J9 PTO 001 Combined Enclosures.pdf

Enclosure A: ASTs and Portable Container/Drum Storage Area Inventories

Tank ID # Contents Capacity (Gallons)

Usage STI Category Map Grid

(SPCC Plan) Operator/Tenant

Owner/ Funding Responsibility

Inspector

G55-01AG Diesel 113 Emergency Generator 1 E5 Security CNIC-ST Contractor

1H-01AG Diesel 184 Emergency Generator 1 D7 NAVFAC CNIC-ST Contractor

11-01AG Diesel 4,000 Emergency Generator 1 C8 UEM CNIC-ST Contractor

11-02AG Diesel 4,000 Emergency Generator 1 C8 UEM CNIC-ST Contractor

13-01A Gasoline 1,000 Marine Fueling 1 D8 MWR CNIC-ST Contractor

31-01A Diesel 104 Emergency Generator 1 B7/C7 NSGL BOQ CNIC-ST Contractor

106-01AG Diesel 240 Emergency Generator 1 C7 Fire Station CNIC-ST Contractor

125-01A Diesel 200 Fire Pump Supply 1 C7 Fire Pump Bldg CNIC-ST Contractor

179-01AG Diesel 1,400 Emergency Generator 1 C7 Police Station CNIC-ST Contractor

179-02AG Diesel 114 Emergency Generator 1 C8 Police Station CNIC-ST Contractor

236-01O Used Oil 220 Process Vessel N/A B6 TSC TSC Tenant

236-02O Used Oil 220 Process Vessel N/A B6 TSC TSC Tenant

236-03O Used Oil 220 Process Vessel N/A B6 TSC TSC Tenant

236-04O Used Oil 220 Process Vessel N/A B6 TSC TSC Tenant

236-05O Used Oil 220 Process Vessel N/A B6 TSC TSC Tenant

236-06O Used Oil 220 Process Vessel N/A B6 TSC TSC Tenant

238-01A Diesel 564 Bulk Storage 1 B7 TSC TSC Tenant

238-02A Diesel 318 Bulk Storage 1 B7 TSC TSC Tenant

325-02A Used Fuel 500 Bulk Storage N/A A2 TSC TSC Tenant

325-03A Used Oil 500 Bulk Storage N/A A2 TSC TSC Tenant

520-01A Diesel 250 Fire Pump Supply 3 A7 SWOSU CNIC-ST Contractor

1405-01A Diesel 100 Fire Pump Supply 3 C6 RTC CNIC-ST Contractor

1506-01A Lube Oil 275 Lube Oil Storage 1 B5 BSV&E CNIC-TR Contractor

1506-02A Lube Oil 275 Lube Oil Storage 1 B5 BSV&E CNIC-TR Contractor

1506-03A Lube Oil 275 Lube Oil Storage 1 B5 BSV&E CNIC-TR Contractor

1506-05A Diesel 150 Fire Pump Supply 1 B5 BSV&E CNIC-ST Contractor

1506-06A Used Oil 500 Used Oil Storage 1 B5 BSV&E CNIC-TR Contractor

1507-01A Gasoline 10,000 Vehicle Fueling 1 B5 BSV&E CNIC-ST Contractor

1507-02A E-85 10,000 Vehicle Fueling 1 B5 BSV&E CNIC-ST Contractor

1507-04A Biodiesel 10,000 Vehicle Fueling 1 B5 BSV&E CNIC-ST Contractor

2019-01AG Diesel 472 Emergency Generator 1 G2 UEM CNIC-ST Contractor

2801-01AG Diesel 150 Emergency Generator 1 D5 Fire Station CNIC-ST Contractor

3215-01AG Diesel 241 Emergency Generator 1 D1 Army Reserve CNIC-ST Contractor

3216-01A Used Oil 500 Used Oil Storage 1 E1 Goodwill Goodwill Tenant

3311-01A Gasoline 250 Vehicle Fueling 1 C1 MWR MWR Tenant

3311-02A Diesel 250 Vehicle Fueling 1 C1 MWR MWR Tenant

3311-03A Used Oil 500 Used Oil Storage 1 C1 MWR MWR Tenant

3400-01AG Diesel 1,000 Emergency Generator 1 D2 MEPCOM CNIC-ST Contractor

3402-01A Diesel 350 Emergency Generator 1 C2 MEPCOM CNIC-ST Contractor

NSGL Above-ground Storage Tank (AST) Inventory

3402-02A Diesel 500 Emergency Generator 1 C2 MEPCOM CNIC-ST Contractor

3451-01AG Diesel 165 Emergency Generator 1 C2 NEX CNIC-ST Contractor

3502-01A Diesel 280 Fire Pump Supply 3 F1 Storage Facility CNIC-ST Contractor

3511A-01A Gasoline 500 Vehicle Fueling 3 E1 Challenge Unlimited Challenge Unlimited Tenant

3511A-02A Diesel 500 Vehicle Fueling 1 E1 Challenge Unlimited Challenge Unlimited Tenant

6224-02A Diesel 538 Bulk Storage 1 B6 TSC TSC Tenant

6224-05A Diesel 3,000 Bulk Storage 1 B6 TSC TSC Tenant

7101-01AG Diesel 241 Emergency Generator 1 F5 RTC CNIC-ST Contractor

7104-01AG Diesel 425 Emergency Generator 1 F5 RTC CNIC-ST Contractor

7111-01AG Diesel 411 Emergency Generator 1 E5 RTC CNIC-ST Contractor

7113-01AG Diesel 411 Emergency Generator 1 F4 RTC CNIC-ST Contractor

7116-01AG Diesel 406 Emergency Generator 1 E4 RTC CNIC-ST Contractor

7122-01AG Diesel 600 Emergency Generator 1 C5 RTC CNIC-ST Contractor

7260-01AG Diesel 194 Emergency Generator 1 E5 RTC CNIC-ST Contractor

7330-01AG Diesel 138 Emergency Generator 1 E5 RTC CNIC-ST Contractor

7811-01AG Diesel 370 Emergency Generator 1 D5 RTC CNIC-ST Contractor

8200-01A Used Oil 120 Used Oil Storage 1 D1 MACG-48 MARFORRES Tenant y

ID Number Contents Number of Containers

Capacity (Gallons)

Map Grid (SPCC Plan)

