Attach_J-6_SPRP_Pentagon_Reservation_Amd_0001.pdf

Pentagon Reservation

Spill Prevention and Response Plan (SPRP)

Prepared for:

Washington Headquarters Services

Facilities Services Directorate 1155 Defense Pentagon

Washington DC 20301

Prepared by:

Applied Environmental, Inc.

200 Fairbrook Drive

Suite 201 Herndon, VA 20170

Eastern Research Group, Inc.

14555 Avion Parkway Suite 200

Chantilly, VA 20151-1102

October 2, 2015

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SPILL RESPONSE ACTIONS

Personal safety and protection of life and limb take precedence over environmental protection.

Pentagon Reservation Emergency Telephone Numbers – 24 hours (BOCC will notify all required personnel)

Initial Notification (BOCC) (703) 614‐1597 U.S. Court of Appeals Building Management (Joe Lusk) (202) 761‐1448 X 606

Incident Commander (Pentagon Fire Marshal) (703) 695‐3300 / ((703) 695‐8004 Arlington County Fire Department 911/(703) 228‐3362

Alternate Incident Commander (ESEB Branch Chief) (703) 614‐9583 / (703) 785‐1997 EPA Region III Main Office(800) 438‐2474

Hazardous Waste Office (Haztrain) David Mundt, Thomas Harris (703) 692‐4114 National Response Center (NRC) (800) 424‐88021 (24 Hour)

ESEB (703) 693‐3683 Virginia Department of Environmental Quality (Spill Reporting Line) (703) 583‐

3800(normal business hours), (800) 468‐8892(24 hour)

PFPA(703) 697‐5555 or 911 from Office Landline Virginia Department of Environmental Quality (Main Office) (703) 583‐3800

Hybla Valley Building Management(703) 614‐9583 CHEMTREC (24 Hour Information Line) (800) 424‐9555

Notes:

REVERSE CARD FOR FIRST RESPONDER REPORTING FORM

CLASS I SPILLS1 CLASS II AND III SPILLS2

Discover Spill

Contain and Clean Up the Spill Using

Appropriately Trained Personnel and Available

Spill Response Equipment

Discover Spill

Notify the BOCC: 703‐614‐1597 OR BOCC Emergency Phone Number –

911 or 703‐697‐1001

Notify ESEB by Calling 703‐614‐9583/703‐785‐1997*

Contain and Control the Spill

• Stop the source

• Protect nearby storm or floor drains

• Contain and prevent overland flow of material

Secure the Area

• Restrict access

• Remove ignition sources

• Provide passive ventilation

Report to the Incident Commander upon His/Her Arrival to the Scene

Alternate ESEB Phone Numbers*

• Environmental Engineer – 703‐692‐5601 or 703‐915‐1718

• Spill Response Contractor –800.Oil.Tank (800‐645‐8265)

Initiate Facility Evacuation According to the Pentagon CEMP, If Necessary

FIRST RESPONDER REPORTING FORM

Collect as much of the following information as reasonable before making initial notification.

Critical Information

Name and rank of reporting individual

Location of spill (building/area number, indoors or outside)

Number of injured personnel

Type of injuries

Substance(s) spilled

Estimated quantity spilled

Rate of discharge/release

Time of spill

Extent of spill travel

Does the fire department need to respond to protect life, property, or environment? Yes No

Additional Information (i.e., other potential hazards)

Initial information is critical. Get as much information as you can, but don’t hesitate to make the initial notification if a spill is moving or worsening rapidly!

REVERSE CARD FOR SPILL RESPONSE ACTIONS

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QUICK REFERENCE SPILL RESPONSE GUIDE (RED PLAN)

1.0 PURPOSE

In the event of a spill at the Pentagon Reservation, this RED PLAN serves as a QUICK REFERENCE

GUIDE and “Jump Start” for initiating the correct response actions at the earliest possible time.

Information contained in the Red Plan has been extracted from various sections of the Pentagon

Reservation Oil Spill Prevention and Response Plan (SPRP). The facility’s oil and hazardous substance storage locations, drainage ways, spill response deployment sites, and other pertinent spill response information are identified on the Facility Diagram that is included at the end of the Red Plan.

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2.0 EMERGENCY NOTIFICATIONS AND RESPONSE RESOURCES

2.1 Emergency Contact Information

Table R‐1 contains installation and local telephone numbers and email addresses which are to be used to alert personnel of the incident or to request additional assistance.

