J-0200000-13 Installation Spill Control Plan.pdf

SPILL PREVENTION, CONTROL, AND

COUNTERMEASURES PLAN

Naval Submarine Base New London

Groton, Connecticut

Prepared by:

Naval Facilities Engineering Command, Atlantic Environmental Compliance

January 2015

Naval Submarine Base New London CT SPCC January 2015 i

Table of Contents

COMPLETION OF REVIEW/MANAGEMENT APPROVAL ............................................. iv

PROFESSION ENGINEER CERTIFICATION ................................................................. v

RECORD OF REVIEW / AMENDMENTS ....................................................................... vi

1.0 PLAN ADMINISTRATION

1.1. Purpose

1.2. Certification of Substantial Harm Determination [40 CFR 112.20(e)]

1.3. Designated Person [40 CFR 112.7(f)(2)]

1.4. Professional Engineer Certification [40 CFR 112.3(d)]

1.5. Location of SPCC Plan [40 CFR 112.3(e)]

1.6. SPCC Plan Review [40 CFR 112.5(b)]

1.7. Amendments of SPCC Plans [40 CFR 112.5(a)]

1.8. Management Approval [40 CFR 112.7]

1.9. Cross-Reference with SPCC Provisions [40 CFR 112.7]

2.0 GENERAL FACILITY INFORMATION

2.1. Facility Description [40 CFR 112.7(a)(3)]

2.1.1. Location and Activities

2.1.2. Facilities Not Yet Fully Operational [40 CFR 112.7]

3.0 GENERAL REQUIREMENTS FOR SPCC PLANS

3.1. Conformance with Requirements [40 CFR 112.7(a)(1)]

3.2. Environmental Equivalence [40 CFR 112.7(a)(2)]

3.2.1. Concrete Encased Tank Inspection Procedures

3.2.2. Preventing Physical Damage to Aboveground Piping

3.3. Spill Reporting [40 CFR 112.7(a)]

3.3.1. Contact List [40 CFR 112.7(a)(3)(vi)]

3.3.2. Discharge Notification Procedures [40 CFR 112.7(a)(4) & 112.7(a)(5)]

3.4. Predicted Quantity of Oil Discharged [40 CFR 112.7(b)]

3.5. Secondary Containment to Address Typical Failure Modes [40 CFR 112.7(c)]

3.5.1. Bulk Storage Containers

3.5.2. Drum Storage Areas

3.5.3. Mobile Equipment

3.5.4. Mobile Refuelers and Other Non-Transportation-Related Tankers

3.5.5. Loading Racks

3.5.6. Oil Filled Operational Equipment

3.6. Practicability of Secondary Containment [40 CFR 112.7(d)]

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

3.8. Oil-Handling Personnel Training [40 CFR 112.7(f)]

ii

3.8.1. Annual SPCC Training [40 CFR 112.7(f)(1)]

3.8.2. Annual Oil Handler Discharge Prevention Briefings [40 CFR 112.7(f)(3)]

3.9. Security [40 CFR 112.7(g)]

3.10. Tank Truck Loading/Unloading Racks [40 CFR 112.7(h)]

3.11. Brittle Fracture Evaluation [40 CFR 112.7(i)]

3.12. Conformance with State and Local Applicable Requirements [40 CFR 112.7(j)]

3.13. Qualified Oil-Filled Operational Equipment [40 CFR 112.7(k)]

4.0 SPCC PLAN REQUIREMENTS FOR ONSHORE FACILITIES (EXCLUDING

PRODUCTION FACILITIES)