Operator/Tenant Owner/ Funding

Responsibility Inspector

140-01UCO Used Cooking Oil 1 220 C8 Port O'Call - MWR MWR Tenant

400-01UCO Used Cooking Oil 1 220 A7 Panda Express NEX Tenant

400-02UCO Used Cooking Oil 1 220 A7 Taco Bell NEX Tenant

523-02E Lube Oil 1 62 B7 SWOSU SWOSU Tenant

523-01E Lube Oil 1 62 B7 SWOSU SWOSU Tenant

525-01UCO Used Cooking Oil 1 220 B7 MWR Epicenter MWR Tenant

590-01UCO Used Cooking Oil 1 220 B7 McDonalds McDonalds Tenant

590-02UCO Cooking Oil (New) 1 220 B7 McDonalds McDonalds Tenant

3216-01T Lube Oil 1 60 E1 Goodwill Goodwill Tenant

3216-02T Lube Oil 1 60 E1 Goodwill Goodwill Tenant

3216-03T Lube Oil 1 60 E1 Goodwill Goodwill Tenant

3216-04T Lube Oil 1 60 E1 Goodwill Goodwill Tenant

3216-05T Lube Oil 1 60 E1 Goodwill Goodwill Tenant

3216-06T Lube Oil 1 60 E1 Goodwill Goodwill Tenant

3216-07T Lube Oil 1 60 E1 Goodwill Goodwill Tenant

3216-08T Lube Oil 1 60 E1 Goodwill Goodwill Tenant

3216-09T Lube Oil 1 60 E1 Goodwill Goodwill Tenant

3451-01UCO Used Cooking Oil 1 220 C2 NEX NEX Tenant

8400-01UCO Used Cooking Oil 1 220 C2 MWR Golf Course MWR Tenant

11-01D Mineral Oil, Used Oil 8 440 C8 UEM CNIC-UT Tenant

11-02D Used Oil 4 220 C8 UEM CNIC-UT Tenant

52-01D Used Oil 4 220 D8 Navy Reserve Navy Reserve Tenant

52-02D Lube Oil 3 165 D8 Navy Reserve Navy Reserve Tenant

221-01D Diesel, Used Oil 6 330 B6 HW CAA N/A Tenant

221-02D Used Oil 1 55 B6 HW CAA N/A Tenant

236-01D Lube Oil, Used Oil 3 165 B6 TSC TSC Tenant

238-01D Lube Oil 1 55 B7 TSC TSC Tenant

238-02D Used Oil 1 55 B7 TSC TSC Tenant

523-01D Cutting Oil, Lube Oil, Hydraulic Oil 5 275 B7 SWOSU SWOSU Tenant

1506-01D Parts Cleaner, Motor Oil, Gear Oil 5 275 B5 BSV&E CNIC-TR Tenant

1506-02D Used Oil 2 110 B5 BSV&E CNIC-TR Tenant

3216-01D Motor Oil 1 55 E1 Goodwill Goodwill Tenant

3503-01D Dry-Cleaning Solvent 3 165 F1 NEX Laundry/Dry Cleaners NEX Tenant

3503-02D Dry-Cleaning Solvent 10 550 F1 NEX Laundry/Dry Cleaners NEX Tenant

3503-03D Dry-Cleaning Solvent 4 220 F1 NEX Laundry/Dry Cleaners NEX Tenant

NSGL Portable Container and Drum Storage Area Inventory

2110-01D Hydraulic Oil, Motor Oil, Used Oil 5 275 E1 Challenge Unlimited Challenge Unlimited Tenant

8200-01D Waste Diesel 1 55 D1 MACG-48 Vehicle Storage MARFORRES Tenant

8200-02D Lube Oil, Gear Oil 3 165 D1 MACG-48 Vehicle Storage MARFORRES Tenant

8200-03D Used Oil 6 330 D1 MACG-48 Vehicle Storage MARFORRES Tenant

Enclosure B: List of USTs

NSGL

Tank ID #

OSFM Tank

ID #

Former SPCC Tank

ID #

Building # Contents

Capacity (Gallons)

Usage Date

Installed

Tank & Containment

Material

Map Grid (SPCC Plan)

Operator/ Tenant

Owner/ Funding

Responsibility Inspector

1-01U 41 U1 1 Diesel 600 Emergency Generator 3/15/1994

Fiberglass Reinforced Plastic C8 CNIC/NAVFAC CNIC-ST Contractor

400-01U 3228 U46 400 Unleaded Gasoline 10,000 Vehicle Fueling 10/31/2000

Fiberglass Reinforced Plastic A7 NEX/NAVFAC CNIC-ST Contractor

400-02U 3229 U47 400 Unleaded Gasoline 12,000 Vehicle Fueling 10/31/2000

Fiberglass Reinforced Plastic A7 NEX/NAVFAC CNIC-ST Contractor

3402-01U 46 U104 3402 Diesel 2,500 Emergency Generator 3/15/1994

Fiberglass Reinforced Plastic C2 MEPCOM/NAVFAC CNIC-ST Contractor

8150-01U 3 U146 8150 Unleaded Gasoline 12,000 Vehicle Fueling 5/31/1995

Fiberglass Reinforced Plastic E3 NEX/NAVFAC CNIC-ST Contractor

8150-02U 2 U147 8150 Unleaded Gasoline 12,000 Vehicle Fueling 5/31/1995

Fiberglass Reinforced Plastic E3 NEX/NAVFAC CNIC-ST Contractor

8150-03U 1 U148 8150 Unleaded Gasoline 15,000 Vehicle Fueling 5/31/1995

Fiberglass Reinforced Plastic E3 NEX/NAVFAC CNIC-ST Contractor

NSGL Undergroundground Storage Tank (UST) Inventory

Enclosure C: AST Monthly Inspection Form

Monthly Checklist Page 1 of 3

STI SP001 Monthly Inspection Checklist

General Inspection Information:

Inspection Date: __________________ Prior Inspection Date: _________________ Retain until date: __________________

Inspector Name (print): _______________________________________________________________ Title: _____________________________

Signature ___________________________________________________________________________

Tank(s) inspected ID ___________________________________________________________________

Regulatory facility name and ID number (if applicable) ____________________________________________________________________

Inspection Guidance:

This checklist is intended as a model. Locally developed checklists are acceptable as long as they are substantially equivalent (as applicable). Inspections of multiple tanks may be captured on one form as long as the tanks are substantially the same.

For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures.

The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified per paragraph 4.1.2 of the standard.

Upon discovery of water in the primary tank, secondary containment area, interstice, or spill container, remove promptly or take other corrective action. Inspect the liquid for regulated products or other contaminants and dispose of properly.

Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section.

Retain the completed checklists for at least 36 months.

After severe weather (snow, ice, wind storms) or maintenance (such as coating) that could affect the operation of critical components (normal and emergency vents, valves), an inspection of these components is required as soon as the equipment is safely accessible after the event.

