NMIC-1 - RFP - Vol 2 of 2 Part 9.pdf

ATTACHMENT 5

NATIONAL MARITIME INTELLIGENCE CENTER SPILL

PREVENTION, CONTROL, AND COUNTERMEASURE PLAN

Final Submission 10 December 2020

Design-Build Request for Proposal Replace HVAC System & DDC System Upgrade NMIC Bldg 1 Suitland, Maryland

FINAL

SPILL PREVENTION, CONTROL, AND

COUNTERMEASURE PLAN

NATIONAL MARITIME INTELLIGENCE CENTER

Suitland, Maryland

Contract No. N40080-17-D-0314 Task Order: N4008017F4370

December 2019

Prepared For:

NAVFAC Washington 1314 Harwood Street, SE Building 212, 2nd Floor Washington Navy Yard, DC 20374

Prepared By:

Assisted Management Solutions, Inc.

41650 Court House Drive, Suite 100 Leonardtown, Maryland 20650

Rhea Engineers & Consultants, Inc.

441 Mars-Valencia Road Valencia, Pennsylvania 16059

NMIC SPCC 2019 i N40080-17-D-0314, F4370

Table of Contents

Table of Contents ............................................................................................................................. i List of Tables ................................................................................................................................. iv

List of Figures ................................................................................................................................ iv

List of Appendices ......................................................................................................................... iv

Acronyms and Abbreviations ..........................................................................................................v

Facility Diagrams ........................................................................................................................... vi Completion of Review/Management Approval ........................................................................... viii Certification of the Applicability of the Substantial Harm Criteria Checklist ............................... ix

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

Record of Review and Amendments ............................................................................................. xi

1.0 Plan Administration ........................................................................................................... 1-1

1.1 Purpose ................................................................................................................. 1-1

1.2 Facility Response Plan [40 CFR 112.20(a)] ........................................................ 1-1

1.3 Designated Person [40 CFR 112.7(f)(2)] ............................................................. 1-2

1.4 Professional Engineer Certification [40 CFR 112.3(d)] ...................................... 1-2

1.5 Location of SPCC Plan [40 CFR 112.3(e)] ......................................................... 1-2

1.6 SPCC Plan Review [40 CFR 112.5(b)] ............................................................... 1-2

1.7 Amendments of SPCC Plans [40 CFR 112.5(a)] ................................................. 1-3

1.8 Management Approval [40 CFR 112.7] .............................................................. 1-4

1.9 Cross-Reference with SPCC Provisions [40 CFR 112.7] .................................... 1-4

2.0 General Facility Information ............................................................................................. 2-1

2.1 Facility Description [40 CFR 112.7(a)(3)] .......................................................... 2-1

2.1.1 Location and Activities ............................................................................ 2-1

2.1.2 Facilities, Procedures, Methods, or Equipment Not Yet Fully Operational [40 CFR 112.7] .................................................................................................... 2-4

3.0 General Requirements for SPCC Plans ............................................................................. 3-1

3.1 Conformance with Requirements [40 CFR 112.7(a)(1)] ..................................... 3-1

3.2 Environmental Equivalence [40 CFR 112.7(a)(2)] .............................................. 3-1

3.3 Discharge Prevention [40 CFR 112.7(a)(3)(ii)] ................................................... 3-1

3.4 Discharge or Drainage Controls [40 CFR 112.7(a)(3)(iii)] ................................. 3-2

3.5 Release Countermeasures [40 CFR 112.7(a)(3)(iv)] ........................................... 3-2

3.6 Recovered Material Disposal [40 CFR 112.7(a)(3)(v)] ....................................... 3-3

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

3.8 Discharge Notification and Response Procedures [40 CFR 112.7(a)(4) & 112.7(a)(5)] ...................................................................................................................... 3-3

3.9 Predicted Direction, Rate of Flow, and Total Quantity of Oil Discharged as a Result of Equipment Failure [40 CFR 112.7(b)] ............................................................. 3-4