4.1. Diked Storage Area: Restrain Stormwater [40 CFR 112.8(b)(1) and (2)]

4.2. Facility Drainage: Design and Equipment [40 CFR 112.8(b)(3) and (4)]

4.3. Facility Drainage: Pump Transfer [40 CFR 112.8(b)(5)]

4.4. Bulk Storage Container Construction [40 CFR 112.8(c)(1)]

4.5. Secondary Containment for Largest Bulk Storage Container [40 CFR 112.8(c)(2)] . 21

4.6. Diked Area Drainage [40 CFR 112.8(c)(3)]

4.7. Corrosion Protection for Buried Storage Tanks [40 CFR 112.8(c)(4) and (5)]

4.8. Test or inspect each aboveground container for integrity [40 CFR 112.8(c)(6)]

4.9. Heating Coils [40 CFR 112.8(c)(7)]

4.10. Overfill Prevention [40 CFR 112.8(c)(8)]

4.11. Liquid Level Sensing Devices [40 CFR 112.8(c)(8)(v)]

4.12. Effluent Treatment Facility Observations [40 CFR 112.8(c)(9)]

4.13. Correct Visible Discharges [40 CFR 112.8(c)(10)]

4.14. Secondary Containment for Mobile or Portable Container [40 CFR 112.8(c)(11)]

4.15. Corrosion Protection for Buried Piping [40 CFR 112.8(d)(1)]

4.16. Terminal Connections [40 CFR 112.8(d)(2)]

4.17. Pipe Supports [40 CFR 112.8(d)(3)]

4.18. Piping, Aboveground Valves and Appurtenances [40 CFR 112.8(d)(4)]

4.19. Vehicle Warning [40 CFR 112.8(d)(5)]

5.0 FACILITY INFORMATION

5.1. Oil Container Inventory Summary

5.2. Site-Specific Information

5.2.1. Tank Systems Data Sheets & Maps

5.2.2. Drum Storage Area Sheets & Maps

5.2.3. Mobile Equipment/Container Storage and Operating Area Sheets & Maps

5.2.4. Mobile Refueler Parking Area Sheets and Maps

5.2.5. Loading Racks

5.2.6. Oil-Filled Operational Equipment Tables

6.0 DISCHARGE RESPONSE

6.1. Discharge Prevention Measures

6.2. Discharge or Drainage Controls

iii

6.3. Discharge Discovery Countermeasures

6.3.1. Initial Spill Discovery Actions

6.3.2. Spill Reporting Procedure

6.4. Spill Response Capability

6.5. Methods of Disposal of Recovered Material

APPENDIX A: CERTIFICATION OF THE APPLICABILITY OF THE SUBSTANTIAL

HARM CRITERIA CHECKLIST ........................................................ A-1

APPENDIX B: SPCC DEFICIENCIES ...................................................................... B-1

APPENDIX C: ASSUMPTIONS AND CALCULATIONS .......................................... C-1

APPENDIX D: STANDARD OPERATING PROCEDURES ..................................... D-1

APPENDIX E: CONTAINER INSPECTION FORMS ................................................. E-1

APPENDIX F: BERM INSPECTION AND DRAINAGE INSTRUCTIONS ................. F-1

APPENDIX G: INTEGRITY TESTING PROGRAM ................................................... G-1

APPENDIX H: NOTES AND OBSERVATIONS ....................................................... H-1

APPENDIX I: OIL FILLED OPERATIONAL EQUIPMENT ....................................... I-1

APPENDIX J: STORAGE TANK MANAGEMENT PLAN ......................................... J-1

APPENDIX K: SPCC TRAINING RECORD ............................................................. K-1 iv

Completion of Review/Management Approval

In accordance with 40 CFR 112.5(b), I have completed review and evaluation of this Spill Prevention, Control, and Countermeasures Plan for Naval Submarine Base New London and, as a result, have amended the Plan on this date. Interim amendments made after this date will be documented in the Record of Review and Amendments on page vi of the Plan. A full review will again be accomplished within five years from this date.

In accordance with 40 CFR 112.7, this plan is approved and will be implemented as described herein utilizing all necessary resources.

Carl A. Lahti Date Captain, U.S. Navy Commanding Officer U.S. Naval Submarine Base New London Groton, CT v

Professional Engineer Certification [40 CFR 112.3(d)]

The undersigned licensed Professional Engineer attests:

(i) That I am familiar with the requirements of 40 CFR part 112.

(ii) That I have visited and examined the Facility.

(iii) That the Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of 40 CFR part 112.

(iv) That procedures for required inspections and testing have been established.

(v) That the Plan is adequate for the Facility.

(vi) That, if applicable, for a produced water container subject to §112.9(c)(6), any procedure to minimize the amount of free-phase oil is designed to reduce the accumulation of free-phase oil and the procedures and frequency for required inspections, maintenance and testing have been established and are described in the Plan.

This certification in no way relieves the owner or operator of the Facility of his/her duty to prepare and fully implement this Plan in accordance with the requirements of 40 CFR part 112.

This Plan is valid only to the extent that the Facility owner or operator maintains, tests, and inspects equipment, containment, and other devices as prescribed in this Plan.

________________________ VA 0402031686______

Signature License Number

Richard Padgett Environmental Engineer Name Title

NAVFAC-ATLANTIC 30 January 2015______ Company Date vi

Record of Review and Amendments

All reviews and amendments to this plan will be summarized below and signed by a Professional Engineer (PE) or Point of Contact (POC). A PE must certify technical amendments in accordance with § 112.3(d).

Amend-ment No.

Date Section/ Pages

Affected

Description of Changes

PE or POC Name

PE or POC Signature

New

Document

Jan

All Entire document changed in January

Richard Padgett

PE

vii

Acronyms and Abbreviations API American Petroleum Institute AST Aboveground Storage Tank CDO Command Duty Officer CFR Code of Federal Regulations COMSUBGRU Commander Submarine Group CNRMA Commander, Naval Region Mid-Atlantic CTDEEP Connecticut Department of Energy and Environmental Protection DFM Diesel Fuel Marine DLA Defense Logistics Agency DOT Department of Transportation EPA Environmental Protection Agency FIC Facility Incident Commander FR Federal Register FRP Fiberglass Reinforced Plastic GPM Gallons per minute GRI SPCC Guidance for Regional Inspectors, EPA (2013 edition) HAZMAT Hazardous Materials ICP Integrated Contingency Plan IEPD Installation Environmental Program Director LEPC Local Emergency Planning Committee MIDLANT Naval Facilities Engineering Command, Mid Atlantic min Minute MSDS Material Safety Data Sheet NAVFAC Naval Facilities Engineering Command NEX Naval Exchange NFPA National Fire Protection Association NOSC Navy On-Scene Commander OFOE Oil-filled Operational Equipment OPNAVINST Chief of Naval Operations Instruction OSHA Occupational Safety and Health Administration PE Professional Engineer PM Program Manager POC Point of Contact psi Pounds per square inch PWD Public Works Department sec Second SOP Standard Operating Procedure SPCC Spill Prevention, Control, and Countermeasures Plan STI Steel Tank Institute SUBASENLON Submarine Base New London UST Underground Storage Tank

1.0 PLAN ADMINISTRATION

1.1. Purpose

The purpose of this Spill Prevention, Control, and Countermeasure (SPCC) Plan (Plan) is to establish procedures, methods, equipment, and other requirements necessary to prevent the discharge of oil from Naval Submarine Base New London (SUBASENLON) facilities from reaching navigable waters of the United States or adjoining shorelines. The Plan is intended to prepare the owner (Commander, Navy Region Mid-Atlantic (CNRMA)), hereinafter referred to as Owner, and operator (NAVFAC Mid-Atlantic Public Works Department New London (PWD), Environmental Division), hereinafter referred to as Operator, to ensure early detection and quick response in the event of a discharge of oil and to allow the Operator to respond in a safe, effective, and timely manner to mitigate the impacts of a discharge from the containers included in this Plan. The Operator is responsible to accomplish all actions directed in the Plan.