Table R‐1. Pentagon Reservation Emergency Telephone Numbers

Pentagon Reservation and Outlying Facilities – 24 hours (BOCC will notify all required personnel)

Initial Notification (BOCC) (703) 614‐1597

Incident Commander (Pentagon Fire Marshal) (703) 695‐3300 / ((703) 695‐8004

Alternate Incident Commander (ESEB Branch Chief) (703) 614‐9583 / (703) 785‐1997

Hazardous Waste Office (Haztrain) David Mundt, Thomas Harris (703) 692‐4114

ESEB (703) 693‐3683

PFPA (703) 697‐5555 or 911 from Office Landline

Hybla Valley Building Management (703) 614‐9583

U.S. Court of Appeals Building Management (Joe Lusk) (202) 761‐1448 X 606

Offsite

Arlington County Fire Department 911/(703) 228‐3362

EPA Region III Main Office (800) 438‐2474

National Response Center (NRC) (800) 424‐88021 (24 Hour)

Virginia Department of Environmental Quality (Spill Reporting Line) (703) 583‐3800 (normal business hours)

(800) 468‐8892(24 hour) or http://www.deq.virginia.gov/Programs/Poll utionResponsePreparedness/PollutionRepo rtingForm.aspx

Virginia Department of Environmental Quality (Main Office) (703) 583‐3800

Chemical Transportation Emergency Center (CHEMTREC) (24‐Hour

Information Line)

(800) 424‐9555

Note: The NRC will notify the USCG and USEPA.

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2.2 Notification Requirements

Table R‐2 on the next several pages includes descriptions of the notification requirements and the specific information to be provided.

Table R‐2. Pentagon Reservation Notification Requirements

Scenario No.

Basis for Reporting

Agencies to Contact

Time Frame for Contact Information to Be Provided

1 Spill of petroleum product in excess of 25 gallons – Any spill of a petroleum product to the environment in excess of 25 gallons.

A, B, C Immediately Facility name and address.

Your name and phone number.

Type and quantity of material spilled.

Time of spill.

Whether spill is continuing.

Location of spill.

Current response action.

Environmental impact and potential hazards.

Personal injuries or casualties, if any.

Corrective action being taken.

Requirement for DLA Energy spill cleanup support and/or funding (for DLA notification)

2 Spill of petroleum product to surface water – Any spill of petroleum product that violates 40 CFR 110.6 must be reported. This is basically any amount of petroleum product that reaches surface water (overland or through sewers).

A, B, C Immediately Same as Scenario 1 with this addition:

Location of spill and name of receiving water

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Table R‐2. Pentagon Reservation Notification Requirements

Scenario No.

Basis for Reporting

Agencies to Contact

Time Frame for Contact Information to Be Provided

4 Spill of petroleum product to surface water in excess of 1,000 gallons – If the facility has a spill in excess of 1,000 gallons or has two spills of more than 42 gallons each, a report to the USEPA Regional Administer is required (40 CFR 112.4). Refer to Section 6.8.2 of this document for additional information.

A, B, C, D, E, F

Immediately Same as Scenario 2 and written report that describes:

Name of facility.

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

Location of the facility.

Date and year of initial facility operation.

Maximum storage or handling capacity of the facility and normal daily throughput.

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

A complete copy of the Plan with any amendments.

The cause(s) of the spill, including a failure analysis of system/subsystem in which failure occurred.

The corrective actions and/or countermeasures taken, including an adequate description of equipment repairs and/or replacements.

Additional preventive measures taken or contemplated to minimize possibility of reoccurrence.

Other information as Regional Administrator may reasonably require pertinent to the Plan or spill event.

5 Spills or overflows from a UST – Report to the implementing agency any spills or overflows that result in a spill to the environment of 5 gallons of petroleum product, or the petroleum product causes a sheen on nearby surface water, or exceeds the RQ of a hazardous waste.

A, B, C, D, E, F

Immediately Facility name and address.

Your name and phone number.

Type and quantity of material spilled.

Time of spill.

Whether spill is continuing.

Location of spill.

Current response action.

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Table R‐2. Pentagon Reservation Notification Requirements

Scenario No.

Basis for Reporting

Agencies to Contact

Time Frame for Contact Information to Be Provided

7 Discharge to sanitary sewer – Accidental spill of petroleum product, hazardous waste/material, or any other material which by reason of their nature or quantity are sufficient to cause fire or explosion or be injurious in any other way to the sewerage system or to the operation of the waste reclamation facilities.

A, B, C, D, E, F

Immediately Facility name and address.

Your name and phone number.

Type and quantity of material spilled.

Time of spill.

Whether spill is continuing.

Location of spill.

Current response action.

Notes:

2.3 Local Spill Cleanup Contractors

Clean Harbors is available to assist in spill cleanup and restoration work when Pentagon Reservation resources are insufficient to conduct these activities. A local contractor that specializes in spill cleanup and site restoration is listed in Table R‐3.

Table R‐3. Pentagon Reservation ‐ Local Spill Cleanup Contractors

Contractor Name and Location Services 24‐Hour Phone Number

Clean Harbors (Contact through Applied Environmental) 1, 2, 3, 4, 5 Applied Environmental –

(703) 648‐0822 or 24‐hours

(703) 932‐2515

Clean Harbors ‐ (800) 645‐

Notes:

2.4 Spill Control/Emergency Response Equipment

Spill kits are located at each major storage area. Clean Harbors will provide spill control and emergency equipment as needed.

