Final_HRP_ODCP.pdf

Pentagon Heating and

Refrigeration Plant (HRP)

Oil Discharge

Contingency Plan (ODCP)

Prepared for:

Washington Headquarters Services

Defense Facilities Directorate

Engineering & Technical Services Division

1155 Defense Pentagon

Washington, D.C. 20301

Prepared by:

Applied Environmental 200 Fairbrook Drive

Suite 201

Herndon, VA 20170

ERG

14555 Avion Parkway

Suite 200

Chantilly, VA 20151

20 September 2016

This page intentionally left blank.

-- FOR OFFICIAL USE ONLY --

Oil Discharge Contingency Plan

Pentagon Heating and Refrigeration Plant iii

TABLE OF CONTENTS

Page

1.0 INTRODUCTION

1.1 Purpose

1.2 Applicability

1.3 Plan Organization

1.4 Geographic Location [9 VAC 25-91-170.A1]

1.5 Reviews and Amendments

1.6 Plan Distribution

2.0 FACILITY INFORMATION

2.1 Facility Operators [9VAC 25-91-170A.2]

2.2 Facility Description [9VAC 25-91-170A.3]

3.0 DESCRIPTION OF STORAGE AND CAPACITIES [9 VAC 25-91-170A.4, 5]

3.1 Aboveground Storage Tanks

3.2 Underground Storage Tanks

3.3 Unloading Areas

3.4 Transformers

3.5 Oil/Water Separators

4.0 AGENCY NOTIFICATIONS [9 VAC 25-91-170A.6]

5.0 NOTIFICATION RESPONSIBILITES [9 VAC 25-91-170A.7]

5.1 General

5.2 Activity Spill Response Center

5.3 Various Personnel Functions

5.3.1 OSOT

5.3.2 FIC (WHS ESEB Manager)

5.3.3 Hazardous Waste Coordinator (HWC)

5.3.4 Chief of Security Police (PFPA)

5.3.5 Safety and Environmental Management Branch (SEMB)

5.3.6 Safety Officer (Director of the Safety Office)

5.3.7 Public Affairs Officer

5.3.8 General Counsel

5.3.9 Supervisory Personnel at Spill Location

6.0 SPILL CONTAINMENT AND CLEANUP RESPONSIBILITIES [9 VAC 25-91-

170A.8, 9]

6.1 Emergency Notification and Actions for Discoverer/Spiller

6.2 General Spill Response Actions (OSOT)

6.2.1 On-Scene Command

6.2.2 Immediate Action

6.2.3 Site Control and Evaluation Actions

Pentagon Heating and Refrigeration Plant iv

6.2.4 Spill Containment and Control

6.2.5 Cleanup and Disposal

6.2.6 Documentation and Cost Recovery

7.0 OUTSIDE SPILL RESPONSE ORGANIZATIONS [9 VAC 25-91-170A.10]

8.0 WORST CASE DISCHARGE ASSESSMENT [9 VAC 25-91-170A.11]

8.1 Booming Procedures

8.1.1 Evacuation Procedures

9.0 FACILITY CONTAINMENT EQUIPMENT [9 VAC 25-91-170A.12]

10.0 NATURAL RESOURCES AT RISK [9 VAC 25-91-170A.13]

11.0 MUNICIPAL SERVICES AT RISK [9 VAC 25-91-170A.14]

12.0 TRAINING, EQUIPMENT TESTING, AND DRILLS [9 VAC 25-91-170A.13]

12.1 Training

12.2 Inspections

12.3 Drills

13.0 INVENTORY CONTROL PROCEDURES [9 VAC 25-91-170 A.17]

14.0 EARLY DETECTION SYSTEM [9 VAC 25-91-170 A.18]

15.0 POST-RELEASE DETECTION PROCEDURES [9 VAC 25-91-170 A.19]

16.0 PREVENTIVE MAINTENANCE [9 VAC 25-91-170 A.20]

17.0 SECURITY [9 VAC 25-91-170 A.21]

18.0 POST-DISCHARGE REVIEW [9 VAC 25-91-170 A.22]

LIST OF APPENDICES

Appendix A SAFETY DATA SHEETS

Appendix B STANDARD OPERATING PROCEDURES

Appendix C ON-SCENE OPERATIONS TEAM STAFF DIRECTORY

Appendix D SPILL INCIDENT/LOG SHEETS

Appendix E NATURAL RESOURCES AT RISK

Appendix F INSPECTION FORMS v

LIST OF TABLES

Page

Table 1-1. Record of Reviews and Amendments

Table 2-1. Pentagon Heating and Refrigeration Plant

Table 3-1. Aboveground Storage Tank Summary

Table 3-2. Tanker Truck Unloading Area Summary

Table 3-3. Transformer Summary

Table 3-4. Summary of Oil and Water Separators

Table 4-1. Agency Notification List

Table 6-1. Suggested Criteria for "Burn/No Burn" Decisions

Table 6-2. Methods for Spill Control and Containment

Table 6-3. General Considerations for Stopping Source of Releases

Table 6-4. Methods for Spill Cleanup

Table 7-1. Outside Response Organizations

Table 8-1. Estimated Boom Length for Potential Release at the HRP

Table 9-1. Spill Response Equipment Inventory for HRP vi

LIST OF FIGURES

Page

Figure 1-1. Site Location Map

Figure 2-1. HRP Layout

Figure 3-1. Oil Storage Locations

Figure 3-2. Fuel Oil Containment System

Figure 3-3. Photograph of Unloading Area

Figure 3-4. Diagram of Unloading Area with Elevation

Figure 3-5. PERC As-built Drawing

Figure 8-1. Potential Boom Locations and Access Routes

Figure 8-2. Shore Seal Booms during Tidal Fluctuations

Figure 8-3. Emergency Routes and Road Closures

1.0 INTRODUCTION

1.1 Purpose

This Oil Discharge Contingency Plan (ODCP) addresses concerns on the effect of oil discharges on the environment as well as considerations of public health and safety. It ensures that a facility takes such steps as are necessary to protect environmentally sensitive areas; to respond to the threat of an oil discharge; and to contain, clean up and mitigate an oil discharge within the shortest feasible time.