This Plan was prepared by the Naval Facilities Engineering Command, Atlantic in accordance with the provisions of Title 40, Code of Federal Regulations (CFR), Part 112 (SPCC Rule or §112), various industry standards, and the Navy Environmental Readiness Program Manual (OPNAVINST 5090.1D). Facilities located within the facility boundary of SUBASENLON that store and transfer oil in support of Navy activities are included in this plan because the amount of oil stored and/or their location. Therefore, they may reasonably be expected to discharge oil in harmful quantities into or upon navigable waters of the United States, adjoining shorelines, into the subsurface aquifer, or outside the property onto non-Federal land.

1.2. Certification of Substantial Harm Determination [40 CFR 112.20(e)]

§112.20(e) If the owner or operator of a facility determines pursuant to paragraph (a)(2) of this section that the facility could not, because of its location, reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines, the owner or operator shall complete and maintain at the facility the certification form contained in appendix C to this part and, in the event an alternative formula that is comparable to one contained in appendix C to this part is used to evaluate the criterion in paragraph (f)(1)(ii)(B) or (f)(1)(ii)(C) of this section, the owner or operator shall attach documentation to the certification form that demonstrates the reliability and analytical soundness of the comparable formula and shall notify the Regional Administrator in writing that an alternative formula was used.

The Certification of Substantial Harm Determination is located in Appendix A.

1.3. Designated Person [40 CFR 112.7(f)(2)]

§112.7(f)(2) Designate a person at each applicable facility who is accountable for discharge prevention and who reports to facility management.

The Installation Environmental Program Director (IEPD) for PWD New London is the designated person described in §112.7(f)(2) who reports to facility management and is accountable for discharge prevention.

See Section 6 of this Plan for additional contact information.

1.4. Professional Engineer Certification [40 CFR 112.3(d)]

Professional Engineer Certification is located on page v of the Plan.

1.5. Location of SPCC Plan [40 CFR 112.3(e)]

§112.3(e) If you are the owner or operator of a facility for which a Plan is required under this section, you must:

(1) Maintain a complete copy of the Plan at the facility if the facility is normally attended at least four hours per day, or at the nearest field office if the facility is not so attended, and (2) Have the Plan available to the Regional Administrator for on-site review during normal working hours.

Environmental compliance is provided to SUBASENLON through PWD New London personnel.

In accordance with §112.3(e), a complete copy of this Plan is maintained at the COMSUBGRU TWO Headquarters Building, Environmental Office (Building 439, Room 104) hereinafter referred to as the Environmental Office. The Environmental Office is attended 0800 to 1600 (closed on Saturdays and Sundays).

1.6. SPCC Plan Review [40 CFR 112.5(b)]

§112.5(b) Notwithstanding compliance with paragraph (a) of this section, complete a review and evaluation of the SPCC Plan at least once every five years from the date your facility becomes subject to this part; or, if your facility was in operation on or before August 16, 2002, five years from the date your last review was required under this part.

As a result of this review and evaluation, you must amend your SPCC Plan within six 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. You must implement any amendment as soon as possible, but not later than six months following preparation of any amendment. You must document your completion of the review and evaluation, and must sign a statement as to whether you will amend the Plan, either at the beginning or end of the Plan or in a log or an appendix to the Plan. The following words will suffice, “I have completed review and evaluation of the SPCC Plan for (name of facility) on (date), and will (will not) amend the Plan as a result.”

The Tank Program Manager at PWD New London is responsible for initiating and coordinating comprehensive reviews of the SPCC Plan at least once every five years. The Tank Program Manager will amend this Plan within six months of the review and will implement the amended Plan within six months of the amendment to include more effective prevention and control technology if such technology will significantly reduce the likelihood of a spill event and if such technology has been field proven at the time of the review. Such updates are considered technical amendments and must be certified by a PE. Reviews and amendments of the Plan will be documented in the Record of Reviews located on page vi of this Plan.

1.7. Amendments of SPCC Plans [40 CFR 112.5(a)]

§112.5(a) Amend the SPCC Plan for your facility in accordance with the general requirements in §112.7, and with any specific section of this part applicable to your facility, when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge as described in §112.1(b). Examples of changes that may require amendment of the Plan include, but are not limited to: 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; or revision of standard operation or maintenance procedures at a facility. An amendment made under this section must be prepared within six months, and implemented as soon as possible, but not later than six months following preparation of the amendment.

In accordance with §112.5(a), the Plan will be amended whenever any change in the Facility design, construction, operation, or maintenance that materially affects the Facility’s potential for an oil discharge, including, but not limited to:

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 Revision of standard operation, inspection, or maintenance procedures.

Amendments to this Plan made to address changes of this nature are considered technical amendments and must be certified by a PE. Non-technical amendments can be made by the PWD New London Petroleum Tank Media Manager and include changes to contact information and other changes to this Plan that do not affect the potential for an oil discharge. All amendments, whether technical or non-technical, must be recorded in the Record of Review and Amendments page of this Plan (page vi).

Discrepancies and recommended corrective actions noted during preparation of this Plan are listed in Appendix B. When discrepancies are corrected in accordance with the recommended actions in Appendix B, the discrepancy list should be noted with a date and signature to document completion of the corrective action. Such updates are not considered technical in nature and should be recorded in the Record of Review and Amendments page of this Plan (page vi) as administrative updates.