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3.0 QUICK REFERENCE GUIDE – SPILLS

Spilled fuel constitutes a fire and explosion hazard with the threat to human life and destruction of property. Petroleum vapors are also hazardous to personnel due to anesthetic and toxic concentrations below explosive levels. Volatile fuel may cause skin irritation if allowed to remain on the skin (i.e., soaked gloves and/or clothing). Personnel safety and protection of life and property take precedence over environmental protection. If there is a threat to personnel safety, the Arlington County Fire

Department should be the first official agency notified. Special precautions should be exercised when handling fuel oil.

3.1 Emergency Response Actions

Personnel safety and protection of life and property take precedence over environmental protection in all circumstances. Response actions are always commensurate with the amount of oil discharged and the risk posed by the release.

Three minor spill classifications are listed in Table R‐4:

Table R‐4 Pentagon Reservation Spill Classifications

Class of Spill Definition

I < 2 feet in any direction.

II < 10 feet in any direction or < 50 square feet.

III > 10 feet in any direction, > 50 square feet, or continuous in nature.

3.1.1 Initial Response Actions for a Class I Spill

The normal course of action in the event of a Class I spill is to contain and clean up the spill using appropriately trained personnel and available spill response equipment. Leaks and minor spillage shall be reported to appropriate Pentagon Reservation authorities to ensure appropriate action is taken to correct deficiencies or malfunctions that caused the discharge.

Class I Spills Required Actions

Contain spill.

Clean up spill.

Report spill.

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3.1.2 Initial Response Actions for a Class II or Class III Spill

The following is the normal course of action in the event of a Class II or Class III spill:

notifications.

3.1.3 Emergency Response Action Checklists

Initial information is critical. Pre‐printed forms with pertinent questions must be carried by response personnel. The following checklists and forms are included in Appendix B of the SPRP:

— Emergency Action Checklist – The key first discovery steps to be taken in an emergency situation are listed in this checklist (referred to as Table R‐6 in the Red Plan).

Class II or III Spills Required Actions

Initiate Facility Evacuation (if necessary).

Notify the Pentagon Reservation BOCC (703‐614‐1597).

Stop spill safely.

Contain spill.

Secure area.

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— Incident Commander Checklist – The key actions to be performed by the initial IC including initial incident assessment, site safety characterization, activation of resources, briefing of supporting spill management team, and interaction with the IC, as appropriate, are described in this checklist.

— Response Notification Form – The key incident information required to be reported to the authorities is described on this form. The form includes all relevant data required by the

NRC and a section for documenting notifications as they are made.

— Initial Site Safety and Control Analysis (Part 1 and 2) – The site safety analysis to be performed by the IC to assess safety related aspects of the incident and related PPE requirements are included on this form.

— Incident Briefing (Form ICS 201‐OS) – This form serves as the initial plan of action and is to be completed by the IC or delegate. The form is to be used to brief the supporting ESF‐10 and other supporting resources and regulatory agency representatives.

Answers to some of the questions on these forms will not be immediately known, but it is important to obtain and record as much information as quickly as possible without placing personnel in danger. If applicable, the identification number, shipping manifests, and placard information are essential for the identification of spilled or released material. First responders can use USDOT’s Emergency Response

Guidebook to help identify hazardous substances and for guidance on initial precautionary and containment steps.

3.1.4 Additional Response Actions

In case of fire or explosion, activate the fire alarm system, notify the BOCC, who will notify the

Arlington County Fire Department (911) immediately, and evacuate the area.

Allow no smoking or open flames within the spill area.

Do not use equipment with magneto‐sparked engines or equipment producing sparks or static electricity in potential spill risk areas.

Federal law prohibits the use of any material that would cause oil to sink or disperse.

Place chemical‐soaked sorbent and soil in metal, leak‐tight drums; label and dispose of properly.

3.2 Likely Spill Flow Path Prediction and Receptors

Detailed drawings pertaining to the Pentagon Reservation and outlying facilities storm water drainage conveyance and sanitary sewer systems are available for review at the ESEB office. Brief descriptions of these systems are outlined in Section 3.5. Drainage features of WHS are shown on the Facility Diagram in Appendix A.

Spill response deployment sites are defined as areas throughout the facility where: (1) spill response equipment and personnel can be deployed to mitigate spills from either high‐risk operations (i.e., bulk fuel storage, undiked bulk fuel piping, flight line staging area), and/or (2) topography or structural or

R-12 drainage features can aid in the control of a potential release (i.e., sluice gates, primary retention ponds, downgradient control, capture points). Personnel at the Pentagon Reservation will attempt to confine any spill within the boundaries of the Reservation by using mitigation techniques at the response deployment sites. Refer to the Facility Diagram in Appendix A for spill response equipment locations and Sections 17.1 and 17.2 for spill control techniques. Spill response deployment sites at the Pentagon

Reservation are located at each outfall.

Storm Water Drainage System

The existing stormwater management system consists of inlets that capture runoff from surfaces and convey water to underground storm sewer pipes. The storm sewer network is gravity‐driven and the culverts discharge untreated runoff into Boundary Channel and the Pentagon Lagoon. There are four stormwater discharge outfalls associated with the Reservation: one outfall discharges into Boundary

Channel and three outfalls discharge into the Pentagon Lagoon (see Figure 2 in Appendix A).