1.2 Applicability

This section identifies state requirements according to the Virginia Department of Environmental

Quality (DEQ) Facility and Aboveground Storage Tank (AST) Regulations (9 VAC 25-91). Per

9 VAC 25-91-20, an ODCP is required if either of the following conditions apply at a facility:

An individual AST located within the Commonwealth of Virginia with an aboveground storage capacity of 25,000 gallons or greater of oil; and/or

A facility in the Commonwealth of Virginia with an aggregate aboveground storage capacity of 25,000 gallons or greater of oil.

Both of these conditions apply at the Pentagon Heating and Refrigeration Plan (HRP); therefore, an ODCP for the HRP is required to be developed and submitted to the DEQ for approval. The other areas of the Pentagon Reservation do not meet the minimum oil storage threshold for an

ODCP and are therefore not included in this plan.

1.3 Plan Organization

This ODCP is organized into sections corresponding to the 22 requirements for an ODCP as listed in 9 VAC 25-91-170. The subsection of the code that a particular section pertains to is shown in brackets following the section title (i.e., Geographic Location [9 VAC 25-91-170.A1]).

1.4 Geographic Location [9 VAC 25-91-170.A1]

The Pentagon Reservation is located in Arlington County, VA. Figure 1-1 shows the overall location of the Pentagon Reservation. The HRP is located in the southeastern corner of the

Reservation. It consists of the heating and refrigeration plant, incinerator plant, a hazardous material response facility, and three large transformer sets.

Figure 1-1. Site Location Map

1.5 Reviews and Amendments

This ODCP will be reviewed, updated as necessary and re-submitted to VDEQ every 60 months from the date of approval unless significant changes occur sooner. Operators shall notify VDEQ of significant changes and make appropriate amendments to the ODCP within 30 days of the occurrence. A significant change includes the following:

A change of operator of the facility;

An increase in the maximum storage or handling capacity of the facility that would change the measures to limit the outflow of oil, response strategy or operational plan in the event of the worst case discharge;

A decrease in the availability of private personnel or equipment necessary to remove to the maximum extent practicable the worst case discharge and to mitigate or prevent a substantial threat of such a discharge;

A change in the type of product dealt in, stored or handled by any facility covered by the plan for which a SDS or its equivalent has not been submitted as part of the plan; or

A change in the method or operation utilized for the early detection of a discharge to groundwater (i.e., change in a method of leak detection).

Table 1-1 lists the amendments to this ODCP.

Table 1-1. Record of Reviews and Amendments

Amendment

Changes &

Effected Information Date Name Signature

1 Change in Operator; Change in leak detection for piping 9/20/2016 Sridhar Susarla

1.6 Plan Distribution

The master copy of the ODCP is kept in the Pentagon WHS ESEB. The master copy includes any records of revisions and amendments, any written inspection procedures, records of inspections, and records of spills. An additional copy is kept at the HRP. The completed ODCP is also provided to the VDEQ.

2.0 FACILITY INFORMATION

The following sections present general information on the facility, including facility operator contact information and a description of the facility.

2.1 Facility Operators [9VAC 25-91-170A.2]

Facility operations are under the direction of:

Mr. Sajeel Ahmed

Department of Defense

Pentagon, Room 2E1008

Washington, D.C. 20301-1155

(703) 697-7241

2.2 Facility Description [9VAC 25-91-170A.3]

General information about the site is provided in Table 2-1. A layout of the HRP is provided as

Figure 2-1.

Table 2-1. Pentagon Heating and Refrigeration Plant

FACILITY NAME Pentagon Heating and Refrigeration Plant

TYPE OF FACILITY Heating and Refrigeration Plant

DATE OF INITIAL OPERATION 1995

PHYSICAL ADDRESS Southeast of the Pentagon Building across Virginia

Route 110

COUNTY Arlington

PHONE NUMBERS 24-HOUR PFPA (703) 697-5555

DAY (703) 697-4478

FAX (703) 693-7203

PRIMARY CONTACT NAME Joe Eichenlaub

POSITION Manager, Pentagon Environmental, Sustainability, and

Energy Branch (ESEB)

ADDRESS MF737

WORK PHONE (703) 614-9583

CELL PHONE (703) 785-1997

SECONDARY CONTACT NAME Donald Kuney

POSITION Manager

ADDRESS Pentagon Heating and Refrigeration Plant

WORK PHONE (703) 697-4478

CELL PHONE (571) 256-1353

Figure 2-1. HRP Layout

3.0 DESCRIPTION OF STORAGE AND CAPACITIES [9 VAC 25-91-170A.4, 5]

This section includes a summary of the types of storage tanks, materials and quantities stored, and areas at the facility that are required to be covered under the ODCP. Tanks and containers included in this plan are aboveground storage tanks, underground storage tanks, oil/water separators, mobile or portable storage tanks, transformers, and loading/unloading areas. The area where each item is located is also identified. Safety Data Sheets (SDSs) are located in Appendix

A. Figure 3-1 shows the oil storage locations at the HRP.

3.1 Aboveground Storage Tanks

This section includes a summary of aboveground storage tanks located at the HRP, developed through the field survey. Table 3-1 provides information identifying the tank’s location, capacity, material, types of material stored, years installed, and types of secondary containment.