1.8. Management Approval [40 CFR 112.7]

Management Approval Acknowledgement is located on page iv of the Plan.

1.9. Cross-Reference with SPCC Provisions [40 CFR 112.7]

§112.7 If you do not follow the sequence specified in this section for the Plan, you must prepare an equivalent Plan acceptable to the Regional Administrator that meets all of the applicable requirements listed in this part, and you must supplement it with a section cross-referencing the location of requirements listed in this part and the equivalent requirements in the other prevention plan.

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

Table 1: Regulation Cross-Reference

40 CFR 112 Regulatory Requirement Description Location

112.3(d) Professional Engineer Certification Section 1.4

112.3(e) Location of SPCC Plan Section 1.5

112.5(a) Amendments Section 1.7

40 CFR 112 Regulatory Requirement Description Location

112.5(b) SPCC Plan Review Section 1.6

112.7 Management Approval Section 1.8

Cross-Reference with SPCC Rule Section 1.9

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

Section 2.1.2

112.7(a)(1) Conformance with Requirements Section 3.1

112.7(a)(2) Environmental Equivalence Section 3.2

112.7(a)(3) Facility Information, Boundary and Facility Diagram Section 2.1.1

112.7(a)(3)(i) Container Storage Capacity and Oil Type Section 2.1.1

112.7(a)(3)(ii) Discharge Prevention Measures Section 6.1

112.7(a)(3)(iii) Discharge or Drainage Controls Section 6.2

112.7(a)(3)(iv) Discharge Discovery Countermeasures Section 6.3

112.7(a)(3)(v) Methods of Disposal of Recovered Material Section 6.7

112.7(a)(3)(vi) Contact List Section 3.3.1

112.7(a)(4) Discharge Notification Section 3.3.2

112.7(a)(5) Discharge Response Procedures Section 3.3.2

112.7(b) Predicted Direction, Rate of Flow, and Total Quantity of Oil Discharged as a Result of Equipment Failure

Section 3.4

112.7(c) Secondary Containment to Address Typical Failure Modes

Section 3.5

112.7(d) Practicability of Secondary Containment Section 3.6

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

112.7(f)(1) Oil-handling Personnel Training Section 3.8.1

112.7(f)(2) Designated Person Section 1.3

112.7(f)(3) Discharge Prevention Briefings Section 3.8.2

112.7(g) Security Section 3.9

112.7(h) Tank Truck Loading/Unloading Racks Section 3.10

112.7(i) Brittle Fracture Evaluation Section 3.11

112.7(j) Conformance with Applicable State and Local Requirements

Section 3.12

112.7(k) Qualified Oil-filled Operational Equipment Section 3.13

112.8(b)(1) Diked Storage Area: Restrain Stormwater Section 4.1

112.8(b)(2) Diked Storage Area: Drainage Valves and Inspect Stormwater

Section 4.1

112.8(b)(3) Facility Drainage: Design Section 4.2

112.8(b)(4) Facility Drainage: Equipment Section 4.2

112.8(b)(5) Facility Drainage: Pump Transfer Section 4.3

112.8(c)(1) Bulk Storage Container Construction Section 4.4

112.8(c)(2) Secondary Containment for Capacity of Largest Bulk Storage Container Plus Freeboard

Section 4.5

112.8(c)(3) Dike Drainage Section 4.6

40 CFR 112 Regulatory Requirement Description Location

112.8(c)(4,5) Corrosion Protection for Buried, Partially Buried and Bunkered Storage Tanks

Section 4.7

112.8(c)(6) Inspection of Bulk Storage Containers Section 4.8

112.8(c)(7) Heating Coils Section 4.9

112.8(c)(8) Overfill Prevention System Section 4.10

112.8(c)(8)(v) Liquid Level Sensing Device Testing Section 4.11

112.8(c)(9) Effluent Treatment Facilities Section 4.12

112.8(c)(10) Correct Visible Discharges Section 4.13

112.8(c)(11) Secondary Containment for Capacity of Largest Mobile or Portable Oil Storage Container Plus Freeboard

Section 4.14

112.8(d)(1) Corrosion Protection for Buried Piping Section 4.15

112.8(d)(2) Terminal Connections Section 4.16

112.8(d)(3) Pipe Supports Section 4.17

112.8(d)(4) Piping, Aboveground Valves and Appurtenances Inspection

Section 4.18

112.8(d)(5) Vehicle Warning Section 4.19

112.20(e) Certification of Substantial Harm Determination Section 1.2

2.0 GENERAL FACILITY INFORMATION

Facility Name: Naval Submarine Base New London

Mailing Address: Commanding Officer Box 00

Groton, CT 06349

Physical Location: Intersection of Crystal Lake Road & CT Rt. 12

Type: Operations and Training Base

Owner: Commander, Navy Region MIDLANT

Operator: NAVFAC MIDLANT PWD New London

Primary contact: Mr. Michael Brown Installation Environmental Program Director Environmental Division

Box 400 439 Tautog Avenue Room 104 Groton, CT 06349-5400

Office Phone: (860) 694-3976 michael.brown13@navy.mil

2.1. Facility Description [40 CFR 112.7(a)(3)]

2.1.1. Location and Activities

§112.7(a)(3) Describe in your Plan the physical layout of the facility and include a facility diagram, which must mark the location and contents of each fixed oil storage container and the storage area where mobile or portable containers are located. The facility diagram must identify the location of and mark as “exempt” underground tanks that are otherwise exempted from the requirements of this part under §112.1(d)(4). The facility diagram must also include all transfer stations and connecting pipes, including intra-facility gathering lines that are otherwise exempted from the requirements of this part under §112.1(d)(11). You must also address in your Plan:

(i) The type of oil in each fixed container and its storage capacity. For mobile or portable containers, either provide the type of oil and storage capacity for each container or provide an estimate of the potential number of mobile or portable containers, the types of oil, and anticipated storage capacities;

The Naval Submarine Base (SUBASENLON) is located on the east bank of the Thames River in Groton, Connecticut, approximately twelve miles south of Norwich on the intersection of Crystal Lake Road and Route 12. The facility occupies approximately 600 acres and has more than 300 structures and buildings. Figure 2.1.1 is a map depicting SUBASENLON. The latitude of the center of the facility is approximately N. 41°, 23’ 30” and the longitude is approximately W. 72°, 05’ 30.”

SUBASENLON provides the following six major services for the operational Navy fleet:

1. Maintenance and repair facilities for submarines and other assigned craft

2. Basic, advanced, and refresher submarine training courses to naval personnel

3. Ambulatory care for sailors and their families

4. Research and training on the specific medical needs of sailors who live in an undersea environment

5. Housing and support services for navy-base personnel

6. Homeport for submarines and their crews.

The Operator has determined the extent of the Facility boundary as defined in the SPCC Rule based on the ownership and operation of equipment at the Facility. The Facility consists of all the operations and land area encompassed by the perimeter security fence line plus the Polaris Park Fire House which is outside the fence line but still directly supports the mission of SUBASENLON and is under direct operational control of the Operator.

SUBASENLON operates several storage tanks which are outside the facility boundary. These tanks are located on non-contiguous geographically separate parcels and do not support the military mission of NLON. These sites include:

Sheppard of the Sea NEX Mart Child Development Center Admiral Fife Recreational Area.

The tanks at these sites are not included in this SPCC Plan, but they are included in the SUBASENLON Storage Tank Management Plan. These tanks and other STMP information are included as Appendix J of this Plan.

The only oil-containing equipment at SUBASENLON not included in this Plan is some oil-filled operational equipment (OFOE) within the security fence line associated with the electrical utility/distribution system that is not under Navy control. These assets are owned and managed by the local utility authority and are therefore not included in this Plan.

The facility diagram can be found in Section 5. Site-specific information such as oil storage container details, contents, capacity, discharge prevention measures, potential release scenarios, and appropriate secondary containment assessments, as well as discharge controls can be found in Section 5.2.1. Similar details concerning drum storage areas, mobile equipment, fuel truck parking areas, loading racks, and OFOE are found in Sections 5.2.2, 5.2.3, 5.2.4, 5.2.5, and 5.2.6 respectively. Spill response procedures, disposal procedures, and contact lists can be found in Section 6.

Two underground storage tanks (UST) fully regulated under §281 are included in this plan. Spill release scenarios relating to the transfer of oil into and out of these tanks are assessed and appropriate secondary containment measures are specified. Other release scenarios such as tank and delivery vehicle failure are not addressed.

It is noted that Building 548 is equipped with three fully-regulated underground storage tanks and a loading rack. As of the writing of this Plan, the USTs at 548 are not in service. The appropriate paperwork to reflect the inactive status of these tanks was submitted to CDEEP in November 2013. Therefore the USTs at 548 are considered out of service and will not be addressed in this Plan. If the assets at Building 548 are returned to active status, this Plan must be amended to reflect the change. Because there are regulatory requirements associated with the temporary out of service status, these assets are covered in the STMP.

2.1.2. Facilities, Procedures, Methods, or Equipment Not Yet Fully Operational [40

CFR 112.7]

§112.7 . . . If the Plan calls for additional facilities or procedures, methods, or equipment not yet fully operational, you must discuss these items in separate paragraphs, and must explain separately the details of installation and operational start-up.

The oil storage containers and operations included in this Plan are fully operational.

Naval Submarine Base New London SPCC January 2015

Figure 2.1.1. Sites covered under this SPCC Plan

POLARIS PARK FIRE

HOUSE

SUBASENLON

3.0 GENERAL REQUIREMENTS FOR SPCC PLANS

The following measures are implemented to prevent oil discharges during the handling, use, or transfer of oil products at SUBASENLON.

3.1. Conformance with Requirements [40 CFR 112.7(a)(1)]

§112.7(a)(1) Include a discussion of your facility's conformance with the requirements listed in this part.

The oil storage containers, oil-filled operational equipment, mobile containers, and all associated management processes included in this Plan conform to the requirements of the SPCC rule with the exception of the nonconformance issues noted in the text and summarized on the deficiency list included as Appendix B.

3.2. Environmental Equivalence [40 CFR 112.7(a)(2)]

§112.7(a)(2) Comply with all applicable requirements listed in this part. Except as provided in §112.6, your Plan may deviate from the requirements in paragraphs (g), (h)(2) and (3), and (i) of this section and the requirements in subparts B and C of this part, except the secondary containment requirements in paragraphs (c) and (h)(1) of this section, and §§112.8(c)(2), 112.8(c)(11), 112.9(c)(2), 112.9(d)(3), 112.10(c), 112.12(c)(2), and 112.12(c)(11), where applicable to a specific facility, if you provide equivalent environmental protection by some other means of spill prevention, control, or countermeasure. Where your Plan does not conform to the applicable requirements in paragraphs (g), (h)(2) and (3), and (i) of this section, or the requirements of subparts B and C of this part, except the secondary containment requirements in paragraph (c) and (h)(1) of this section, and §§112.8(c)(2), 112.8(c)(11), 112.9(c)(2), 112.10(c), 112.12(c)(2), and 112.12(c)(11), you must state the reasons for nonconformance in your Plan and describe in detail alternate methods and how you will achieve equivalent environmental protection. If the Regional Administrator determines that the measures described in your Plan do not provide equivalent environmental protection, he may require that you amend your Plan, following the procedures in §112.4(d) and (e).