3.10 Secondary Containment to Address Typical Failure Modes [40 CFR 112.7(c)] . 3-4

3.10.1 Bulk Storage Containers .......................................................................... 3-4

3.10.2 Drum and Portable Container Storage Areas ........................................... 3-5

NMIC SPCC 2019 ii N40080-17-D-0314, F4370

3.10.3 Oil-Filled Operational Equipment ........................................................... 3-5

3.11 Practicability of Secondary Containment [40 CFR 112.7(d)] ............................. 3-5

3.12 Inspections, Tests, and Records [40 CFR 112.7(e)] ............................................ 3-5

3.13 Oil-Handling Personnel Training [40 CFR 112.7(f)(1) and (3)] ......................... 3-6

3.14 Security [40 CFR 112.7(g)] ................................................................................. 3-7

3.15 Tank Truck Loading/Unloading Racks [40 CFR 112.7(h)] ................................. 3-8

3.16 Brittle Fracture Evaluation [40 CFR 112.7(i)] ..................................................... 3-9

3.17 Conformance with State and Local Applicable Requirements [40 CFR 112.7(j)] .............................................................................................................................. 3-9

3.18 Qualified Oil-Filled Operational Equipment [40 CFR 112.7(k)] ...................... 3-10

4.0 SPCC Plan Requirements for Onshore Facilities (Excluding Production Facilities) and Animal/Fish/Vegetable Fats, Oils, and Greases .......................................................................... 4-1

4.1 Diked Storage Area: Restrain and Inspect Stormwater [40 CFR 112.8(b)(1) and (2), §112.12(b)(1) and (2)] ............................................................................................... 4-1

4.2 Facility Drainage: Design and Equipment [40 CFR 112.8(b)(3) and (4), §112.12(b)(3) and (4)] ..................................................................................................... 4-1

4.3 Facility Drainage: Pump Transfer [40 CFR 112.8(b)(5), 40 CFR 112.8(b)(5)] .. 4-2

4.4 Bulk Storage Container Construction [40 CFR 112.8(c)(1), 40 CFR 112.12(c)(1)] .

.............................................................................................................................. 4-2

4.5 Secondary Containment for Capacity of Largest Bulk Storage Container Plus Freeboard [40 CFR 112.8(c)(2), §112.12(c)(2)] .............................................................. 4-3

4.6 Diked Area Drainage [40 CFR 112.8(c)(3), 40 CFR 112.12(c)(3)] .................... 4-3

4.7 Corrosion Protection for Buried, Partially Buried and Bunkered Storage Tanks [40 CFR 112.8(c)(4) and (5), §112.12(c)(4) and (5)] ...................................................... 4-4

4.8 Test or Inspect Each Aboveground Container for Integrity [40 CFR 112.8(c)(6), 40 CFR 112.12(c)(6)]....................................................................................................... 4-4

4.8.1 Shop-Fabricated Tank Inspection Program ............................................. 4-5

4.8.2 Drum and Portable Container Inspection Program .................................. 4-5

4.9 Heating Coils [40 CFR 112.8(c)(7), 40 CFR 112.12(c)(7)]] ............................... 4-6

4.10 Overfill Prevention [40 CFR 112.8(c)(8), 40 CFR 112.12(c)(8)] ........................ 4-6

4.11 Liquid Level Sensing Devices [40 CFR 112.8(c)(8)(v), 40 CFR 112.12(c)(8)] .. 4-7

4.12 Effluent Treatment Facility Observations [40 CFR 112.8(c)(9), 40 CFR 112.12(c)(9)] .................................................................................................................... 4-7

4.13 Correct Visible Discharges [40 CFR 112.8(c)(10), 40 CFR 112.12(c)(10)] ....... 4-7

4.14 Secondary Containment for Capacity of Largest Mobile or Portable Oil Storage Container Plus Freeboard [40 CFR 112.8(c)(11), 40 CFR 112.1(c)(11)] ........................ 4-8

4.15 Corrosion Protection for Buried Piping [40 CFR 112.8(d)(1), 40 CFR 112.12(d)(1)] .................................................................................................................... 4-8

4.16 Terminal Connections [40 CFR 112.8(d)(2), 40 CFR 112.12(d)(2)] .................. 4-9

4.17 Pipe Supports [40 CFR 112.8(d)(3), 40 CFR 112.12(d)(3)] ................................ 4-9

4.18 Piping, Aboveground Valves and Appurtenances [40 CFR 112.8(d)(4), 40 CFR 112.12(d)(4)] .................................................................................................................... 4-9

4.19 Vehicle Warning [40 CFR 112.8(d)(5), 40 CFR 112.12(d)(5)] ......................... 4-10

NMIC SPCC 2019 iii N40080-17-D-0314, F4370

5.0 Facility Information ........................................................................................................... 5-1