Areas at the Pentagon Reservation and outlying facilities that store or transfer petroleum products, used oil, or hazardous substances and discharge storm water directly into storm drains or catch basins that have outlets to the storm sewer are as follows:

• RDF Fuel Transfer Area (Outfall 1)

• HRP (Outfalls 3 and 4)

• Outdoor emergency generators (all outfalls)

• “Old” sewage lift station (Outfall 1)

3.3 Probable Spill Response by Nature/Volume of Spill

Initial spill response operational tactics determined by the IC will be influenced by the nature and magnitude of the incident. Table R‐5 provides examples the IC may consider in initiating response operations.

Table R‐5

Pentagon Reservation Probable Spill Response by Nature/Volume of Spill

Substance Volume Probable Response

Oil 0‐250 gallons Expedient Earthen Containment/Sorbent/

Offsite Disposal

Oil 250‐1,000 gallons Expedient Earthen Containment/Sorbent or Pumping/

Offsite Disposal

Oil 1,001‐20,000 gallons Maintain Containment/Skimming and Pumping/

Offsite Disposal or Reclamation

Biocides (includes herbicides and pesticides)

Solids (all Volumes) Liquids (all Volumes)

Shovel or Offsite Disposal Containment/Sorbent/ Offsite Disposal

Contaminated Earth All Volumes Excavation/Containerization/

Offsite Disposal

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Table R‐6

Steps to be Taken When a Spill Exceeds the Capability of Reservation Response Personnel

Incident Title:

Date:

Reported By:

Time:

Status Steps To Be Taken in an Emergency Situation

Done To Do NA

1. Identify the source of the spill.

2. Provide first aid to any injured. Call the BOCC if assistance is required.

3. Notify:

4. Stop the flow of oil/hazardous substance (without endangering personnel).

a. Close valve.

b. Tighten gasket.

c. Shut down pump.

d. Complete any necessary action to stop the flow of oil/hazardous substance.

5. Close all spill drains.

6. Close/stop all downstream drains.

7. Estimate the amount and type of oil spilled or hazardous substance released.

8. Secure the area.

9. Identify hazards and immediate areas threatened.

10. Make initial external notifications in accordance with Table 17‐2 of the SPR Plan.

12. Initiate memorandum of agreements for support and response contractors as necessary.

13. Start cleanup.

14. Remove/reuse recovered material.

15. Complete follow up external notifications in accordance with Table 17‐2 of the SPR Plan.

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Table R‐7

Incident Commander Checklist

Done To Do NA Discovery and Notification

Ensure qualified individual is notified and role executed.

Ensure required installation, regulatory agency, and response contractor notifications

Initial Actions

Initial response team activated (time):

Spill management team activated (time):

Spill response contractor activated (time):

Evaluate the incident:

Materials involved –

Personnel hazards –

Fire/explosion hazard –

Total amount lost –

Recovered amount –

Evaporation/burned –

Uncontained –

Wildlife impact –

Perform initial site safety characterization.

Prepare/deliver initial incident assessment briefing to spill management team. Use Incident

Briefing (Form ICS 201‐OS) in the Red Plan.

Advise the federal on‐scene coordinator on actions being taken.

Determine if support is sufficient:

Land response equipment needed –

Water response equipment needed –

Defensive Actions

Secure the source.

Prepare and follow site safety plan:

Conduct site safety briefings for response personnel.

Establish decontamination procedures for response personnel.

Set up eyewash/washdown/decontamination station.

Set up first aid stations.

Designate exposure monitoring personnel.

Deploy response assets.

Evacuations:

Facility evacuation, Community evacuation

Request assistance if required.

Establish site traffic control.

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Table R‐7

Pentagon Reservation

Incident Commander Checklist (continued)

Done To Do NA Discovery and Notification

Establish command post (use ICS structure) and communications center.

Establish unified command with federal and state on‐scene coordinators.

Obtain source(s) for material handling equipment.

Communications:

Obtain cellular phones.

Establish working channels (VHF).

Recovery, Cleanup, and Disposition

Coordinate cleanup with federal (NRT, RRT, etc.), and state agencies.

Obtain food and water for response personnel.

Obtain sanitary facilities within reasonable distance of site.

Document respiratory and/or skin reaction complaints.

Initiate salvage operations.

Implement/maintain fire control.

Obtain samples for analysis.

Documentation and Cost Recovery

Prepare preliminary damage assessment and update frequently.

Prepare natural resource damage assessment.

Maintain field accounting for accurate cost tracking.

Identify funding sources.

Waste Management:

Type of oil or hazardous substance –

Amount of contaminated liquids –

Amount of contaminated solids –

Amount of HAZMAT –

Determine proper storage procedures for contaminated materials.

Determine proper disposal procedures for contaminated materials and coordinate disposal with appropriate federal and state agencies.

Communicate available information on response activities to Base Public Affairs Officer

(facts only, no speculation) for dissemination to media.