Table 3-1. Aboveground Storage Tank Summary

Tank Site Tank ID

Number Capacity (gal)

Tank

Material

Material

Stored

Year

Installed

Type of Secondary

Containment

PENTAGON HEATING AND REFRIGERATION PLANT

HRP Boiler

Fuel Oil

ASTs

HRP-1,

HRP-2

2 @ 300,000 gallon/tank

Welded

Steel

#2 Fuel Oil 1995 Concrete Dike

HRP

Incinerator

Day Tank

HRP-3 1 @ 600 gallon Welded

Steel

#2 Fuel Oil 1995 Concrete Dike

HRP Fire

Equipment

AST

HRP-4 1 @ 120 gallon Welded

Steel

#2 Fuel Oil 1995 Concrete Dike

HRP

Access

Lane

Generator

HRP-5 1 @ 200 gallon Welded

Steel

Diesel 2014 Integral Secondary

Containment (ISC)

SUBTOTAL: NUMBER OF TANKS 5

SUBTOTAL: OIL STORAGE CAPACITY (GAL) 600,920

The function of the two 300,000-gallon fuel oil tanks at the HRP is to store a sufficient quantity of fuel oil to operate the boilers for approximately twenty days at full capacity. During normal operations, the plant burns natural gas in its boilers. Fuel oil is only used when natural gas is unavailable, or when the Washington Gas Company has notified the HRP of an interruption in natural gas service.

The two tanks consist of vertical, cylindrical, carbon steel tanks, 20 feet in height, each with the storage capacity of 300,000 gallons at the design liquid level of 20 feet. Each tank is enclosed within a secondary containment wall that is lit at night. Each wall encloses a volume sufficient to contain the entire contents of the fuel tank it surrounds, should the tank rupture when full.

The fuel oil tanks interface with the Distributed Control System (DCS) main control room located in the main building of the HRP. The control room has indicators and alarms for the tank levels. The following local indications and alarms are provided for each fuel oil tank:

Fuel oil tank level gauges provide local indication of the fuel oil levels in the fuel oil tanks. They are installed on the sides of the tanks within the fuel oil tank containment structures;

The high level alarm located on each tank activates when the fuel oil reaches 19 feet during filling. The alarm is sent to the DCS and the fuel pumping is stopped;

When the fuel oil level falls to 8 feet, the low level alarm is activated and the signal is sent to DCS; and

When the fuel oil level in the tank falls to 3 feet, the low-low level alarm is actuated and the signal is sent to DCS. The DCS will de-energize all fuel oil supply pumps assigned to the alarming fuel oil tank to prevent damage to the pumps.

3.2 Underground Storage Tanks

No underground storage tanks (USTs) are located at the HRP.

3.3 Unloading Areas

This section includes summary information for the designated tanker truck unloading area located at the HRP. Table 3-2 provides information identifying the location, number of pads, type of material transferred, and type of secondary containment for the unloading area.

Table 3-2. Tanker Truck Unloading Area Summary

Site Number of Truck Pads

Materials

Transferred Type of Secondary

PENTAGON HEATING AND REFRIGERATION PLANT

(L-1) HRP Unloading Area 1 #2 Fuel Oil Concrete berm with collection tank and oil/water separator

The tanks are filled, as required, by a 10,000-gallon tanker truck. The fuel vendor’s contract requires them to have drip pans, sorbent materials, and the responsibility to contain and clean up any spills. The tanker unloading operation is supervised by plant personnel and the tanker driver.

The tanker truck parks on the unloading pad, directly over the sump, so that any fuel oil spillage would be collected in the sump during transfer operations. Any spillage of oil during transfer is reported immediately to the HRP On-site Manager. Tanker truck unloading standard operating procedures (SOPs) are located in Appendix B. Additionally, a fuel oil containment system is provided to limit the possibility of oil spilling into the environment. A description of this system is presented in Section 3.5.

Figure 3-1. Oil Storage Locations

3.4 Transformers

This section includes a summary of the transformers located at the HRP. Table 3-3 provides information identifying the transformer location, kilovolt-amps (KVA), oil capacity and PCB content.

Table 3-3. Transformer Summary

Location KVA

Total Oil

Capacity

Type of

Secondary

Containment

PCB

Contamination

PENTAGON HEATING AND REFRIGERATION PLANT

HRP Large Transformer Set 3 @ 20,000 6,423 gallons Aggregate None

HRP Small Transformer 1 @ 750 276 gallons Aggregate None

HRP Incinerator Transformer 1 @ 1,500 448 gallons Irregular concrete curbing (capacity –

619 gallons)

None

SUBTOTAL: OIL STORAGE CAPACITY (GAL) 7,147

3.5 Oil/Water Separators

This section includes information on the oil/water separator located at the HRP. Table 3-4 provides information identifying the location of the oil/water separator, tank capacity and discharge location.

Table 3-4. Summary of Oil and Water Separators

Location Tank Capacity Discharge Location

PENTAGON HEATING AND REFRIGERATION PLANT

HRP Transfer Oil/Water Separator 1 @ 65 gallons Oil pumped out, water to storm sewer (then ultimately to the Pentagon Lagoon)

OIL/WATER SEPARATOR CAPACITY (GAL) 65

The oil/water separator is part of the HRP’s Fuel Oil Containment System. The function of the

Fuel Oil Containment System is to prevent fuel oil spilled in the fuel oil tank enclosures and on the unloading pad from escaping into the environment.

The Fuel Oil Containment System, as shown in Figure 3-2, consists of three sumps, multiple drains, and the oil/water separator. Open sumps are located in each of the fuel oil tank enclosures. Sump pumps (SP-9 and SP-10) are located in each of the open sumps. The pumps remove liquids from their respective sumps and discharge to another sump beneath the unloading pad in front of the fuel oil pump house.

Figure 3-2. Fuel Oil Containment System

The unloading pad itself has a grating in the center, and the surface of the pad is graded so that any fuel oil spilled on the pad will drain through the grating into the sump below. Refer to

Figures 3-3 and 3-4 for diagrams of the unloading area. Figure 3-3 is a photograph of the unloading pad and Figure 3-4 is a diagram showing elevations of the unloading area. The sump pump in that sump (SP-11) removes water from the sump beneath the unloading pad and discharges to the oil/water separator, located adjacent to the unloading pad. The water discharge from the oil/water separator is piped to a pump station that leads to the Arlington County sanitary sewer system. Refer to Figure 3-5 for the as-built drawing of the Pentagon Emergency Response

Center (PERC) recently constructed near the HRP. This drawing shows the connection of the oil/water separator at manhole (A) to the sanitary sewer line shown in green. This replaces the 8”

Dip Gravity line. The sanitary sewer connects to the pump station which leads to the Arlington

County sanitary sewer system.

