmful quantity of oil that has the potential to be discharged from the facility.

Information relevant to the Contingency Plan is contained in this section of the SPCC Plan and includes the following:

• Section 3.3. 1. - Applicable Spill Response Regulations and Park Response Policy;

• Section 3.3.2. - Spill Response Command Structure;

• Section 3.3.3. - Spill Response and Cleanup Procedures;

• Section 3.3.4. - Internal and External Reporting Procedures;

• Section 3.3.5. - Arrangements with Local Authorities; and

• Section 3.3.6. - Emergency Response Equipment and Materials.

3.3.1. Applicable Spill Response Regulations and Park Response Policy

EPA regulations (40 CFR 110) define a spill as the discharge of harmful quantities of oil into or upon the navigable waters of the US or adjoining shorelines. The Clean Water Act prohibits the discharge of oil into or upon navigable water in harmful quantities. "Harmful quantities" are defined as a discharge that violates applicable water quality standards or causes a sheen upon, or discoloration of, the surface of the water or the adjoining shorelines. Contaminated groundwater, which is also included in this definition, may also have the potential to seep, leach, or flow into navigable waters. Storm sewers are also considered a navigable waterway, since most storm sewers eventually discharge into a navigable waterway.

The Clean Water Act and the National Oil and Hazardous Substance Pollution Contingency Plan regulations describe the appropriate response to discharges of petroleum products from ASTs and other sources into navigable waters and the environment. Park management and staff commit to meeting those regulatory requirements through the implementation of established spill response and cleanup procedures, as an applicable situation requires.

Park management and staff commit to make every effort to prevent spills. Further, park staff members emphasize hazardous substance containment at the source to prevent any harmful amounts of oil from being discharged to a navigable waterway in any amount that may cause sheen on the surface.

3.3.2. Spill Response Command Structure

To assure the effectiveness of this Contingency Plan, park management has created the following personnel structure:

The park will utilize the Incident Command System (ICS) to respond to oil spills. The Incident Commander (IC) will generally be the senior Fire Official on scene. The IC will establish the command structure, and request additional resources as needed. The role of the IC may be redesignated to a qualified senior or higher-ranking official if the incident begins to have impacts such as traffic or extended closures to the public beyond the geographic point of the spill.

The Oil Spill Response Team is composed of those incident responders who are trained and qualified to safely respond to oil spill incidents;

Yosemite National Park has a Reciprocal Fire Protection Agreement or Mutual Aid Agreement with several of the local communities, and is part of the California Fire Assistance Agreement, which is coordinated by the California Office of Emergency Services. Through these agreements, Yosemite National Park and the Mariposa County Fire Department may mobilize Type 1 and Type 2 Hazmat teams to identify, evacuate, and contain a spill. Any emergency responses that exceed the resources or capacity of the Park and Mariposa County will be handled at the appropriate qualification level using the Incident Command system. Due to the unique cleanup requirements of individual spills, this may include coordinating cleanup or other responses through a qualified third-party contractor, determined on a case-by-case basis by the IC.

All park staff and volunteers are made aware that they are responsible for reporting oil spills immediately upon discovery; as such, they are critical staff in the facility spill response structure.

Fuel delivery contractors are capable of responding to incidental spills and have established emergency notification procedures to initiate response to non-incidental spills that could occur during fuel transfer operations. As such, they are also a part of the facility spill response structure.

3.3.3. Spill Response and Cleanup Procedures

Specific details of spill response and cleanup procedures are described in Appendix B, SPCC Plan Compliance Packet, and Sections 6-12.

For releases of oil, OSRT members will undertake necessary and appropriate initial abatement measures to control further releases and secure the site to protect human health and the environment. This response will consist of one of the following:

Active response for incidental spills of oil products: Active response will consist of control and clean-up of small spills or spills that the IC, in their professional judgment, determine can be safely handled given the training and resources available. To respond to these incidental spills, emergency equipment as described in Section 3.3.6 will be used.

Defensive response and professional spill response assistance for non-incidental spills of oil products: Non-incidental spills will first be handled by the park's fire crews, then outside departments or contractors, as needed.

The IC will notify the SPCC Coordinator, who will notify all regulatory agencies of reportable oil spills as required by applicable state or federal regulatory requirements discussed in Section 3.3.4 of this Plan and in Sections 13-17 of the Compliance Packet.

After a spill incident has occurred, OSRT members will complete the following activities:

Restock emergency supplies;

Test emergency equipment;

Properly decontaminate equipment and impacted area; and In the event of a reportable spill event, complete the Initial Spill Information Report in Section

15, and provide to the IC and SPCC Coordinator.