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Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community, Esri, HERE, DeLorme, MapmyIndia, © OpenStreetMap contributors

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Prepared for:

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Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community, Esri, HERE, DeLorme, MapmyIndia, © OpenStreetMap contributors

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Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community, Esri, HERE, DeLorme, MapmyIndia, © OpenStreetMap contributors

Hazardous Waste Accumulation

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FOR OFFICIAL USE ONLY

i

Washington Headquarters Services (WHS) Facilities Services Directorate (FSD)

Environmental, Sustainability, Energy and Branch (ESEB)

TO: DISTRIBUTION

1. Forwarded is the Oil Spill Prevention and Response Plan (SPRP) for the Pentagon Reservation.

2. This Plan satisfies all applicable state and federal (40 CFR 112) requirements for the development of a Spill Prevention, Control, and Countermeasure (SPCC) Plan.

3. This document is UNCLASSIFIED, however it is FOR OFFICIAL USE ONLY.

4. This Plan is effective for implementation upon receipt.

5. The Office of Primary Responsibility (OPR) for this document is ESEB.

6. This document will be reviewed annually and updated as is appropriate. All addressees of the

Plan are requested to advise this office of any factors that may prevent the execution of this Plan as presented herein. Recommendations for changes should be submitted within 60 days after receipt of this document.

7. The operator shall properly coordinate with ESEB to develop policies for employees and public awareness, staff training requirements, daily operating procedures and internal inspection or auditing program for this Plan.

8. The operator shall promptly coordinate with ESEB to identify and correct deficiencies in the daily operating procedures, storage facilities, equipment, structures and associated facilities.

Locations Where SPRP Copies are Maintained

Name of Building Location Pentagon Heating and Refrigeration Plant (HRP) Manager’s Office Pentagon Pentagon Building Management Office (PBMO), ESEB

Office, Remote Delivery Facility (RDF) Generator Station Hybla Valley Office Building Building Manager’s Office U.S. Court of Appeals for the Armed Forces Building Manager’s Office

Craig Georg Director, Standards and Compliance Division ii

MANAGEMENT APPROVAL

This SPRP was prepared for Washington Headquarters Services (WHS) facilities, including the Pentagon, Hybla Valley, and the U.S. Court of Appeals, herein referred to as “Pentagon Reservation”.

This plan was prepared in accordance with good engineering practices and also functions as a Spill Prevention, Control, and Countermeasure (SPCC) plan in accordance with 40 CFR 112. It has the full approval of management at a level of authority to commit the necessary resources to ensure full SPRP implementation. This SPRP will be implemented as described herein, and will be reviewed and evaluated at least once every 5 years.

I have reviewed the recommendations for regulatory compliance as presented in this SPRP. I have authority to approve this document on behalf of WHS and to commit the necessary resources to implement the required improvements to comply with existing applicable federal and state laws.

Signature Date

Printed Name Title iv

RECORD OF SPRP REVIEWS/AMENDMENTS

In accordance with 40 CFR 112.3 and 112.5 of the SPCC Plan regulations, there are three situations that require an amendment to the Pentagon Reservation SPRP.

Situation A If your onshore or offshore facility was in operation on or before 16 August 2002, you must maintain your SPRP, and must amend it, if necessary to ensure compliance with this part, and must implement the amended SPRP as soon as possible.

Situation B The owner or operator of a facility that meets the general applicability requirements of 40 CFR

112.1 must review and amend the SPRP when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge of oil into or upon the navigable waters of the United States or adjoining shore lines…or that may affect natural resources belonging to, appertaining to, or under the exclusive management authority of the United States (including resources under the Magnuson Fishery Conservation and Management Act).

Examples of changes that may require amendment of the SPRP include, but are not limited to any of the following:

• Commissioning or decommissioning containers;

• Replacement, reconstruction, or movement of containers;

• Reconstruction, replacement, or installation of piping systems;

• Construction or demolition that might alter secondary containment structures;

• Changes of product or service; and

• Revision of standard operation or maintenance procedures at a facility.

An amendment made under this section must be prepared within 6 months (of the facility change), and implemented as soon as possible, but not later than 6 months following preparation of the amendment.

Situation C The facility owner or operator must complete a review and evaluation of the SPRP at least once every 5 years from the date your last review was required under this part. As a result of this review and evaluation, you must amend your SPRP within 6 months of the review to include more effective prevention and control technology if the technology has been field-proven at the time of the review and will significantly reduce the likelihood of a discharge as described in §112.1(b) from the facility. For any amendment to the SPRP, you must implement the amendment as soon as possible, but not later than 6 months following preparation of the amendment. You must document your completion of the review and evaluation, and must sign a statement as to whether you will amend the SPRP, either at the beginning or end of the SPRP or in a log or an appendix to the SPRP. The following words will suffice:

A licensed professional engineer must review and certify any technical amendments to this SPRP for it to be effective to satisfy the SPCC rules.

I have completed review and evaluation of the SPRP for WHS facilities on (date) and will (will not) amend the SPRP as a result.

v

TABLES FOR RECORD OF REVIEW AND AMENDMENT

To facilitate SPRP reviews and amendments, the following two tables are provided.