There are manholes located in the unloading pad and in the vault where the oil/water separator is located. These manholes provide access to SP-11 and to the oil/water separator, respectively. The oil/water separator is inspected weekly. To determine the oil level in the oil/water separator, an operator removes the manhole cover in the unloading pad, climbs into the vault, and removes the manway cover to the oil/water separator to visually inspect for the presence of oil. There is no overfill alarm on the oil/water separator. After an operator has determined that oil from the oil/water separator needs to be pumped out, a portable pump is used to pump the oil into portable oil containers for appropriate disposal.

The original piping in the fuel oil trench was replaced with double-walled piping. The new piping is schedule 40 carbon steel carrier piping with a schedule 10 gauge steel containment and

0.1” of fiberglass reinforced polyester (FRP) cladding on the exterior. A new leak detection system was also installed for the fuel oil trench. Four interstitial leak sensors were installed in ports on the supply and return lines of the piping. There are cored concrete drain holes located throughout the fuel oil trench between the pump house and the heating plant to allow rainwater to percolate into the ground. However, due to poor drainage at the north end of the trench, a sump pump was installed to remove surface water that accumulates. The sump pump has a start and stop button. There is a float switch in the sump for the sump pump. The float switch stops the sump pump automatically on low level. The sump pump is not programmed to automatically start when a high level is detected. The reason for this control is to prevent fuel oil from being pumped to the storm sewer in the event of a spill.

The sumps are inspected once per operator shift (every 12 hours) and before starting a pump.

The operator verifies that no oil is present on the surface of the water prior to starting the pump.

Additionally, the unloading pad sump is checked before starting pumps SP-9 or SP-10 to ensure that it is not already full. Pump SP-11 is not operated until the operator is assured that the oil/water separator does not contain oil.

Figure 3-3. Photograph of Unloading Area

Figure 3-4. Diagram of Unloading Area with Elevation

Figure 3-5. PERC As-built Drawing

4.0 AGENCY NOTIFICATIONS [9 VAC 25-91-170A.6]

Table 4-1 lists all federal, state, and local agencies to be notified in the event of a discharge.

Table 4-1. Agency Notification List

Emergency Notification and Spill Assistance Directory

Agency Telephone No. Notify When:

Arlington County Fire

Department

911 or (703) 228-3362 Worst case scenario spill, spill threatens local community, or assistance is required

Sheriff Office

Rescue Squad

Northern Virginia Hazardous

Material Response Team

DC Emergency Management

Agency

(202) 727-6161 (24-hr) Any spill to Pentagon Lagoon over 50 gallons

DC Department of Energy and

Environment

(202) 535-2600 Any spill to Pentagon Lagoon over 50 gallons

Environmental Protection

Agency National Response

Center

(800) 424-8802 or (202) 426-

Any spill

Virginia Department of

Environmental Quality

8am-5pm Monday-Friday (703)

583-3800

Any spill

24 Hours (800) 468-8892

Arlington County POTW Day (703) 358-6485 Spill enters or threatens to enter sanitary sewer system Evening (703) 358-6555

Fairfax County POTW (703) 323-1211

Blue Plains POTW (202) 787-2068

CHEMTREC (800) 262-8200 In the event of chemical transportation emergency, CHEMTREC provides immediate advice for those at the scene of emergencies, then promptly contacts the shipper of the chemicals for more detailed assistance and appropriate follow-up.

5.0 NOTIFICATION RESPONSIBILITES [9 VAC 25-91-170A.7]

The following sections present the procedures for emergency notification and response in the event of a release. Refer to Appendix C for the on-scene response team staff contact information.

5.1 General

The Manager of the Environmental, Sustainability, and Energy Branch is the designated Facility

Incident Commander (FIC) and is the individual assigned the responsibility for directing and coordinating all spill response actions at the HRP. The FIC has available all expertise and resources of the On-Scene Operations Team (OSOT) in determining and performing response actions. Deployment of the OSOT will be activated only if called by the FIC or his representative on scene. The OSOT provides for coordinating response to control, contain, recover and restore the environment from all hazardous spills. For spills beyond OSOT capabilities, additional assistance is provided through established agreements with local emergency services and contractors.

5.2 Activity Spill Response Center

The Pentagon Force Protection Agency (PFPA) acts as the Spill Response Center responsible for receiving all initial spill reports at the HRP and throughout the Pentagon Reservation. The Spill

Response Center operates 24 hours/day and alerts/activates the FIC and OSOT members, and coordinates required outside assistance and notification. The Spill Response Center provides all necessary communications for the proper coordination of response activities.

5.3 Various Personnel Functions

5.3.1 OSOT

The OSOT consists of representatives from various facilities throughout the Pentagon

Reservation (including the HRP) and contains a balance of technical and labor personnel. The

OSOT supports the FIC as a planning group for the preparation, implementation, and updating of this plan, and as an Emergency Response Team for conducting response operations during actual incidents. The functions of the FIC and OSOT members are outlined below.

5.3.2 FIC (WHS ESEB Manager)

Acts as the designated FIC responsible for directing and coordinating all on-scene spill response actions.

Activates or authorizes the activation of all or part of the OSOT as required during an incident response.

Coordinates all required notifications to Federal, state, or local agencies and the news media, with the ESEB Office Manager.

Coordinates all required assistance from Federal, state, or local response organizations and private contractors.

Coordinates, where applicable, sampling and testing of the affected lands and/or waterways to monitor the extent and/or degree of pollution caused by the spill, including periodic sampling of on-site waterways for background information.