Except as discussed in this section, this Plan does not deviate from the requirements in §112.

For instances where this Plan deviates from the requirements in the SPCC Rule, this section includes the reasons for nonconformance, detailed alternate methods, and an explanation of how equivalent environmental protection will be achieved.

3.2.1. Concrete Encased Tank Inspection Procedures

The PE certifying this Plan deviates from adherence to an accepted industry standard to meet the integrity testing provision of §112.8(c)(6) for shop-fabricated concrete-encased double-walled aboveground storage tanks included in this Plan. In accordance with §112.8(c)(6), aboveground containers must be tested or inspected for integrity on a regular schedule in accordance with industry standards. The accepted industry standard for integrity testing of shop-fabricated tanks at SUBASENLON is Steel Tank Institute's (STI) SP001 Standard for Inspection of ASTs (5th Edition). However, several Convault tanks in use at SUBASENLON are concrete-encased double-walled containers and, as of the writing of this Plan, no accepted industry standard for inspection or integrity testing of this tank design exists. Based on discussions with STI representatives, integrity testing recommendations published by Convault, and review of the Convault manufacturer’s Inspection Checklist, the goal of integrity testing of concrete-encased tanks can best be met through routine periodic inspections.

In accordance with guidance contained in United States Environmental Protection Agency (EPA) Office of Emergency Management Bulk Storage Container Fact Sheet dated July 2012, a hybrid inspection program has been developed for the concrete-encased double-walled tanks at SUBASENLON which accomplishes the intent of the Steel Tank Institute's (STI) SP001 Standard for Inspection of ASTs (5th Edition) periodic inspection and integrity testing requirements. The amended process performs all the STI inspection items with the exception of STI Annual Inspection Checklist Numbers 4.1 and 4.2. The hybrid inspection plan is also consistent with the Convault manufacturer’s Inspection Checklist and recommendations contained in the Convault Manufacturer Integrity Testing open letter dated August 19, 2002. It is noted that the EPA Fact Sheet states that an environmental equivalence determination is not required for a hybrid inspection program.

3.2.2. Preventing Physical Damage to Aboveground Piping

After considering facility layout and EPA guidance, the PE certifying this Plan is deviating from the requirement in §112.8(d)(5) to warn all vehicles entering the facility to be sure that no vehicle will endanger aboveground piping or other oil transfer operations.

Per the 2013 GRI (p. 3-1) “environmental equivalence need not be a mathematical equivalence, but it must achieve the same desired outcome, though not necessarily through the same mode of operation (see 67 Federal Register (FR) 47095, July 17, 2002).” Physical damage to aboveground piping and other equipment may be protected from the possibility of a collision by installing fencing, barriers, curbing, or other physical obstacles.

The primary protection for above ground piping connected to bulk storage containers included in this Plan against the possibility of vehicular collision is by routing away from traffic. In those cases where tank and/or pipe systems are located in areas susceptible to damage from vehicles, protective measures are in place such as fencing, barriers, or curbing. This approach provides superior environmental protection as compared to verbal or written warnings to drivers by physically preventing vehicular damage to piping systems. Any sites with inadequate protection are included in the deficiency list in Appendix B.

3.3. Spill Reporting [40 CFR 112.7(a)]

3.3.1. Contact List [40 CFR 112.7(a)(3)(vi)]

§112.7(a)(3)(vi) You must also address in your Plan: Contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with whom you have an agreement for response, and all appropriate Federal, State, and local agencies who must be contacted in case of a discharge as described in §112.1(b).

The procedures, contact list, and phone numbers for the Facility Response Coordinator, National Response Center, cleanup contractors with whom the Facility has an agreement for response, and all appropriate federal, state, and local agencies who must be contacted in case of a discharge as described in §112.1(b) are provided in Section 6.

3.3.2. Discharge Notification and Response Procedures [40 CFR 112.7(a)(4) & 112.7(a)(5)]

§112.7(a)(4) Unless you have submitted a response plan under §112.20, provide information and procedures in your Plan to enable a person reporting a discharge as described in §112.1(b) to relate information on the exact address or location and phone number of the facility; the date and time of the discharge, the type of material discharged;

estimates of the total quantity discharged; estimates of the quantity discharged as described in §112.1(b); the source of the discharge; a description of all affected media; the cause of the discharge; any damages or injuries caused by the discharge; actions being used to stop, remove, and mitigate the effects of the discharge; whether an evacuation may be needed; and, the names of individuals and/or organizations who have also been contacted.

§112.7(a)(5) Unless you have submitted a response plan under §112.20, organize portions of the Plan describing procedures you will use when a discharge occurs in a way that will make them readily usable in an emergency, and include appropriate supporting material as appendices.

SUBASENLON has prepared an Integrated Contingency Plan under §112.20 which contains discharge notification and response procedures.

3.4. Predicted Direction, Rate of Flow, and Total Quantity of Oil Discharged as a Result of Equipment Failure [40 CFR 112.7(b)]

§112.7(b) Where experience indicates a reasonable potential for equipment failure (such as loading or unloading equipment, tank overflow, rupture, or leakage, or any other equipment known to be a source of a discharge), include in your Plan a prediction of the direction, rate of flow, and total quantity of oil which could be discharged from the facility as a result of each type of major equipment failure.