Owner/Operator Record of SPRP 5-Year Reviews

I have completed review and evaluation of the SPRP for WHS facilities on the date indicated below and will amend the SPRP as a result.

Signature of Reviewer Date of Review Will

Amend the SPRP Will Not

Amend the SPRP 9/6/2001 Yes ----- 4/10/2006 Yes ----- 4/10/2010 Yes ----- 10/31/2015 Yes -----

Owner/Operator Record of SPRP Amendments

If applicable, briefly describe the type of amendment (i.e., administrative or technical). State how the amendment was completed (i.e., page change, addendum, etc.). Provide the date of the amendment and the printed name/position of person responsible for the amendment. A licensed professional engineer must review and certify all technical amendments. For any amendment to this SPRP, WHS must implement the amended SPRP within 6 months (except as noted on the Management Approval page).

Description of Change (Administrative or Technical) Date Entered Posted By

Addition of RDF at the Pentagon and an emergency generator at Hybla Valley Generator.

Pages in the 2000-2001 SPCC Plan:

88A & B, 91A & B, 129A & B

*Table and figure index numbers in the 2006 SPRP:

5-2.1.10 (Formerly 5-2.1.16) Pentagon Day Tanks for RDF 5-3.1.3. Hybla Valley Hybla-1

9/6/2001 Louis M. Montgomery, P.E.

(ALA. 20195)

The following tanks and storage areas are no longer in existence and/or use at the Pentagon Reservation. The corresponding tables are listed below, these tables and the related figures have been removed from the SPRP:

• Pentagon Army EG Day Tank, Pentagon D 9 EG Tank, Pentagon JISC EG AST, Pentagon NMCC EG AST, Pentagon Day Tank #1 for NMCC EG, Pentagon Day Tank #2 for NMCC EG, Pentagon Army EG UST, Pentagon E 5, E 6,7B, E 9B,E 10B, F 7B, POAC Transformers.

• Pentagon D 8 HS Area, Pentagon D 9 HS Area.

• Pentagon HS Area Room BF760.

• Pentagon POAC Pool HS Area.

• Pentagon Repair Shop HS Area.

• Pentagon HS at C8B MC.

• FOB-2 Pump Room HS Area.

• Table 5-4.6.3. FOB-2 Paint Room HS Area.

4/10/2006 Purvagna N. Amin, P.E.

(VA 0402039604)

vi

Description of Change (Administrative or Technical) Date Entered Posted By

The table and figure numbers for the following tanks and storage areas have changed such that:

• Pentagon AT&T EG AST formerly 5-2.1.4 became 5-2.1.3.

• Pentagon BMDO EG AST (Room BB-937), formerly 5-2.1.5, became 5-2.1.4.

• Pentagon D 1 EG AST (Room 1D-173), formerly 5-2.1.6, became 5-2.1.5.

• Pentagon D 2 EG AST (Room 1C 246), formerly 5-2.1.7, became 5-2.1.6.

• Pentagon D 8 Generator AST, formerly 5-2.1.8, became 5-2.1.7.

• Pentagon New Sewage Lift Station EG AST, formerly 5-2.1.14, became 5-2.1.8.

• Pentagon Old Sewage Lift Station EG, formerly 5-2.1.15, became 5-2.1.9.

• Pentagon Day Tanks for RDF, formerly 5-2.1.16, became 5-2.1.10.

• Underground Fuel System for RDF, formerly 5-2.2.2, became 5-2.2.1.

• E 10B Large Transformer, formerly 5-2.4.17, became 5-2.4.12.

• Pentagon Kitchen Transformers, formerly 5-2.4.20, became 5-2.4.13.

• Pentagon HS 90-Day Temporary Storage, formerly 5-2.6.6, became 5-2.6.3.

• Pentagon Paint Room HS, formerly 5-2.6.7, became 5-2.6.4.

4/10/2006 Purvagna N. Amin, P.E.

(VA 0402039604)

The following tanks and storage areas have been added to SPRP, the corresponding table and figure index numbers are provided.

• 5-2.1.11 Pentagon "N1 & N2"

• 5-2.1.18 Pentagon Library and Conference Center EG

• 5-4.1.4. FOB-2 Generac EG

• 5-4.1.5. FOB-2 Katolight EG

• 5-4.1.6. FOB-2 Vault 4 EG

• 5-4.1.7. FOB-2 Whole Building Backup Generator

• 5-4.1.8. FOB-2 Generac Small Emergency Generator

• 5-4.1.9. FOB-2 Generac Emergency Generator at Fence

• 5-6.1.1. Naval Exchange Gas Station Biodiesel AST

• 5-6.1.2. Naval Exchange Gas Station Natural Gas AST

• 5-7.1.1. United States Court of Appeals for the Armed Forces Emergency

Generator AST

• 5-6.2.4. Naval Exchange Gas Station Ethanol UST

• 5.2.4.21 Pentagon RDF-1J7B Transformers

• 5.2.4.22 Pentagon RDF J7R Vault Transformers

• 5.2.4.23 Pentagon RDF K7R Vault Transformers

• 5.2.4.24 Pentagon RDF Basement E6BNP (Normal Power) Transformers

• 5.2.4.25 Pentagon RDF Basement (room BF675) E6BMC (Mission Critical)