ITEM STATUS

Tank and Piping

Monthly Checklist Page 2 of 3

Is the primary tank free of water or has another preventative measure been taken?

NOTE: Refer to paragraphs 6.10 and 6.11 of the standard for alternatives for Category 1 tanks. N/A is only appropriate for these alternatives.

Equipment on tank

Containment (Diking/Impounding) excess liquid, debris, cracks, corrosion, erosion, fire hazards and other integrity issues?

Concrete Exterior AST (CE-AST)

Other Conditions

Monthly Checklist Page 3 of 3

Additional Comments:

Enclosure D: 30-Day UST Walkthrough Inspection Form

Facility #: __________________

Facility Address: ____________________________________________________________

30 Day Walkthrough Inspection Report: 20___ (year) (Inspections must be conducted by the designated Class A/B Operator)

Signature of A/B Operator:

Print Name of A/B Operator: ______________________________________________

A/B Operator must initial and enter the date each month for each inspection, or enter N/A if applicable.

JAN FEB MARCH APRIL MAY JUNE

Lift spill bucket lids & visually check for damage, including inspecting for cracks, holes or bulges.

Remove any liquid or debris found.

Check for any potential sources of water entry, including surface water.

Check spill buckets for release of regulated substances, including in the interstices of double wall spill buckets.

Check for any obstructions lodged in fill pipe. Remove if found. Check that fill cap fits securely on the fill pipe.

Check release detection equipment for operability. Check for any alarms or unusual operating conditions.

Print 30 day ATG report from ATG or complete log of inspection for 2-wall spill buckets. Keep for inspector.

Print & save 30 Day ATG PASS reports for leak detection & NORMAL reports for sensors. Keep for inspector.

Check dispensers, hoses, nozzles & breakaways.

Check impressed current rectifier for power & operation. Enter hour, volt & amp readings on written Log.

COMMENTS on first 6 months:

30 Day Walkthrough Inspection Report: 20___ (year) (Inspections must be conducted by the designated Class A/B Operator)

Signature of A/B Operator:

Print Name of A/B Operator: ______________________________________________

A/B Operator must initial and enter the date each month for each inspection, or enter N/A if applicable.

JULY AUGUST SEPT OCTOBER NOV DEC

Lift spill bucket lids & visually check for damage, including inspecting for cracks, holes or bulges.

Remove any liquid or debris found.

Check for any potential sources of water entry, including surface water.

Check spill buckets for release of regulated substances, including in the interstices of double wall spill buckets.

Check for any obstructions lodged in fill pipe. Remove if found. Check that fill cap fits securely on the fill pipe.

Check release detection equipment for operability. Check for any alarms or unusual operating conditions.

Print 30 day ATG report from ATG or complete log of inspection for 2-wall spill buckets. Keep for inspector.

Print & save 30 Day ATG PASS reports for leak detection & NORMAL reports for sensors. Keep for inspector.

Check dispensers, hoses, nozzles & breakaways.

Check impressed current rectifier for power & operation. Enter hour, volt & amp readings on written Log.

COMMENTS on last 6 months:

Enclosure E: Monthly Portable Container and Drum Storage Area Inspection Form

FORM 6: DRUM SITE INSPECTION CHECKLIST

Instructions: One inspection checklist per drum site. (*) designates an item in non-conformance/unsatisfactory status; provide action in comment section to resolve problem and notify Environmental Protection Specialist if any significant deficiencies are identified.

Regulatory Driver: 40 CFR 112 Frequency: Monthly

AST INSPECTION STANDARD

COPYRIGHT© 2011 Steel Tank Institute

Drum Site Name:____________________________________________ Date: ____________________

Location:__________________ Quantity of Drums: _________ Volume of Drums: ________ Content: _______________

STI SP001 Portable Container Monthly Inspection Checklist Inspection Guidance:

For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures.

The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be perfo and can identify changes and developing problems.

(*) designates an item in a non-conformance status. This indicates that action is required to address a problem.

Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a

Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section.

Retain the completed checklists for 36 months.

Item Area: Area: Area: Area:

1.0 AST Containment/Storage Area

1.1 ASTs within designated

storage area?

1.2 Debris, spills, or other fire

hazards in containment or storage area?

1.3 Water in outdoor

secondary containment?

1.4 Drain valves operable

and in a closed position?

1.5 Egress pathways clear

and gates/doors operable?

2.0 Leak Detection

2.1 Visible signs of

leakage around the container or storage area?

3.0 Container

3.0 Noticeable container

distortions, buckling, denting or bulging?

(*) designates an item in non conformance status. This indicates that action is required to address a problem.

Comments:

Inspector: ___________________________________ Signature: ____________________________________ Date: _________________

Enclosure F: AST Annual Inspection Form

Annual Checklist Page 1 of 4

STI SP001 Annual Inspection Checklist

General Inspection Information:

Inspection Date: __________________ Prior Inspection Date: _________________ Retain until date: __________________

Inspector Name (print):________________________________________________________________ Title: _____________________________

Signature: ___________________________________________________________________________

Tank(s) inspected ID ___________________________________________________________________

Regulatory facility name and ID number (if applicable) ____________________________________________________________________

Inspection Guidance:

This checklist is intended as a model. Locally developed checklists are acceptable as long as they are substantially equivalent (as applicable).

For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures.

The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified per paragraph 4.1.2 of the standard.

Remove promptly standing water or liquid discovered in the primary tank, secondary containment area, interstice, or spill container. Before discharge to the environment, inspect the liquid for regulated products or other contaminants and disposed of it properly.

In order to comply with EPA SPCC (Spill Prevention, Control and Countermeasure) rules, a facility should regularly test liquid level sensing devices to ensure proper operation (40 CFR 112.8(c)(8)(v)).

Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section.

Retain the completed checklists for at least 36 months.

Complete this checklist on an annual basis, supplemental to the owner monthly-performed inspection checklists.

Note: If a change has occurred to the tank system or containment that may affect the SPCC plan, the condition should be evaluated against the current plan requirement by a Professional Engineer knowledgeable in SPCC development and implementation.

ITEM STATUS

Tank Foundation/Supports

Annual Checklist Page 2 of 4

Tank Equipment

Annual Checklist Page 3 of 4

Annual Checklist Page 4 of 4

Additional Comments:

Enclosure G: UST Annual Walkthrough Inspection Report

Annual Walkthrough Inspection Report: 20___ (year)

A/B Operator Signature (if applicable): _______________________________________________

Print Name of A/B Operator (if applicable): ____________________________________________

Inspections Required Annually (Inspections of piping sump areas must be performed by a certified employee of a contractor licensed in either the Install/Retrofit or Tank Tightness Testing modules.) All piping sumps areas shall be checked annually. Sump lids must be lifted and dispenser cabinets opened to inspect piping containment sump areas.