Maintains official records and photographs documenting the extent of the spill and all containment, cleanup and recovery actions taken and procedures used.

5.3.3 Hazardous Waste Coordinator (HWC)

Designated Leader of the OSOT Immediate Response Team.

Designates, trains, and maintains on 24-hour alert an Immediate Response Team consisting of trained personnel, fully equipped with hazardous materials equipment, to provide initial control, emergency rescue, and hazard mitigation at the scene of a hazardous spill.

Responds to all spill emergency calls and assumes on-scene command. Evaluates the severity of the situation and directs immediate response action to protect life and property with due regard for the environment.

Initiates action to contain and control a hazardous spill. Performs cleanup operations of small spills, without jeopardizing fire-fighting capabilities, if and only when it is absolutely necessary to safeguard human life and health or the environment from further spill complications.

Coordinates with the safety officer to ensure air monitoring to measure toxic and explosive vapor concentrations and define a hazardous area and evacuation area.

Coordinates with the Navy Public Works Center and the HRP to take spill equipment to the spill locations.

5.3.4 Chief of Security Police (PFPA)

Provides initial action to secure the spill area, control traffic, and assist when site evacuation is required as directed by the FIC.

Ensures routine checking of hazardous materials storage areas and facilities during non-duty hours, including holidays, to assure they are not being tampered with, subjected to unauthorized use, or display evidence of leaks or spillage.

Ensures patrolling units are familiar with potential spill areas and reports all areas that appear to be suspect.

5.3.5 Safety or ESEB

Provides technical assistance and advice to the Hazardous Waste Coordinator

(HWC).

5.3.6 Safety Officer (Director of the Safety Office)

Provides technical assistance and advice to the FIC with respect to the health and safety of personnel.

Ensures that response personnel have the proper protective equipment and are trained in its care and use.

Ensures immediate dispatching of medical personnel and ambulance(s) to the spill site, upon emergency call, to assist injured personnel.

Ensures emergency treatment is rendered as necessary and injured personnel are removed to the hospital for treatment.

Ensures hospital staff is familiar with the symptoms of exposure to hazardous substances used at the HRP, and can provide the necessary treatment or obtain it from other qualified facilities.

Provides the FIC with current and follow-up information on injured personnel as soon as possible.

5.3.7 Public Affairs Officer

Responds to oil spills at the FIC's request.

Keeps abreast of all Pentagon actions during a spill to be able to provide prompt and accurate information to concerned parties on the nature of the spill and the steps being taken to correct the problem.

Clears all news media released involving facility actions with the proper internal agencies.

Prepares and directs a public awareness program to inform activity personnel about spill prevention programs and individual responsibilities in initial spill response.

5.3.8 General Counsel

Responds to oil spills at the FIC’s request, to ensure that all necessary legal information, records, and samples are obtained and safeguarded for possible future use in legal actions, or for the purpose of cost recovery.

Advises the FIC on the legal aspects of spill response.

5.3.9 Supervisory Personnel at Spill Location

Reports immediately to the Security Office any spill or accident involving hazardous substances.

Coordinates all immediate actions to be taken by site personnel in case of an oil spill, as established in this plan.

Advise FIC of the spill situation upon arrival, and furnish facility information as necessary during response operations.

6.0 SPILL CONTAINMENT AND CLEANUP RESPONSIBILITIES [9 VAC 25-91-

170A.8, 9]

6.1 Emergency Notification and Actions for Discoverer/Spiller

Any individual discovering a spill, or a situation that may lead to a spill of oil, shall immediately take the following actions. The order of these actions will depend on existing conditions:

Evacuate the area to a safe distance upwind and upgrade from the spill;

Spread the word to people in adjacent spaces;

Inform your supervisor or supervisor of the nearest facility; and

Report the spill immediately to the Facility Incident FIC (Appendix C).

Whenever possible, provide the following information on the Spill Incident Report Log Sheet

(Appendix D). Do not wait until all information on the spill is available.

Your name and telephone number;

Location of the spill;

Date and time of spill;

Type of material discharged;

Estimate of total quantity discharged;

Source of spill (e.g., tank container);

Description of affected media;

Cause of discharge;

Number and type of injuries and damage caused;

Behavior of spilled material (reactions, leak, spill, fire observed);

Anticipated movement of spill and actions begin taken;

Whether an evacuation may be needed; and

Names of individuals and/or organizations who have also been contacted.

Do not allow unauthorized persons to enter the spill area. Restrict all sources of ignition -smoking, combustible engines, and open flames. Wait for the Incident Commander and the

OSOT to arrive and direct them to the spill. Provide information and assistance as instructed.

At FIC Request:

Activate/alert appropriate OSOT members. Appendix C contains telephone directory of all OSOT members. Log exact time of each notification in the Spill

Incident Log Sheet (Appendix D);

Contact Arlington County Fire Department for assistance (Section 4);

Activate local emergency response organizations or cleanup contractor as directed. Section 7 contains telephone numbers of assistance organizations;

Coordinate any additional assistance with the Spill Response Center; and

Coordinate the transfer of onsite spill response equipment to the spill site. A list of equipment available is located in Section 9.

6.2 General Spill Response Actions (OSOT)

6.2.1 On-Scene Command

The Manager of the Environmental Department is the FIC. This individual will activate the spill response and develop an immediate plan of action.

The Alternate FIC (AFIC) is designated as the manager of the HRP. The AFIC is responsible for performing initial spill response procedures and serving as FIC until the designated FIC arrives at the scene. Refer to Appendix C for the name and contact information of the AFIC.

6.2.2 Immediate Action

The FIC will assess the situation and take immediate actions to protect people and property and avoid loss of life. The FIC will direct and coordinate the following concurrent efforts of the

OSOT emergency units:

Initial Response: Arlington County Fire Department

Rescue/Evacuate all personnel from areas that may be exposed to the spilled substance, especially to vapors, smoke, or fire.