Experience indicates a reasonable potential for equipment failure (such as loading or unloading equipment, tank overflow, rupture, or leakage, or any other equipment known to be a source of a discharge) for all bulk storage containers included in this Plan. Therefore, for each container site included in this Plan, a prediction of the direction, rate of flow, and total quantity of oil which could be discharged as a result of each type of major equipment failure is included as Table 5.2.1A. Due to the large number of individual containers, a separate Table 5.2.1A has been prepared for each site. Appendix C is a list of general assumptions and calculations used to develop the numerical data presented in Table 5.2.1A.

In addition, site-specific compliance summary sheets and site maps for individual oil container sites in Section 5 depict flow direction and likely fate in the event of a release. Due to the large number of individual containers, separate site maps and information sheets have been prepared for each tank installation site.

3.5. Secondary Containment to Address Typical Failure Modes [40 CFR 112.7(c)]

§112.7(c) Provide appropriate containment and/or diversionary structures or equipment to prevent a discharge as described in §112.1(b), except as provided in paragraph (k) of this section for qualified oil-filled operational equipment, and except as provided in §112.9(d)(3) for flowlines and intra-facility gathering lines at an oil production facility. The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system, such as a tank, will not escape the containment system before cleanup occurs. In determining the method, design, and capacity for secondary containment, you need only to address the typical failure mode, and the most likely quantity of oil that would be discharged. Secondary containment may be either active or passive in design. At a minimum, you must use one of the following prevention systems or its equivalent:

(1) For onshore facilities:

(i) Dikes, berms, or retaining walls sufficiently impervious to contain oil;

(ii) Curbing or drip pans;

(iii) Sumps and collection systems;

(iv) Culverting, gutters, or other drainage systems;

(v) Weirs, booms, or other barriers;

(vi) Spill diversion ponds;

(vii) Retention ponds; or

(viii) Sorbent materials.

3.5.1. Bulk Storage Containers

Methods of secondary containment intended to comply with the provisions of §112.7(c) for containers included in this Plan include a combination of structures (e.g., dike, spill pallet, or built-in secondary containment) and land-based spill response (e.g., drain cover, sorbent) to prevent the most likely quantity of oil discharged during a typical failure mode from reaching navigable waters and adjoining shorelines. Typical failure modes, the most likely quantities of oil that would be discharged during typical failure modes, and any active or passive methods of secondary containment are presented on individual data sheets for each tank site in Section 5.2.1, Table 5.2.1A. Passive secondary containment methods have been designed to contain oil to prevent the escape of oil from the containment system before cleanup occurs.

3.5.2. Drum Storage Areas

Methods of secondary containment intended to comply with the provisions of §112.7(c) for drum storage areas are presented in Section 5.2.2. The active or passive methods of secondary containment, typical failure modes, and most likely quantities of oil that would be discharged during typical failure modes are presented on individual data sheets for each drum storage area in Section 5.2.2, Table 5.2.2A.

3.5.3. Mobile Equipment

Methods of secondary containment intended to comply with the provisions of §112.7(c) for mobile equipment with an internal storage capacity of non-motive power oil greater than 55 gallons are presented in Section 5.2.3. SUBASENLON has three pieces of mobile equipment which meet these criteria. The containment requirements for the equipment during both storage and operational mode are addressed separately on individual datasheets presented for each item in Section 5.2.3, Table 5.2.3A.

3.5.4. Mobile Refuelers and Other Non-Transportation-Related Tankers

SUBASENLON operates non-transportation-related fuel delivery trucks which meet the definition of mobile refuelers in §112.8(c)(2). In addition, SUBASENLON operates a 14 unit fleet of oily water trucks which transport bilge water from operational vessels to the oily waste treatment facility (OWTF) located on the installation. According to the 2013 GRI, these oily water tankers also qualify for the mobile refueler exemption from sized secondary containment under §112.8(c)(2). The 2013 GRI, Chapter 4.7.6, states, “The exemption from sized secondary containment for mobile refuelers also applies to other non-transportation-related tank trucks.

Other non-transportation-related tank trucks may operate similarly to mobile refuelers, though not specifically transferring fuel. Instead, these tank trucks may carry other oils such as transformer oils, lubrication oils, crude oil, condensate, or non-petroleum oils such as AFVOs

(animal fats and vegetable oils). Examples include a truck used to refill oil-filled equipment at an electrical substation and a pump truck at an oil production facility. These tank trucks may have the same difficulty in complying with the sized secondary containment requirements as mobile refuelers. Therefore, all non-transportation-related tank trucks are excluded from the sized secondary containment requirements for bulk storage containers, however the general secondary containment requirements at §112.7(c) apply (see 73 FR 74236, December 5, 2008).”

The non-transportation-related tanker trucks operated at SUBASENLON consists of the aforementioned fuel delivery trucks and oily waste tanker trailers with capacities ranging from 1,000 to 5,000 gallons. Active measures are used to contain minor releases which may occur during operation of these vehicles. Absorbent materials are carried in the trucks to address minor spills and releases which occur while connecting and disconnecting hoses or minor valve drips. A maximum of five gallons of released liquid is anticipated during any operation release event. The tankers may be staged on the piers adjacent to vessels during operation.

When parked with liquid onboard, these vehicles are positioned in one of the following areas— all of which are equipped with secondary containment. It should be noted that parking mobile refuelers and other non-transportation-related tanker trucks in containment areas is not required under §112.8(c)(2), but instead is done as a best management practice at SUBASENLON.