Contractor must initial and enter date of Annual Walkthrough Inspection.

Day/Month/Year of Inspection

Contractor Initials

Enter comments below corresponding to inspections listed at left.

Visual check for damage to piping containment sump areas: Check lids, covers & containment for damage & leaks.

COMMENTS & ACTIONS TAKEN:

Check sumps for the presence of regulated substances or any indication that a release may have occurred. Remove any liquid or debris if present.

COMMENTS & ACTIONS TAKEN:

Check that interstices of double wall containment sumps are free of water or product.

COMMENTS & ACTIONS TAKEN:

If applicable: Check gauge stick (manual tank gauging) or bailer (GW monitoring).

COMMENTS & ACTIONS TAKEN:

Contractor Employee Conducting Annual Inspection of Piping Containment Sump Areas:

1) Signature: _____________________________________

2) Print Name & Title: _____________________________________

Annual Test & Inspection: May be Performed by Contractor or A/B Operator Contractor or A/B Operator must initial and enter date of Annual Emergency Stops Test.

Day/Month/Year of Emergency Stop Test

Contractor or A/B Operator Initials

Enter comments below regarding Annual Emergency Stops Test. Attach OSFM Operational Testing of Emergency Stops Report to Walkthrough Inspection Report & keep at facility.

Test Emergency Stops for interconnection and STP shutdown.

Attach OSFM report form.

COMMENTS:

Contractor or A/B Operator must initial and enter date of Annual Shear Valve Inspection.

Day/Month/Year of Shear Valve Inspection

Contractor or A/B Operator Initials

Enter comments below regarding Annual Shear Valve Inspection. Attach OSFM Annual Inspection of Shear Valves Report to Walkthrough Inspection Report & keep at facility.

Check shear valves for proper height, secure mounting & free operation of trip arm & poppet.

COMMENTS:

Annual Walkthrough Inspection Report: 20___ (year)

A/B Operator Signature (if applicable): _______________________________________________

Print Name of A/B Operator (if applicable): ____________________________________________

Inspections Required Annually (Inspections of piping sump areas must be performed by a certified employee of a contractor licensed in either the Install/Retrofit or Tank Tightness Testing modules.) All piping sumps areas shall be checked annually. Sump lids must be lifted and dispenser cabinets opened to inspect piping containment sump areas.

Contractor must initial and enter date of Annual Walkthrough Inspection.

Day/Month/Year of Inspection

Contractor Initials

Enter comments below corresponding to inspections listed at left.

Visual check for damage to piping containment sump areas: Check lids, covers & containment for damage & leaks.

COMMENTS & ACTIONS TAKEN:

Check sumps for the presence of regulated substances or any indication that a release may have occurred. Remove any liquid or debris if present.

COMMENTS & ACTIONS TAKEN:

Check that interstices of double wall containment sumps are free of water or product.

COMMENTS & ACTIONS TAKEN:

If applicable: Check gauge stick (manual tank gauging) or bailer (GW monitoring).

COMMENTS & ACTIONS TAKEN:

Contractor Employee Conducting Annual Inspection of Piping Containment Sump Areas:

1) Signature: _____________________________________

2) Print Name & Title: _____________________________________

Annual Test & Inspection: May be Performed by Contractor or A/B Operator Contractor or A/B Operator must initial and enter date of Annual Emergency Stops Test.

Day/Month/Year of Emergency Stop Test

Contractor or A/B Operator Initials

Enter comments below regarding Annual Emergency Stops Test. Attach OSFM Operational Testing of Emergency Stops Report to Walkthrough Inspection Report & keep at facility.

Test Emergency Stops for interconnection and STP shutdown.

Attach OSFM report form.

COMMENTS:

Contractor or A/B Operator must initial and enter date of Annual Shear Valve Inspection.

Day/Month/Year of Shear Valve Inspection

Contractor or A/B Operator Initials

Enter comments below regarding Annual Shear Valve Inspection. Attach OSFM Annual Inspection of Shear Valves Report to Walkthrough Inspection Report & keep at facility.

Check shear valves for proper height, secure mounting & free operation of trip arm & poppet.

COMMENTS:

Enclosure H: ILR00 Permit

Enclosure I: Marina Fueling and Private Boat Storage Area Map

Industrial SWPPP Naval Station Great Lakes

FIGURE 2:

MARINA FUELING SITE/PRIVATE BOAT STORAGE AND MAINTENANCE AREA

January 2020 23

Enclosure J: Hunt Military Communities Storage Yard

Industrial SWPPP Quarterly Outfall Monitoring Plan Naval Station Great Lakes

Figure 3:

HUNT MILITARY COMMUNITIES STORAGE YARD

January 2020 32

Enclosure K: Monthly Industrial Facility Storm Water Inspection Form

January 2020

NSGL - Monthly Industrial Facility Storm Water Inspection Report Marina & Private Boat Storage Area

General Information

Inspected by:

Inspection Date:

Signature:

Potential Storm Water Pollution Sources

• Boat Engine / Part Leak

• Routine Boat Washing

• Paint Spills / Particulates

• Equipment Maintenance

• Gas Pump / Fuel Storage Tank

• Marine Vehicle Sanitary Waste Pump-Out Station

• Recreational Vehicle Sanitary Waste Pump-Out Station

Best Management Practices (BMPs)

1. Good Housekeeping: Is facility maintained in a clean and orderly way? Are materials stored outside that have the potential to pollute storm water appropriately protected?

Yes No Notes / Deficiencies:

2. Preventative Maintenance (PM): Is there evidence that PM is being performed on equipment whose failure could result in release of chemicals to the storm sewer or surface water?

Yes No Notes / Deficiencies:

3. Spill Prevention and Response: Are spill prevention and response procedures established and training conducted (for potential pollution sources not covered by SPCC program)?

Question appropriate personnel on procedures and training if available. Is spill kit available and maintained?

Yes No Notes / Deficiencies:

4. Storm Water Management Practices: Are structural storm water management practices present, such as sediment ponds, oil / water separators, or vegetative buffers, operating correctly?

Yes No N/A Notes / Deficiencies:

5. Sediment and Erosion Control: Are proper controls in place to prevent exposed soils, whether from construction or erosion, from potential runoff with storm water?