Secure gas and electricity as soon as possible to reduce potential for fire or explosion. Remove ignition sources, such as combustion engines, electric motors, cigarette smoking, and open flames.

Control Fire if any.

Prevent spill from spreading, if possible, without risking exposure to the spilled material.

Warning: Rescue team shall enter a high-risk area only in the event of hazard imminent to life, and shall wear full protective gear, including Self-Contained

Breathing Apparatus.

Responding Paramedics

Administer first aid to injured personnel. If substance(s) known, consult appropriate technical references and SDSs (Appendix A) for First Aid measures and symptoms of exposure. Avoid all contact with the contaminant(s).

Transfer all injured to hospital for medical attention as soon as possible.

Alert hospital.

Security (PFPA)

Clear area of nonessential personnel.

Establish and control a patrolled perimeter at a safe distance from the affected area, to divert traffic and control public access.

Concurrent with immediate emergency actions, the FIC shall initiate the following actions:

Establish a command post at a safe distance upwind from the incident;

Activate other OSOT members, as required. Designate a safe location and advise the responding units to stage at such location until instructed to take specific action; and

Notify Director - FSD of the spill. Determine whether or not spill needs to be reported to the National Response Center (800-424-8802) and any state or local agencies.

An oil spill needs to be reported to the National Response Center if it is in such quantities as

“may be harmful” to the public health or welfare or the environment of the United States. As defined by 40 CFR 110.3, this includes discharges of oil that:

Violate applicable water quality standards, and

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.

Maintain an incident log of all actions taken during the course of the response, using the Oil

Incident Log Sheet provided in Appendix D.

6.2.3 Site Control and Evaluation Actions

Promptly after arrival to the site, the OSOT will initiate actions to establish control of the affected area, so that effective stabilization of the spill is achieved with minimal risk to response personnel and the environment.

Site Control

The following general rules shall apply in performing site control and evaluation operations:

Arlington County Fire Department will establish and control the work and safety zones within the control site, consisting of the support area (command post, upwind), contamination reduction area (decontamination station), and contaminated area (immediate spill area in which actual or potential danger exists from the hazardous condition). PFPA will be used to enforce security and safety zones;

Arlington County Fire Department in cooperation with PFPA will identify entrance and exits from the contaminated area and establish emergency escape routes;

Only personnel with proper protective equipment and an assigned activity will enter the contaminated area;

Decontamination procedures must be established to control the spread of contaminants into the clean areas. The Decontamination Station shall be operational before personnel are allowed to enter into the contaminated area;

Entry team shall be thoroughly briefed prior to each entry. They will also be debriefed after decontamination;

All personnel and equipment leaving the contaminated area will be considered contaminated and will pass through the Decontamination Station for proper decontamination. Decontamination Station personnel will also wear protective equipment proper to their function and risk;

All spent wash and rinse solutions, brushes, sponges, etc. used in decontamination considered as contaminated and shall be decontaminated or disposed;

Security will establish a patrolled perimeter at a greater distance from the spill, to keep nonessential personnel and the public away from the control site; and

All non-response personnel within the perimeter affected by the control site will be removed from this area.

Evacuation

The FIC will perform the following:

Determine the need for evacuation of personnel from areas outside the control site. Evacuation distances and directions will be defined based on consultation of the appropriate technical references (e.g., DOT Emergency Response Guidebook), expert advice (e.g., Fire Chief in case of actual potential fire or explosion), actual conditions (e.g., confined spaces, movement of toxic fumes), and the site-specific contingency plan;

If personnel need to be evacuated, notify Director - FSD who shall initiate and coordinate an evacuation procedure (refer to Appendix C for contact information); and

If evacuation of the civilian community near the Reservation becomes necessary or advisable, immediately notify the Director - FSD who should coordinate the procedure with local officials.

Evaluation

The FIC shall direct actions to define the hazards involved and severity of spill as quickly, safely, and completely as possible. The FIC will use the Log and Evaluation sheets provided in

Appendix D, to record information gathered during these actions

If necessary, an entry team properly equipped will carefully monitor the conditions near the immediate spill area and its surroundings, and take necessary samples to determine actual/potential dangers:

Possibility of fire/explosion;

Oxygen deficiency--particularly in confined spaces;

Presence of toxic gases or vapors;

Presence of incompatible materials; and

Possibility of dangerous vapors affecting surrounding area.

Every attempt shall be made to assess the situation from a safe distance. Response personnel shall wear proper breathing apparatus and protective gear, if necessary, to approach the spill. A backup team shall stand by to provide support. Entry team shall approach the spill from upwind assuming worst-case ambient concentration of the substance.

The following factors will drastically influence the proper precautionary measures, spill control methods, and necessary resources (i.e., personnel and equipment) for stabilization of the incident:

Substance characteristics;

Quantity spilled and physical state;

Actual/potential hazards;

Weather conditions;

Spill movement;

Existing containment barriers--natural or man-made;

Existing drainage; and

Distance to environmentally sensitive or highly populated areas.

6.2.4 Spill Containment and Control

The FIC shall ensure all appropriate safety precautions are taken, the best control methods have been selected, and proper spill response equipment is available. Control of immediate hazards, such as from fire, explosion, or toxic gas release, shall have top priority. Depending on the type and condition of the spill, some or all of the following procedures may be employed.

Spill on Fire

Decide whether to extinguish fire or let it burn. Weigh hazards of fighting fire and post-fire cleanup against benefit of possible salvage. Suggested criteria for "burn/no burn" decisions are given in Table 6-1.