Transformers

• 5.2.4.26 Pentagon first floor C6NP (Normal Power) Transformers

• 5.2.4.27 Pentagon first floor C6MC (Mission Critical) Transformers

• 5.2.4.28 Pentagon RDF first floor C5NP (Normal Power) Transformers

• 5.2.4.29 Pentagon RDF first floor C4NP (Normal Power) Transformers

• 5.2.4.30 Pentagon RDF first floor C3NP (Normal Power) Transformers

• 5.2.4.31 Pentagon C8B MC Transformers

• 5.2.4.32 Pentagon C7 MC Transformers

• 5.2.4.33 Pentagon C10B NP Transformers

• 5.2.4.34 Pentagon C10B MC Transformers

• 5.3.4.2. Hybla Valley Cutler Hammer Transformers

• 5.4.4.1. FOB-2 Vault 3 Transformers

• 5.4.4.2. FOB-2 Vault 1 Transformers

• 5.4.4.3. FOB-2 Vault 4 Transformers

• 5.4.4.4. FOB-2 Vault 7 Transformers

• 5.4.4.5. FOB-2 Transformers in Shed beside Vault 7

• 5.5.4.1. Motor Transport Directorate Transformer near Diesel UST

• 5.1.6.3. PHRP Basement HS Storage at Chiller Plant

4/10/06 Purvagna N. Amin, P.E.

(VA 0402039604)

• Plan reorganization- integration of the SPCC (2001), SCP (2001), and ODCP (1997)

4/10/06 Purvagna N. Amin, P.E.

(VA 0402039604)

vii

Description of Change (Administrative or Technical) Date Entered Posted By

• Plan reorganization – complete reorganization and format change to simplify plan.Added text describing Technical Amendment.

• Added new PE Certification for Technical Amendment.

• Added reference to documentation of current regulatory issues.

• Updated bulk storage container inventory

• Updated Facility Diagram using current field information.

• Verified and updated all emergency contact numbers.

• Applied current EPA definition of “loading/unloading racks” throughout plan.

4/10/2015 ERG/Applied Environmental ix

PENTAGON RESERVATION SPRP

A technical and administrative update of the Pentagon Reservation SPRP was prepared under the direction of WHS ESEB in April 2015. In support of this plan development, a site visit was conducted in March 2015. Documentation of observations were provided as memorandum under separate cover. This briefing is kept on file at the WHS ESEB office. This SPRP includes an entire format change to ensure coverage of all regulations. Major changes in the plan are documented in the owner/operator record of SPRP amendments table. Due to the number of changes, the entire plan is published as “a new version”.

PROFESSIONAT ENGINEER CERTIFICATION OF PIAN AMENDMENT

By means of this certification, I hereby attest that:

7. I am familiar with the requirements of Title 40, Code of Federal Regulations (CFRJ, Part 112, Spill Prevention, Control, and Countermeasure (SPCC) regulations;

2. I, or my agent, have visited and examined the Pentagon Reservation and outlying facilities;

3. I have found this Spill Prevention and Response Plan (SPRP) to have been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and the requirements of 40 CFR Part 112;

4. Procedures for required inspections and testing have been established; and

5. The SPRP is adequate for the facility.

This certification shall in no way relieve the owner or operator of the facility of his duty to prepare and fully implement the SPRP in accordance with the requirements of 40 CFR PartLL2.

This certification applies only to the SPCC-related elements of the Pentagon SPRP.

Ienny Raczko Name of Registered

Professional Engineer

0402044127 Registration

Number

Virsinia State of

Registration

Sigdahrre of Registered Prol6ssional Engineer

JENNY L. RACZKO

Ltc. No.01al27 f'h*0, xlll xiii

CERTIFICATION OF SUBSTANTIAL HARM DETERMINATION FORM

FACILITY NAME: Pentagon Reservation FACILITY ADDRESS: 1155 Defense Pentagon Washington, D.C. 20301

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 storage tank (AST) area?

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 (as calculated using the appropriate USEPA formula or a comparable formula1) such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments?

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 (as calculated using the appropriate USEPA formula or a comparable formula1) such that a discharge from the facility would shut down a public drinking water intake2?

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 spill in an amount greater than or equal to 10,000 gallons within the last 5 years?

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 Title

Name (please type or print) Date

1 If a comparable formula is used, documentation of the reliability and analytical soundness of the comparable formula must be attached to this form.

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

xiv xv

EXECUTIVE SUMMARY

This Oil Spill Prevention and Response Plan (SPRP) for the Pentagon Reservation was developed per 40 CFR 112, and supersedes the previous SPRP dated May 2006. This SPRP also functions as a Spill Prevention, Control, and Countermeasure (SPCC) Plan.