Yes No N/A Notes / Deficiencies:

January 2020

NSGL - Monthly Industrial Facility Storm Water Inspection Report Hunt Military Communities Scrap Yard

General Information

Inspected by: Signature:

Inspection Date:

Potential Storm Water Pollution Sources

• Erodible soils from unpaved areas

Stored chemicals and fuels for landscaping and housekeeping

• Outdoor vehicle / equipment parking and storage

• Recyclable debris & equipment

Best Management Practices (BMPs)

1. Good Housekeeping: Is facility maintained in a clean and orderly way? Are materials stored outside that have the potential to pollute storm water appropriately protected?

Yes No Notes / Deficiencies:

2. Preventative Maintenance (PM): Is there evidence that PM is being performed on equipment whose failure could result in release of chemicals to the storm sewer or surface water?

Yes No Notes / Deficiencies:

3. Spill Prevention and Response: Are spill prevention and response procedures established and training conducted (for potential pollution sources not covered by SPCC program)?

Question appropriate personnel on procedures and training if available. Is spill kit available and maintained?

Yes No Notes / Deficiencies:

4. Storm Water Management Practices: Are structural storm water management practices present, such as sediment ponds, oil / water separators, or vegetative buffers, operating correctly?

Yes No N/A Notes / Deficiencies:

5. Sediment and Erosion Control: Are proper controls in place to prevent exposed soils, whether from construction or erosion, from potential runoff with storm water?

Yes No N/A Notes / Deficiencies:

Enclosure L: Quarterly Industrial Outfall Inspection Form

NSGL Industrial SWPPP Outfall Inspection Checklist Naval Station Great Lakes

NSGL NSGL Industrial SWPPP Outfall Inspection Log

Appendix C Page 1 of 2 January 2020

Outfall Characteristics

Outfall #: Photo #: Staff:

Date & Time: Weather:

Date & Approximate Time of most recent precipitation event at NSGL:

Receiving Water:

Accessibility to Outfall:

Pipe Shape Circular Rectangular

Other:

Elliptical

Diameter or Pipe Height (in): Pipe Width, if applicable (in):

Pipe Material: RCP VCP CMP

Other:

PVC CPP

Pipe Condition: New Good

Needs to be Repaired or Replaced

Fair Poor

Outlet Type: Headwall Pipe End

Other:

Sea Wall

Outlet Condition:

New Good

Needs to be Repaired or Replaced

Fair Poor

Condition of receiving water at outfall: Eroding Sedimentation Stable

Comments:

NSGL Industrial SWPPP Outfall Inspection Checklist Naval Station Great Lakes

NSGL NSGL Industrial SWPPP Outfall Inspection Log

Appendix C Page 2 of 2 January 2020

Flow Present at Outfall: Yes No

Odor Present at Outfall: None

Sulfur

Other:

Musty

Oil

Sewage

Gasoline

Solvent

Floatables Present at Outfall: None

Algae

Oil Sheen

Litter

Sewage

Foam/Bubbles

Color of Water at Outfall: None

Brown

Yellow

Gray

Green

Other:

Turbidity of Water at Outfall: Clear Cloudy Opaque

Does Appearance or Odor suggest Yes No Not Sure potential illicit discharge? If so, inspect industrial and surrounding non industrial areas for source.

Recommended Actions: (sample analysis, additional training, establish new BMPs, etc.)

Other Comments:

Wet Weather Visual Screening

Enclosure M: OWS Inventory

BUILDING BUILDING NAME PRIMARY TYPE DESC

OEL UNIT

NAME

ASSET ID DESCRIPTION LOCATION DESCRIPTION BUILDING POC INSPECTION FREQUENCY

ESTIMATED ANNUAL PUMP-

OUTS

ADDITIONAL INFORMATION

GAS TURBINE/ENGINEMAN "C"

SCHOOL

OIL WATER SEPARATOR 238-OWS OWS in pit, three 18" MH

OWS located in pit inside in N end of bldg 238. Three 18" diameter MH 4' deep

Bi-annually 1

Bilge trench and OWS was powerwashed and cleaned in early 2020 due to a detection of polychlorinated biphenyls. Training operations are not active in this area, so OWS should not be in use, but the OWS shall still be inspected to verify if operations have changed.

325 GAS TURBINE SYSTEMS TRAINER OIL WATER SEPARATOR Tank-92406 325-OWS 2000 Gal Highland Tank OWS inside Inside bldg 325, Highland Tank 2000 gal. Annually 0

OWS is located inside Mechanical Room of B-325. The 3 access covers to the OWS are secured by ~ 40 wingnut bolts. The OWS has a gravity pump that pumps skimmed oil to an adjacent above-ground stoarge tank (AST), however there has been no detected oil in this OWS in the past 5 years. All training operations within the building have terminated, but there is residual oil contained within the equipment throughout the building so an annual inspection is still requried to verify if any maintenance is required.

1506 TRANSPORTATION MAINTENANCE OIL WATER SEPARATOR Tank-59127 1506-OWS Oil Water Separator, OWS for truck & car wash racks.

1506/ Trans. Garage. NE of wash area Bi-annually 2

CHALLENGE UNLIMITED

(Former Auto Hobby Shop) OIL WATER SEPARATOR Tank-93692 2110-OWS Oil Water Separator for former Auto Hobby Shop.

2110 - OWS for former Auto Hobby Shop. Outside NE of bldg. One 48" and three 18" concrete MHs.

Brian Smith Annually One-time only

The NSGL grounds maintenance contractor moved into B-2110 in late 2020. The car wash isystem is not operational and the contractor does not intent to use the car wash bay or repair the system.

Contractor shall pump/clean the OWS and provide an assessment of thecondition/functionality., then inspect again within 6 months. The OWS is not currently in use. The follow up inspections are to verify if building occupant operations have changed.

2801 FIRE STATION (RAY STREET) OIL WATER SEPARATOR Tank-87657 2801-OWS Oil Water Separator.

2801/ Fire House #2. Inside west end of south bay. Three 24", 7' deep concrete manholes

Quarterly 2

All liquid and sludge was pumped from OWS in early 2020. There was per- and polyfluoroalkyl substances presumed to be present so the floor drain system and OWS were triple rinsed and filled with clean water. All rinsate was collected in drums and properly disposed.

3216 MHE MAINTENANCE FACILTY OIL WATER SEPARATOR Tank-64911 3216-OWS

Oil Water Separator located subgrade outside on NE side of bldg. Receives wastewater from drain with OWS in washbay area inside building. (inside cleaned annually)

MHE MAINTENANCE FACILITY/ 2 component OWS: OWS subgrade concrete vault located outside on NE side of bldg. MH OWS inside bldg in washbay area drains to outside one.