Table 6-1. Suggested Criteria for "Burn/No Burn" Decisions

Criteria Allow to Burn Extinguish

Spill location Isolated away from public and buildings

Proximity to public and buildings

Availability of safety equipment Limited Self-contained breathing and protective clothing

Population density Low, evacuated High, not evacuated

Presence of other combustible materials

None present Hazardous materials; petroleum or natural gas transmission or storage;

wooded areas; and other combustible structures

Substance spilled High vapor pressure

High toxic vapors

Non-toxic combustion produced

Low vapor pressure

Low toxic vapors and fumes

Hazardous by-product(s) products from combustion

Containment status Complete Uncontrolled

Release from source Continuing Stopped

Availability of foams, dry chemicals, or powders

Limited Sufficient

Wind conditions Calm Strong, gusty

Note: The OSOT library contains valuable references for control of fire situations or flammable substances during spills, including:

The EPA Flammable Hazardous Substances Emergency Response Handbook:

Control and Safety Procedures, and

The NFPA HM Fire Protection Guide.

If decision is to extinguish fire, fight the fire, being careful to use fire-fighting methods compatible with the substance(s) involved. Know exactly what substances are involved, the amounts stored, exact locations, reactions to water or other chemicals, and safe distance to fight the fire. Stay upwind of the smoke. Remain at a safe distance from burning bottles, drums, and cans. These are not vented and may rupture violently, spreading toxic chemicals. Cool nearby containers and buildings to prevent fire from spreading. Use as little water as possible to minimize spreading of contaminants. Control runoff water in as small an area as possible, away from the firefighting activity.

Seek assistance from Fire Department if necessary to control fire. See Appendix C for point of contact.

After extinguishing fire, institute any action required to further control the spill, following the procedures described below for substances not on fire. If appropriate, reevaluate the situation and take necessary precautionary measures (e.g., readjust control perimeters).

Spill Not on Fire

The methods chosen for containment/control of spread of the spill material will depend on the type of spills, materials involved, and incident location. Table 6-2 describes various techniques applicable to different scenarios and identifies the type and location of equipment required.

Stop source of spill if it is still occurring, through such actions as:

Close valves;

Plug leaks in containers;

Upright container;

Replace leaking containers;

Empty leaking containers into non-leaking container; and

Encapsulate leaking container into large recovery container.

Table 6-2. Methods for Spill Control and Containment

Technique Use/Scenario

Equipment

Requirements

Equipment

Characteristics

Equipment

Location

Source Control

Patching

Plugging

Valve shut-off

Up righting/draining container

Stop release from leaking container or valve

Leak control kit

Hand tools

Spark-resistant tools, nonferrous

Spill site

Hazardous

Waste Storage

Facility

Gas/Vapor Reduction Control/mitigate immediate hazard from flammable, explosive, and toxic gases/vapor

Portable fans, blowers

Firefighting foams

Water sprays/mists

Sorbent pads/sheets

Explosion-proof electrical equipment

No power tools

Inert, nonreactive absorbent special for vapor control

Hazardous

Waste Storage

Facility

Fire

Department

Drains Covering Avoid liquid spill runoff into floor/storm drains

Cover sheets

Plastic

Rubber

Chemical resistant

Hazardous

Waste Storage

Facility

Spill site

Dust Covering Prevent dispersion of powder chemical spills

Cover sheets Chemical resistant

Hazardous

Waste Storage

Facility

Spill site

Herding Prevent expansion of liquid spills on land or insoluble, floating spills in water

Brooms

Water hose stream

Compressed air

Inert, nonreactive broom material

Hazardous

Waste Storage

Facility

Fire

Department

Table 6-2. Methods for Spill Control and Containment

Technique Use/Scenario

Equipment

Requirements

Equipment

Characteristics

Equipment

Location

Diking/Damming Contain liquid runoff or water stream contaminated by soluble or miscible spill

Earth moving equipment and tools

Foams

(polyurethane)

Absorbent barriers

(sealed booms, pillows, sandbags)

Inert, nonreactive sorbent material

Spark-resistant tools, nonferrous

Hazardous

Waste Storage

Facility

Outside contractor

Ditch/Trench Excavation, Culverts

Divert liquid spills on land or water stream to containment

Earth moving equipment and tools

Prefabricated culvert

Spark-resistant tools, nonferrous

Hazardous

Waste Storage

Facility

Spill site

Floating Barriers Contain insoluble floating spills

Booms

Device to deploy booms

Chemical resistant

Absorption Contain, collect and remove liquid spill on land or insoluble floating spills in water

Sorbents

Sheets

Mops

Pillows

Booms

Granular

Inert, nonreactive materials

Specific sorbent for specific spill substance

Hazardous

Waste Storage

Facility

Spill site

General considerations for stopping source of releases are given in Table 6-3.

Table 6-3. General Considerations for Stopping Source of Releases

Criteria Attempt No Attempt

Availability of safety equipment Sufficient None

Nature of discharge Open valve or pump failure Rupture or explosion

Type of substance Toxic, nonreactive, nonvolatile, nonpersistent

Highly toxic, dangerously reactive, volatile, corrosive persistent

Volume spilled/volume remaining ratio

Low High

Containment of spillage None Present and sufficient

Rate of discharge Slow, dripping Fast, streaming

Size of hole or rupture Small Large

Potential of fire No potential Already existing

Relative difficulty in stopping discharge

Easy Great

In no instance should an attempt be made to stop a discharge without the proper protective clothing and safety equipment. If the spill cannot be contained and enters, or threatens to enter, the sanitary or storm sewer systems, then the FIC shall perform the following:

Anticipate the movement of the spill. Consult site-specific contingency plan for probable spill routes and secondary containment options, and implement containment options;

Instruct Pentagon Labor forces to take all necessary and possible action (construct dam, deploy temporary interception devices, etc.) to prevent the spill runoff from exiting base property;

Determine the fate of the spill; and

Verbally notify the Director – FSD (Sajeel Ahmed, 703-697-7241) of the incident.

Procedures applicable for controlling the spread of spill contamination, once it has entered the waterways, will depend on location, amount spilled, and properties of the material spilled.

Control methodology shall depend most strongly on how the material behaves in water (i.e., floats or sinks).

See Appendix C for points of contact.