• Loading/unloading rack adjacent to Building 527, where the lube oil supply truck is normally parked

• OWTF, Building 553, and the Queuing facility, Building 554, where the tanker trucks carrying bilge water are parked

• Building 549 loading/unloading rack, where the DFM tanker trucks are parked

• Building 549 tanker truck parking area.

The methods of secondary containment intended to comply with the provisions of §112.7(c) for non-transportation-related tanker parking areas are presented in Section 5.2.4. Each parking area has an individual data sheet in Section 5.2.4, Table 5.2.4A which presents the active or passive methods of secondary containment, typical failure modes, and most likely quantities of oil that would be discharged during typical failures. Containment requirements for fuel transfers into and out of the mobile refuelers are addressed in Sections 5.2.1 and 5.2.2.

Standard operating procedures (SOPs) for tanker loading and unloading are included as Appendix D.

3.5.5. Loading Racks

Methods of secondary containment intended to comply with the provisions of §112.7(h) for fuel loading racks are presented in Section 5.2.5. The containment requirements for the loading racks as well as the interlock/warning requirements addressed separately on individual datasheets presented for each loading rack are in Table 5.2.5A.

3.5.6. Oil Filled Operational Equipment

Oil-filled operational equipment (OFOE) is equipment that includes an oil storage container in which the oil is present solely to support the function of the apparatus or device. OFOE at SUBASENLON includes electrical equipment such as transformers and switches, military component test fixtures, and elevator hydraulic reservoirs.

OFOE is discussed in Section 5.2.6 which contains an inventory of OFOE and the strategy for secondary containment for these devices at SUBASENLON.

3.6. Practicability of Secondary Containment [40 CFR 112.7(d)]

§112.7(d) Provided your Plan is certified by a licensed Professional Engineer under §112.3(d), or, in the case of a qualified facility that meets the criteria in §112.3(g), the relevant sections of your Plan are certified by a licensed Professional Engineer under §112.6(d), if you determine that the installation of any of the structures or pieces of equipment listed in paragraphs (c) and (h)(1) of this section, and §§112.8(c)(2), 112.8(c)(11), 112.9(c)(2), 112.10(c), 112.12(c)(2), and 112.12(c)(11) to prevent a discharge as described in §112.1(b) from any onshore or offshore facility is not practicable, you must clearly explain in your Plan why such measures are not practicable; for bulk storage containers, conduct both periodic integrity testing of the containers and periodic integrity and leak testing of the valves and piping; and, unless you have submitted a response plan under §112.20, provide in your Plan the following:

(1) An oil spill contingency plan following the provisions of part 109 of this chapter.

(2) A written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful.

Secondary containment has been deemed practical at all locations at SUBASENLON.

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

§112.7(e) Inspections, tests, and records. Conduct inspections and tests required by this part in accordance with written procedures that you or the certifying engineer develop for the facility. You must keep these written procedures and a record of the inspections and tests, signed by the appropriate supervisor or inspector, with the SPCC Plan for a period of three years. Records of inspections and tests kept under usual and customary business practices will suffice for purposes of this paragraph.

Inspections and tests of each bulk storage container are mandated in §112.8(c)(6) and described in Section 4.8 of this Plan. The recordkeeping associated with the container inspection/testing program and inspector training is as follows:

Each container 55 gallons and greater has routine monthly and annual inspections in accordance with the inspection program provided in STI SP001. Inspections are documented on the inspection forms contained in Appendix E of this Plan. These routine inspection records are maintained by the Tank Program Manager at the PWD New London Environmental Division for three years and will be kept under usual and customary business practices.

All other tank testing records will also be maintained by the Tank Program Manager at the PWD New London Environmental Division. All shell thickness testing and certified inspection reports, including formal external inspection reports, will be retained for the life of the container.

3.8. Oil-Handling Personnel Training [40 CFR 112.7(f)]

In accordance with §112.7(f), all oil-handling personnel receive initial SPCC training and annual oil handler discharge prevention briefings. The Annual SPCC Training and Oil Handler Discharge Prevention Briefing Logs are archived in Appendix K of this Plan and record information such as meeting dates and attendees. The Annual SPCC Training and Annual Discharge Prevention Briefings may take place concurrently.

The SPCC program manager (PM) is responsible for ensuring that oil/petroleum handling personnel are provided the following training:

• Initial and annual familiarization training on the contents of the SPCC Plan

• Annual spill/discharge prevention briefings and lessons learned.

Oil-handling personnel include personnel that conduct AST inspection and/or are engaged in the operation and maintenance of oil storage containers or the operation of equipment related to storage containers and emergency response personnel. The term does not include administrative assistants, clerks, and other personnel who are never involved in operation or maintenance activities related to oil storage or equipment, oil transfer operations, emergency response, countermeasure functions, or similar activities. Oil/petroleum handling personnel who require this training include SUBASENLON personnel, tenants, and contractors who are employed or are contracted to perform work in the following areas:

• Public Works Department

• FISC Fuel Farm

• Heating/diesel fuel vendors (delivery)

• Naval Submarine Support Facility

• Navy Exchange Gas Station

• Morale, welfare, and recreation areas

• Oily Waste Treatment Facility

• TSDF and CHRIMP Center.

3.8.1. Annual SPCC Training [40 CFR 112.7(f)(1)]

§112.7(f)(1) Personnel, training, and discharge prevention procedures. (1) At a minimum, train your oil-handling personnel in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols;

applicable pollution control laws, rules, and regulations; general facility operations; and, the contents of the facility SPCC Plan.

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