Greg Stiltner (847)688-4589

Bi-annually 1

Inside OWS component in wash bay area is pumped out annually. Building tenant does not believe the outside vault has been pumped in many years. OCT 2017 inspection noted approximately 6" of sediment in the first chamber and 4" of sediment in the second chamber.

Contractor shall inspect and pump both the inside and outside OWS's and continue with bi-annual ispections to determine maintenance needs, 8400 WILLOW GLEN GOLF CLUB HOUSE OIL WATER SEPARATOR Tank-29033 8400-OWS

Oil water separator, 250 gal. Receives wastewater from electric golf carts wash bay. OWS located in the golf cart garage in basement of golf club house.

Interim Candidate ID 8400-OWS.

Golf Club House; located in golf cart garage in basement of bldg.

Three 30" subgrade MHs 6.5' deep.

Bi-annually 2 MWR Funded (SLIN 014)

5 MW RCC/PWD CENTRAL-NAVFAC MW OIL WATER SEPARATOR N/A

Oil water separator does not appear to have be in use, no true inlet from bldg could be identified and potential outlet pipe is very deteriorated.

Outside on the NE side of the bldg. Subgrade concrete vault 9' long by 6.5' wide by 5' deep

One-time only One-time only

OCT 2017 inspection noted 4" of oily sludge in one chamber and 3" of sludge and 3" of water in the other two chambers.

Contractor shall pump/clean the OWS and provide and assessment of the condition/functionality. If no longer in use, Navy in-house personnel will fill and seal this OWS.

13 MARINA OPERATIONAL CENTER OIL WATER SEPARATOR 13-OWS Installed in 2017 Inside bldg 13 along north wall Kevin Zaleski

(847) 688-5417

Bi-annually 1

106 FIRE STATION OIL WATER SEPARATOR 106-OWS 3 manholes, subgrade unit North side of bldg 106, Fire Station, Three 24" MHs approximately 6.5' deep

Quarterly 2

All liquid and sludge was pumped from OWS in early 2020. There was per- and polyfluoroalkyl substances presumed to be present so the floor drain system and OWS were triple rinsed and filled with clean water. All rinsate was collected in drums and properly disposed.

510 DAMAGE CONTROL "A" SCHOOL OIL WATER SEPARATOR 510-OWS Subgrade chamber, with filter section West side of north end of 510, subgrade chamber with multiple MH ports and a filter system

Bi-annually 1

523 SWOSU MR A /VACANT SPACE OIL WATER SEPARATOR N/A

Three connected below grade MHs, recently replaced or refurbished

NW corner of bldg 523, three MHs in concrete slab Bi-annually 1

There was no sediment or sludge observed during OCT 2017 inspection. It is unclear if this OWS is in use for this building.

Contractor shall inspect and provide an assesssment of condition/functionality to determine appropriate future maintenance needs.

525 MWR EPICENTER OIL WATER SEPARATOR N/A

Several manholes located near door at SE corner of bldg. two manholes were inspected

Annually One-time only

Contractor shall pump and clean the OWS and provide an assessment of condition/functionality, then inspect again within 6 months.

Note: There is a FY22 project to replace this OWS.

2712(2710) NEX CARWASH OIL WATER SEPARATOR N/A

06 report lists car wash as 2710, now 2712. Building burned Spring 2017, 4 MHs

NE corner of bldg 2712, Concrete subgrade vault 11' long x 3' wide x 4' deep with 3 MHs 1 lift station. Not in use

One-time only One-time only

OWS is not in use, but OCT 2017 inspection noted considerable floating debris at north end of the vault.

Contractor shall pump/clean the OWS and provide an assessment of conditrion/functionality. If the carwash is not planned to e replaced, Navy in-house personnel will fill and seal the OWS.

Enclosure N - NSGL Oil Water Separator Inventory (3/29/2021)

Enclosure N: OWS Inspection Form

Inspection and Maintenance Checklist Oil/Water Separators

Date: ______________ Work Order # ________________

Type of Inspection Weekly Monthly Quarterly Bi-Annual Annual

Building: _______________________ Inspector(s): _________________________________

Separator ID: __________________

Defect Conditions When Maintenance is Needed

Maintenance (1, 2, or 3)⁺ Comments/Approx. Volume

General Monitoring Inspection of discharge water for obvious signs of poor water quality.

Sediment Accumulation*

Sediment depth in bottom of vault exceeds 6-inches in depth.

Trash and Debris Accumulation*

Trash and debris accumulation in vault, or pipe inlet/outlet, floatables, and non-floatables.

Oil Accumulation*

Oil accumulations that exceed 1-inch, at the surface of the water.

Damaged Pipes Inlet or outlet piping damaged or broken and in need of repair.

Access Cover Damaged/Not Working

Cover cannot be opened, corrosion/deformation of cover.

Vault Structure Damage – Includes Cracks in Walls Bottom, Damage to Frame and/or Top Slab

Cracks wider than ½-inch or evidence of soil particles entering the structure through the cracks, or maintenance/inspection personnel determine that the vault is not structurally sound.

Cracks wider than ½-inch at the joint of any inlet/outlet pipe or evidence of soil particles entering through the cracks.

⁺ Maintenance: Enter 1 if maintenance is needed and include WO#. Enter 2 if maintenance was performed same day.

Enter 3 if condition is acceptable.

* Indicates parameters that are tracked in Maximo.

Inspection Activities Mark an “X” next to each applicable inspection activity.

Separator ID: Date of Inspection:

Name of Inspector(s):

Confined Space Entry Required: ( ) No ( ) Yes (attach permit) Special Tools Required:

Special Conditions:

INSPECTION ACTIVITY DESCRIPTION COMMENTS

GENERAL INSPECTION

Grounds maintenance/debris control Material that could enter the separator system littering:

• the area near the separator,

• in the influent channel, or

• on separator grates.

( ) No significant debris ( ) Significant debris, requires clean- up

Solids Debris buildup. ( ) Solids build-up minimal ( ) Solids require removal

Structure/Construction Material/Lines • Condition of separator liner (if applicable).

• Inspect for potential structural problems/damage (system shifting, significant cracks, low liquid level, etc.).

Foaming (non-aerated system) Foam may indicate the discharge of detergents, cleaners, or other surfactants to the system.

( ) No foam ( ) Foam noted:

Anaerobic conditions Organic (biological) material may be entering the separator and decomposing, if:

• Discrete bubbles pop to the surface of the separator, and/or

• Septic or sulfide (“rotten egg”) smells are noted.