6.2.5 Cleanup and Disposal

Cleanup and disposal are the responsibility of the Hazardous Waste Coordinator under the authority of the FIC. Cleanup method will depend on the characteristics of the spilled material, size of spill, location of spill, character of the area, and potential impacts. Table 6-4 describes standard cleanup methods applicable to many HS spills.

Table 6-4. Methods for Spill Cleanup

Technique Use/Scenario

Equipment

Requirements

Equipment

Characteristics

Equipment

Location

Absorption Contain, collect and remove liquid spill on land or insoluble floating spills in water

Sorbents sheets mops pillows booms granular

Inert, nonreactive materials

Specific sorbent for specific spill substance

Hazardous Waste

Storage Facility

On-Site

Neutralization

Neutralize acids or alkalis spills to acceptable pH (6-8) pH meter or litmus paper

Neutralizing solution

Neutralizer must be weak

Acid spills:

sodium bicarbonate, soda ash, or lime

Alkaline spills:

weak acetic acid or citric acid

Hazardous Waste

Storage Facility

Dilution Dilute concentrations of liquid spills on land to acceptable limits.

Highly soluble unreactive in water chemicals only.

Water hose stream Inert, nonreactive Fire Dept.

Excavation Remove solid liquid spill substance and contaminated medium for proper disposal

Earthmoving equipment and tools

Disposal drums

Spark-resistant tools Spill site

Skimming Remove insoluble floating spills

Skimmer Specialized equipment

Outside contractor

Dredging/Pumping Remove insoluble, nonfloating and contaminated medium from bottom of a body of water

Dredging equipment

Pump

Specialized equipment

Outside contractor

Suction Remove liquid spills from land or water surface

Vacuum Truck Specialized Outside contractor

The FIC shall ensure that cleanup efforts are sufficient to meet regulatory requirements, prevent risk to health and safety of the public, prevent further contamination, and restore environmental quality of the affected area. The Hazardous Waste Coordinator or his designate will direct efforts to:

Collect all necessary samples of the affected lands/waters to determine degree of contamination;

Determine applicable cleanup method. Determine whether the spill material can be treated on site or must be removed, treated, or disposed of elsewhere. Consult appropriate technical references or information sources to determine correct procedures for cleaning up spill of the specific substance involved; and

Assess Cleanup Team capabilities to conduct cleanup operations and determine needs for outside assistance.

If decision is to clean up spill with Pentagon Reservation resources, the Hazardous Waste

Coordinator will assemble the proper Cleanup Team. Cleanup personnel shall use proper protective equipment and observe the standard health and safety procedures.

The Cleanup Team will perform the following duties:

Treat spill to mitigate hazards (i.e., neutralization) if safe and feasible;

Clean up and remove spill material using proper cleaning method;

Thoroughly clean all contaminated surfaces of the spilled material. Detergents and solvents can be used to remove residual spill material from loading docks, asphalt, and other hard, impermeable surfaces;

Collect spill residue, other contaminated material, and all non-reusable cleanup materials, including disposable clothing, sorbents, brushes, rags, brooms, and containers. Package material in DOT approved container. Mark and label container in accordance with DOT requirements;

Thoroughly decontaminate and inspect all reusable protective clothing and equipment before they are returned to their proper storage location; and

Thoroughly ventilate indoor areas.

If it is decided that cleanup is beyond the capabilities of the OSOT, the FIC shall activate the appropriate contract or agreement for the cleanup as established in this plan or coordinate any required additional assistance with the Director - FSD. In the event of cleanup by outside contractor or agency, the FIC shall maintain on-scene command and support cleanup as needed.

After the spill cleanup, the FIC shall:

Ensure that all hazardous waste and contaminated articles generated by a spill and cleanup incident are properly containerized, stored, manifested, and turned in to

Hazardous Waste Storage Facility for disposal according to the Pentagon

Reservation Hazardous Waste Management Plan;

Ascertain that all indoor areas affected by the spill are safe before normal operations in those areas are resumed; and

Determine the need for necessary environmental restoration activities. NAVFAC

Washington can provide technical support in assessing the environmental impact of the spill, the effectiveness of cleanup operations, and assist in developing a plan to restore the environmental quality of the affected area if necessary.

6.2.6 Documentation and Cost Recovery

All personnel involved in the spill response efforts shall prepare a report describing their participation in the response and submit their report to the FIC within 10 calendar days following the incident. The report shall contain the following information:

Description of response activities;

Time and duration of response activities;

Listing or personnel and equipment involved;

Identification of any injuries or damages incurred; and

Discussion of problems, suggestions, etc.

7.0 OUTSIDE SPILL RESPONSE ORGANIZATIONS [9 VAC 25-91-170A.10]

In addition to the in-house organizations and personnel designated in Section 8, the Pentagon

Reservation has made arrangements with local emergency organizations and cleanup contractors to supplement in-house spill response resources and expertise. A list of these organizations is presented in Table 7-1. Appendix E describes all pre-established cooperation agreements made between the Pentagon Reservation and said organizations.

Table 7-1. Outside Response Organizations

Emergency Response Contractors

Bishop & Associates Incorporated

1611 Bush Street

Baltimore, MD 21230

(410) 468-0400 (offsite)

(703) 692-4114 (onsite)Contact:

Dave Mundt

Worst case scenario spill/spill requires assistance

Clean Harbors Co.

3527 Whiskey Bottom Road

Laurel, MD 20724

(Oil, Haz-Mat)

(301) 939-6000

(800) OIL-TANK (645-8245)

Worst case scenario spill or spill requires assistance

Spill Remediation Contractors

Earth Tech

2229 Tomlynn Street

Richmond, VA 23230

(Oil, Haz-Mat)

(804) 358-5858

Spill Clean Up

Clean Harbors Co.

3527 Whiskey Bottom Road

Laurel, MD 20724

(Oil, Haz-Mat)

(301) 939-6000

(800)…