After a spill, the IC and SPCC Coordinator must review the incident and determine the cause. Depending upon the nature and severity of the release (e.g., a reportable release versus a very minor spill caused by overfilling), there should be a determination of the procedures and practices that should be revised to prevent similar incidents from reoccurring (see also Section 3.9 regarding Amendments to Plan, and Section 3.3.6 regarding Emergency Response Equipment and Materials).

3.3.4. Internal and External Reporting Procedures

The IC will notify the SPCC Coordinator immediately of any spills. The SPCC Coordinator will determine what non-emergency notifications are required. The SPCC Coordinator will also notify the NPS PWR EPM in the event of a spill.

If the spill is above incidental quantities (i.e., greater than twenty gallons), the NPS National Emergency Incident Coordination Center, Dispatch Center should also be notified at (888) 246-4335. Park staff should not delay notifying outside agencies if required.

EPA has established requirements to report spills to navigable waters or adjoining shorelines that may be harmful to public health, welfare, or the environment. EPA has determined that discharges of oil that meet these criteria include those that:

• Violate applicable water quality standards;

• Cause a film or sheen upon, or discoloration of, the surface of the water or adjoining shorelines; or

• Cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines.

The "Initial Information Oil Spill Notification" form contains information that will be useful when reporting the spill. It can also be used as the park's internal record of the spill. This form, along with other reporting requirements, is included as part of the Compliance Packet.

Park employees will have additional reporting requirements if they discharge more than 1,000 gallons of oil into or upon the navigable waters of the US or adjoining shorelines in a single spill event, or if they have at least two discharges of more than 42 gallons that require reporting to the NRC within any 12-month period. If this either of these occur, park staff must submit information to EPA Region 9 Administrator within 60 days of the time the facility becomes subject to this requirement. Information required to be reported to the Regional Administrator is listed in Section 13 of the Compliance Packet.

3.3.5. Arrangements with Local Authorities

Copies of this SPCC Plan will be shared with the counties, local fire agencies, the local hospitals, and contractors as requested or needed by them. In addition, park personnel will convene sessions to familiarize personnel from these organizations with details of this SPCC Plan or location and layout of the park oil storage facilities, if requested. Topics that may be covered include type of oil products used, the possibilities for release, the location of the fire equipment such as hydrants, and the location of spill control equipment at the park.

3.3.6. Emergency Response Equipment and Materials

Employees will respond to incidental spills only. In the event of a non-incidental spill, outside assistance will be notified. Response efforts that exceed the capacity of Yosemite and Mariposa County will be handled at the appropriate qualification level using the Incident Command system. Due to the unique cleanup requirements of individual spills, this may involve coordinating the actual cleanup efforts or other responses through a qualified third-party contractor, determined on a case-by-case basis by the IC.

Large spill response kits are located at every fire station within the park, all maintenance facilities where oil handling occurs, and any areas of fuel storage. Small spill response kits are located in most vehicles within the park’s Protection Division, all vehicles involved in oil or fuel transportation, and all pieces of heavy equipment.

3.4. Fuel Delivery Loading / Unloading

Most releases occur from spills during the fuel delivery process. Spills may occur at the fill pipe when the delivery truck's hose is disconnected. Although these spills are usually small, repeated small releases can cause significant environmental problems. Human error causes most spills, but following standard tank filling practices personnel can minimize the potential for spills. For example, the fuel delivery driver must make sure there is room in the tank to be filled for the delivery, and the delivery driver and park staff must also observe the delivery at all times. According to EPA, if fuel truck delivery drivers follow established standard practices, nearly all spills could be prevented. For this reason, federal UST regulations require that operators follow standard filling practices. Standard filling practices are not required by regulation for AST filling. However, it is recommended that park personnel follow the same practices and ensure that fuel delivery operators follow standard filling practices (as described in Section 2 of the attached Compliance Packet in Appendix B) for the park's ASTs and USTs.

Park personnel are encouraged to observe all fuel transfers. To ensure that all fuel transfer procedures are properly adhered to, park personnel or the fuel delivery driver will complete the checklist included as Section 3 of the Compliance Packet. Fuel company personnel will also be required to immediately report any incident that occurs during fueling to the NPS Dispatch Center.

3.4.1. Fuel Company Information

The following fueling company provides fuel to various locations throughout the park. Below is a description of the fuel delivery company and their fueling and emergency procedures. In the event that park staff obtain new vendors (those not listed below), staff will ensure that the contract with the vendor will include components for fuel transfer operations to avoid spills and for emergency response steps for spills that may occur. In addition, staff will append the new contract information, as described above, to this plan so that appropriate staff members have access to information about the fuel company and requirements.