( ) No anaerobic conditions ( ) Sulfide smell ( ) Bubble formation

INSPECTION ACTIVITY DESCRIPTION COMMENTS

Smell (gasoline or solvent) Gasoline or solvent smell may indicate that materials are being discharged to the separator that may cause the generation of hazardous waste and/or unsafe conditions.

( ) No smell ( ) Typical petroleum smell ( ) Gasoline ( ) Solvent ( ) Other

Depth of wastewater in the tank If the wastewater level is below the effluent discharge pipe, the tank may be leaking.

( ) Water level appropriate ( ) Potential leaking

Color of the wastewater Certain materials have distinctive colors that could indicate the discharge of wastewaters to the separator that should be eliminated. For example, antifreeze is generally yellow green.

( ) Clear ( ) Turbid ( ) Blackish ( ) Other:

Oil layer thickness in separation chamber

Visual estimate, indicator paste, or stick method.

( ) None ( ) Sheen - ( ) heavy, ( ) light ( ) Free product: Approximately inches ( ) Requires skimming or removal

Floating debris in separation chamber

Look for floating materials that may interfere with oil removal or the operation of the skimmer.

( ) No ( ) Yes ( ) Requires removal ( ) User requires notification

Observe oil removal from surface of separation chamber or "used oil" holding tank (as applicable)

Ensure removal is conducted in accordance with SOPs and spills do not occur.

Oil staining above the usual water line

Indicates hydraulic overloads or blockage of the effluent structure.

( ) No ( ) Yes

Excessive oil build-up in the separation chamber

Could indicate batch dumping of relatively large quantities of oil.

( ) No ( ) Yes

No build-up of oil in the separation chamber

Could indicate hydraulic overload and flushing of the system or continuous discharge of detergents or other emulsifying agents.

( ) No ( ) Yes

INSPECTION ACTIVITY DESCRIPTION COMMENTS

Available capacity in "used oil" holding tank

Measure the quantity of used oil/water in the holding tank.

( ) Requires pumping ( ) Approximate % of tank available:

SOLIDS

Accumulation of solids in separation chamber

Visual estimate or stick measurement.

( ) No significant accumulation ( ) Approximate thickness of solids:

ft.

( ) Requires solids removal

Range: once/week to monthly, depending on the rate of solids accumulation.

Observe the removal of solids from separation chamber

Ensure removal is conducted in accordance with SOPs and spills do not occur.

Per removal.

EFFLUENT STRUCTURE

Sheen or staining in effluent structure

Could indicate hydraulic surges, discharge of surfactants, discharge of oils not appropriately treated by the separator.

( ) Could not be inspected ( ) Staining ( ) No sheen ( ) Light sheen ( ) Heavy sheen ( ) Requires maintenance

Effluent weir Is weir clean and balanced (if adjustable)?

( ) Could not be inspected ( ) Weir OK ( ) Requires cleaning ( ) Needs balancing

Comments on separator inspection:

OIL/WATER SEPARATOR INSPECTOR SUMMARY SHEET

Building:

Separator ID: Installation Date:

Oil/Water Separator Inspection History

DATE INCHES

OIL

INCHES

SOLIDS

OIL ONLY

REMOVED

OIL & SOLIDS

REMOVED

VOLUME

(GALLONS)

NOTED PROBLEMS OR COMMENTS

Enclosure O: 2020 OWS Management Plan

OIL WATER SEPARATOR

MANAGEMENT PLAN

FOR

NAVAL STATION GREAT LAKES

GREAT LAKES, ILLINOIS

EMAC CONTRACT NO. N40085-15-D-8754

DELIVERY ORDER N40085-18-F-6867

FOR

NAVFAC MIDLANT

PWD GREAT LAKES FEAD

310 Seabee Way Great Lakes, Illinois 60088-2814

Prepared by:

TTL-EQM, LLC

1915 NORTH 12th STREET

TOLEDO, OHIO 43604

April 2020

Oil Water Separator Management Plan Naval Station Great Lakes, Great Lakes, IL

April 2020

OIL WATER SEPARATOR MANAGEMENT PLAN

FOR

NAVAL STATION GREAT LAKES

GREAT LAKES, ILLINOIS

EMAC CONTRACT NO. N40085-15-D-8754

DELIVERY ORDER N40085-18-F-6867

April 2020

Submitted to:

NAVFAC MIDLANT

PWD GREAT LAKES FEAD

310 Seabee Way

Great Lakes, Illinois 60088-2814

TTL Project No. 1198531

TTL-EQM, LLC does hereby certify that, to the best of its knowledge and belief, the technical data delivered herewith under this contract is complete, accurate, and complies with all requirements of the contract.

PREPARED BY:

Tony Finch, CPG TTL-EQM Senior Project Manager

APPROVED BY:

Veronica L. Winkeljohn, PE, PMP TTL-EQM Program Manager i

TABLE OF

CONTENTS

SECTION PAGE NO.

1.0 INTRODUCTION

1.1 Background

2.0 REGULATORY GUIDANCE

2.1 Clean Water Act

2.2 Oil Pollution Act of 1990

2.3 Solid Waste Disposal Act……………………………………………………………………………………………….4

2.4 Resource Conservation & Recovery Act…………………………………………………………………………4

2.5 State & Local Requirements ………………………………………………………………………………………….4

2.6 Department of Defense Directives and Executive Orders…………………..…..………………………5

3.0 MAINTENANCE AND INSPECTION GUIDELINES

3.1 OWS Inspection Procedure……………………………………………………………………………………….…...7

TABLE

Table 1 OWS Recommended Inspection Frequency

FIGURES

Figure 1 Great Lakes Naval Base Site Layout Figure 2 Map Area 1- OWS Locations Figure 3 Map Area 2- OWS Locations Figure 4 Map Area 3- OWS Locations Figure 5 Map Area 4- OWS Locations

APPENDICES

Appendix A Oil Water Separator Inventory Report dated January 2018 Appendix B Wastewater Discharge Control Document Appendix C OWS Inspection and Maintenance Checklist, Inspection Activities and

OWS Inspection Summary Form ii

ACRONYMS

APP/HASP Accident Prevention Plan/Health and Safety Plan FOTW Federal Owned Treatment Works NAVSTA-GL Naval Station Great Lakes OWS Oil Water Separator POTW Public Owned Treatment Works pvc poly-vinyl chloride PWDEV Public Works Department Environmental Division

TTL-EQM TTL-EQM LLC

1.0 INTRODUCTION

This Oil Water Separator (OWS) Management Plan establishes recordkeeping requirements, and inspection and maintenance tasks with recommended frequencies for OWSs at the Naval Station Great Lakes (NAVSTA-GL).