Required Actions

In Title 40 of the Code of Federal Regulations (CFR) Part 112 (40 CFR 112), the SPCC rule cites that plans will be reviewed by the facility owner / operator at least once every five years. Furthermore, the SPRP must be amended within six months of the five-year review or facility changes that affect the potential for a discharge as described in 40 CFR 112.1(b). The revised plan must be implemented no more than six months from the date of amendment unless an extension is requested from the Regional Administrator.

Recommended Actions

Information presented in this plan is based on field investigations and interviews conducted in March 2015. Personnel from the Pentagon Reservation that manage tanks and bulk storage areas or provide emergency/spill response organizations were interviewed. Findings and observations related to code compliance and best management practice recommendations were provided to WHS in a written Executive Briefing provided under separate cover. WHS is not required to implement the best engineering practice recommendations identified in the Executive Briefing (provided under separate cover). However, if funding is available, WHS should consider implementation of these recommendations as a means to further enhance spill prevention and control.

This technical and administrative update of the SPRP satisfies the SPCC requirements for a full review and evaluation of the plan once every five years.

CONTENTS

Page

DISTRIBUTION .......................................................................................................................................................................... I

MANAGEMENT APPROVAL ................................................................................................................................................. II

RECORD OF SPRP REVIEWS/AMENDMENTS ............................................................................................................IV

TABLES FOR RECORD OF REVIEW AND AMENDMENT ......................................................................................... V

PENTAGON RESERVATION SPRP .................................................................................................................................... IX

PROFESSIONAL ENGINEER CERTIFICATION OF PLAN AMENDMENT ........................................................... XI

CERTIFICATION OF SUBSTANTIAL HARM DETERMINATION FORM ..........................................................XIII

EXECUTIVE SUMMARY ...................................................................................................................................................... XV

1. INTRODUCTION ................................................................................................................................................... 1-1

1.1 Plan Update and Amendment ......................................................................................................... 1-1

1.2 Plan Purpose .......................................................................................................................................... 1-1

1.3 Plan Focus ............................................................................................................................................... 1-2

1.4 Emergency Management Program ............................................................................................... 1-2

1.5 Plan Organization and Regulatory References ........................................................................ 1-2

2. FACILITY INFORMATION ................................................................................................................................. 2-1

2.1 Facility Owner/Operator, Address, and Telephone .............................................................. 2-1

2.2 Facility Contact(s)................................................................................................................................ 2-1

2.2.1 Spill Prevention Coordinators ........................................................................................ 2-1

2.2.2 Incident Commanders ........................................................................................................ 2-1

2.2.3 Agencies to Contact when a Discharge of Hazardous Material or Oil

Occurs ....................................................................................................................................... 2-2

2.3 Facility Description ............................................................................................................................. 2-2

2.3.1 Reservation Name and Address ..................................................................................... 2-2

2.3.2 Date of Initial Operation, Purpose, and Activities .................................................. 2-2

2.3.3 Geographic/Topographic Reservation Description .............................................. 2-7

2.4 On-Going and Pending Oil-Related Projects of Significant Impact ................................. 2-7

3. OIL STORAGE INFORMATION AND DRAINAGE PATHWAYS ............................................................ 3-1

3.1 Facility Diagram ................................................................................................................................... 3-1

3.2 Oil Storage ............................................................................................................................................... 3-1

3.2.1 Oil Storage, Good Engineering Practice, and Liquid Level Sensing ................. 3-1

3.2.2 Oil Storage and Throughput Summary ....................................................................... 3-1

3.3 Facility-Wide Oil Management ....................................................................................................... 3-2

3.3.1 Aboveground Storage Tanks ........................................................................................... 3-2

3.3.2 Underground Storage Tanks ........................................................................................... 3-2

3.3.3 Mobile/Portable Storage Tanks ..................................................................................... 3-2

3.3.4 Drum Storage Areas ............................................................................................................ 3-2

3.3.5 Animal Fat and Vegetable Oil Containers .................................................................. 3-3

3.4 Oil-Filled Operational Equipment ................................................................................................. 3-3

3.5 Oil Water Separators .......................................................................................................................... 3-3

(Continued)

Page xviii

3.6 Drainage Pathway and Distance to Navigable Waters and Critical Water Use Areas.......................................................................................................................................................... 3-3

3.6.1 Site Topography and Surface Water Drainage ........................................................ 3-3

3.6.2 Pentagon Reservation Geology ....................................................................................... 3-4

3.6.3 Regional Hydrogeology ..................................................................................................... 3-4

3.6.4 Likely Spill Flow Path Prediction and Receptors .................................................... 3-4

3.7 Storm Water Drainage System ....................................................................................................... 3-4

3.8 Wastewater Drainage System ........................................................................................................ 3-5

4. POTENTIAL SPILL PREDICTIONS, VOLUMES, RATES, AND CONTROL ........................................ 4-1

4.1 ASTs and USTs, Oil-Filled Operational Equipment and Mobile/Portable

Containers ..............................................................................................................................................