Ahntech Inc Address: 3333 Camino Del Rio Suite 120

San Diego, CA 92108 Phone: (619) 516-5900

Chase’s Foothill Petroleum Address: 4632 CA-49

Mariposa, CA 95338 Phone: (209) 966-3314

3.4.2. Park Staff

Park staff deliver diesel throughout the park to various equipment using truck-mounted ASTs, although the park typically only uses a few of these trucks actively. The dispensers on each tank have automatic shut-off nozzles to prevent overflow. No secondary containment is used for the pickup-truck-mounted

ASTs; however, absorbent materials are carried on the trucks with the tanks to use in the event of a spill.

Procedures are as follows:

1. Park staff stick the tank before adding fuel to the portable tank to ensure no overfills.

2. Park staff fill the tank to 90% capacity.

3. Trucks are equipped with absorbent pads and socks.

4. Staff members unload the fuel to the equipment or tank by connecting the hose and dispenser from the portable tank to the fill port of the equipment or tank. Staff members ensure that all connections are secure prior to unloading fuel.

5. Before fueling is complete, staff members ensure all liquid is out of the hose. Upon completion, the hose is disconnected, and the tank is then transported back to the maintenance area to be stored.

6. The truck-mounted AST will be stored at empty or as close to empty as reasonably possible.

Park staff occasionally use portable generators or portable light units to conduct work around the park.

No secondary containment is used for these portable units that include belly tanks with varying capacities, however, absorbent materials are carried on the trucks that transport these portable units to use in the event of spill. Procedures are as follows:

1. Park staff stick the tank before adding fuel to the portable tank to ensure no overfills.

2. Park staff fill the tank to 90% capacity.

3. Trucks are equipped with absorbent pads and socks.

4. Staff members unload the fuel to the equipment or tank by connecting the hose and dispenser from the portable tank to the fuel port of the equipment or tank. Staff members ensure that all connections are secure prior to unloading fuel.

5. Before fueling is complete, staff members ensure all liquid is out of the hose. Upon completion, the hose is disconnected, and the tank is then transported back to the maintenance area to be stored.

6. The portable unit ASTs will be stored at empty or as close to empty as reasonably possible.

For additional information related to park staff fueling procedures, refer to Sections 1-3 of the Compliance Packet.

3.5. Inspections and Tests

The SPCC Coordinator designates Park staff to conduct inspections and tests in accordance with the procedures developed for the facility by a Professional Engineer. The SPCC Coordinator will maintain these written procedures and records of tank permits, licenses, daily inventory records, and testing results with a copy of this Plan. Inspection information will be recorded on the checklists provided in Sections 4-6 of the SPCC Compliance Packet, or equivalent checklists if inspections are being performed by contracted vendors. Examples of completed checklists being used by the park’s current inspection contractor are included in Section 7. Copies of inspections will be maintained at the facility for a minimum of three years.

3.5.1. UST Tests and Inspections

Park personnel (or qualified contracted vendors) will perform UST inspections on a monthly and annual basis. Inspections for USTs will include ensuring that electronic leak detection systems and overfill alarms are properly functioning (by performing quarterly calibration tests), inspecting the fill ports and sumps to ensure that water or product is not collecting, and observing surrounding areas for any evidence of leakage.

3.5.2. AST Tests and Inspections

Visual inspections of the ASTs covered by this plan are done on a monthly and annual basis. Each aboveground container will be inspected for integrity on a monthly basis and whenever material repairs are necessary. Inspections of ASTs will include an inspection of oil fill and vent piping, valves, tank supports, foundation, and secondary containment, and an indication of damages or deterioration or evidence of leakage. Acceptable AST inspection and testing methods include, but are not limited to, visual inspection; hydrostatic testing; radiographic testing; ultrasonic testing; acoustic emissions testing;

or another system of non-destructive testing.

3.5.3. Mobile and Portable AST Tests and Inspections

The 55-gallon steel drums and the mobile ASTs are considered to be portable containers and are not subject to integrity testing. Park staff inspects the drums and portable truck-mounted ASTs on a visual basis with each use, and staff are trained to replace these containers if there are any signs of corrosion or damage. Per SP001-11, the steel drums/totes need to be either removed from service after twelve years, or tested by the DOT.

3.5.4. Other Integrity Testing

Where installation of the appropriate structures on bulk storage containers referred to in 40 CFR 112.7(d) is not practical, the Park will conduct both periodic integrity testing of containers and periodic integrity and leak testing of the valves and piping.

All aboveground valves, piping, and appurtenances will be regularly inspected. During inspection, the general condition of items such as flange joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces will be assessed.