1.1 Background

NAVSTA-GL is a Naval facility located in Great Lakes, Illinois. NAVSTA-GL requires that oily water flows be appropriately managed in accordance with the CWA and the NAVSTA-GL Discharge Control Document (DCD) for sanitary sewage discharges to the North Shore Water Reclamation District (NSWRD). The 2018 OWS Assessment Report inventoried the OWSs at the NAVSTA-GL through a database inventory, field observations, and physical inspection. The OWS Assessment Report includes OWS descriptions, inspection results, maps depicting OWS locations, photographs of the OWSs and OWS design drawings. A copy of this report is included in Appendix A. A list of the current OWSs at the facility is included as Table 1.

2.0 REGULATORY GUIDANCE

This section summarizes the primary regulations that govern the discharge from the OWSs at the

NAVSTA-GL.

2.1 Clean Water Act

In accordance with the provisions of the Clean Water Act (CWA) (33 U.S.C. 1251); the General Pretreatment Regulations (40 CFR Part 403) that regulate the discharge from the facility; and Chapter 7 of the sewer user ordinance relating to sewers and sewer systems: NAVSTA-GL is classified as an I04 Significant Industrial User.

NAVSTA-GL is authorized to discharge non-residential waste, basin drain down, and sludge dewatering effluent from the facility into the North Shore Water Reclamation District sewer system tributary to the Gurnee Water Reclamation Facility in accordance with the effluent limitations, monitoring requirements and other conditions set forth in the DCD dated February 1, 2016. A copy of the DCD is included in Appendix B.

Table 2-1 - Oil/Water Separators and the Clean Water Act

SECTION DESCRIPTION OF CLEAN WATER ACT SECTION (AF, 1994) REGULATIONS

301 Prohibits the discharge of pollutants into the waters of the United States.

303 Water Quality Standards and Implementation Plans, requires the development of water quality standards to protect bodies of water.

40 CFR 130 and 131.

306 Categorical Effluent Limits. National Standards of Performance, requires effluent and pretreatment standards for specific categories of industries.

40 CFR 405

through 471

307 Toxic and Pretreatment Effluent Standards, requires limits on toxic pollutants.

40 CFR 129 and

311 Oil Pollution Prevention establishes requirements for preventing discharge of oil and other hazardous substances and requires certain actions following spills. The implementing regulations require the development of Spill Prevention Control and Countermeasure Plans; establish actions required in the event of a spill; designate hazardous substances; specify reportable quantities; and provide reporting procedures.

40 CFR 110,

112, 116, and

313 Federal Facilities Pollution Control requires Federal facilities to comply with all Federal, state, interstate and local water pollution requirements in the same manner as nongovernmental entities. The President may issue regulations exempting equipment or other property of the Armed Forces that is uniquely military in nature.

402 National Pollutant Discharge Elimination System requires permits to discharge point source wastewater and some storm waters. NPDES storm water permits require preparation of and compliance with the Storm Water Pollution Prevention Plan.

40 CFR 122,

125, and 402

307, 204, 208, 301, 304, and

Pretreatment Standards. Some pollutant discharges interfere with the operation of Publicly Owned Treatment Works. These standards prohibit the discharge of certain pollutants and require the pretreatment to remove other pollutants.

40 CFR 403

Oil Pollution Act of 1990 amended the CWA to expand oil spill prevention activities, improve preparedness and response capabilities, and ensure that companies are responsible for damages from spills.

40 CFR 110 and

Federal Facility Compliance Act did not amend the CWA, but this 1992 amendment of Subtitle C of the Solid Waste Disposal Act, conditionally excludes the discharge of certain wastes to FOTWs from the definition of solid waste (sewer use exclusion).

None

2.2 Oil Pollution Act of 1990

The CWA prohibits spills, leaks or other discharges of oil or hazardous substances into waters of the United States in quantities that may be harmful. The Oil Pollution Act of 1990 amended the CWA to expand oil spill prevention activities, improve preparedness and response capabilities, and ensure that companies are responsible for damages from spills (CNO, 1996).

The OPA establishes liability for removal costs and damages for those parties responsible for a vessel or facility from which oil is discharged, or which poses the substantial threat of discharge of oil, into or upon waters of the U.S. or adjoining shorelines or the exclusive economic zone. Regulations implementing portions of the OPA which could affect oil/water separators include 40 CFR Part 110, "Discharge of Oil," and Part 112, "Oil Pollution Prevention." Part 112 establishes requirements for the preparation and implementation of Spill Prevention Control and Countermeasure plans (AF, 1996).

2.3 Solid Waste Disposal Act

The SWDA, other than its RCRA provisions, regulates the disposal of solids from oil/water separators. The operating criteria (40 CFR 258.20) for municipal landfills contain restrictions on materials that may be placed in the landfill including regulated hazardous waste, polychlorinated biphenyl (PCB) waste (40 CFR 761), and “free liquids” (40 CFR 258.28).

If the solids from the oil/water separator are to be land applied, the material and operational practices must comply with “Criteria for Classification of Solid Waste Disposal Facilities and Practices” (40

CFR 257).

2.4 Resource Conservation and Recovery Act

RCRA, Subtitle C, "Hazardous Waste Management," establishes the requirements to regulate and control the generation, treatment, storage, transportation, and disposal of solid and hazardous wastes. RCRA also establishes requirements to regulate underground storage tanks containing certain substances, including oil and hazardous wastes.

If the influent wastewater, "used oil," or solids is hazardous, the following may apply:

• Oil/water separators may constitute hazardous waste treatment which requires a RCRA Treatment, Storage or Disposal Facility (TSDF) permit (DA USACE, 1994);

• Oil holding may be prohibited under RCRA unless the military installation is permitted under RCRA as a TSDF (DA USACE, 1994); and

• A leaking oil/water separator may result in designation as a solid waste management unit (Section 2.1.6.2) (DoD, 1997e).

2.5 State and Local Requirements

Not only do the state and local regulators have the option of applying standards more stringent than the Federal requirements, they may also have regulatory interpretations of existing requirements substantially different than EPA. Currently the wastewater discharge for the NAVSTA-GL is regulated under a Wastewater Discharge Control Document (DCD No. 93-94) issued by the North Shore Water Reclamation District. A copy of this document is included in Appendix B. The DCD

A PCB waste, according to federal regulations, is a substance that has a dry-weight PCB concentration greater than 50 mg/kg. State and local concentrations may be lower.

outlines the provisions for wastewater discharge limitations and monitoring requirements for the

NAVSTA-GL.

Compliance with this document does not relieve the holder of its obligations to…