5.1 Oil Container Inventory Summary....................................................................... 5-1

5.2 Site-Specific Information ..................................................................................... 5-2

5.2.1 Tank Systems Data Sheets and Maps ...................................................... 5-3

5.2.2 Drum and Portable Container Storage Area Data Sheets and Maps ...... 5-19

5.2.3 Oil-Filled Operational Equipment Inspection Program and Inventory .. 5-21

6.0 Discharge Response .......................................................................................................... 6-1

6.1 Notification and Reporting Requirements ........................................................... 6-1

6.2 Discharge Prevention Measures ........................................................................... 6-1

6.3 Discharge or Drainage Controls ........................................................................... 6-2

6.4 Discharge Discovery Countermeasures ............................................................... 6-2

6.4.1 Initial Spill Reporting and Discovery Procedures ................................... 6-2

6.4.2 Small Spill Response Procedures............................................................. 6-3

6.4.3 Large or Water-Based Spill Response Procedures .................................. 6-3

6.5 Methods of Disposal of Recovered Material ....................................................... 6-4

NMIC SPCC 2019 iv N40080-17-D-0314, F4370

List of Tables

Table 1: Regulation Cross-Reference .......................................................................................... 1-4

Table 2: Petroleum Storage Tanks Inventory .............................................................................. 5-1

Table 3: Drums and Portable Container Inventory ...................................................................... 5-1

Table 4: OFOE Inventory ............................................................................................................ 5-1

Table 5: Facility Capacity Summary ........................................................................................... 5-2

Table 6: NMIC Emergency Contacts ........................................................................................... 6-1

List of Figures

Figure 1: NMIC Oil Container Location Diagram ....................................................................... vii Figure 2: Site Location Map ........................................................................................................ 2-3

List of Appendices

Appendix A Storage Tank Management Plan

Appendix B SPCC Deficiency List

Appendix C Inspection Forms

Appendix D Assumptions and Calculations

Appendix E Integrity Testing Program

NMIC SPCC 2019 v N40080-17-D-0314, F4370

Acronyms and Abbreviations

API American Petroleum Institute AST Aboveground Storage Tank CFR Code of Federal Regulations COMAR Code of Maryland Annotated Regulations CRDM Continuous Release Discharge Mechanism DOT Department of Transportation EMS Environmental Management System EPA United States Environmental Protection Agency FR Federal Register FRP Facility Response Plan gpm gallons per minute GRI SPCC Guidance for Regional Inspectors, EPA (2013 edition) ICC Intelligence Coordination Center IEPD Installation Environmental Program Director Inst Instantaneous MCIA Marine Corp Intelligence Activity MDE Maryland Department of the Environment NAVFAC Naval Facilities Engineering Command NFPA National Fire Protection Association NIWA Naval Information Warfare Activity NMIC National Maritime Intelligence Cente NOAA National Oceanic and Atmospheric Administration NOSC Navy On-Scene Coordinator

NRC

NSAW

National Response Center Naval Support Activity Washington

OFOE Oil-Filled Operational Equipment ONI Office of Naval Intelligence OPNAV Chief of Naval Operations PE Professional Engineer POC Point of Contact POL Petroleum, Oil, and Lubricant PWD Public Works Department RPB Release Prevention Barrier SCP Spill Contingency Plan SOP Standard Operating Procedure SPCC Spill Prevention, Control, and Countermeasure STI Steel Tank Institute STMP Storage Tank Management Plan U.S. United States UST Underground Storage Tank

NMIC SPCC 2019 vi N40080-17-D-0314, F4370

Facility Diagrams

A facility map that provides the physical location of each bulk oil container regulated under the Spill Prevention, Control, and Countermeasure (SPCC) Program is illustrated in Figure 1 for the National Maritime Intelligence Center (NMIC). Due to security restrictions, no figure was made to depict the physical location for each piece of Oil-Filled Operational Equipment (OFOE) regulated under the SPCC Program for NMIC. The only drum storage location is depicted in Figure 1.

Individual diagrams for buildings with tanks are located in Section 5.2.1 and include site-specific compliance information such as oil storage container details, contents, capacity, discharge prevention measures, potential release scenarios with appropriate secondary containment assessments, and discharge controls. Similar details concerning drum and portable container storage areas and OFOE are found in Sections 5.2.2 and 5.2.3, respectively. NMIC does not have mobile equipment or mobile refuelers.

Figure 1 and the individual diagrams for each container site satisfy the facility diagram requirements of §112.7(a)(3).

NMIC SPCC 2019 vii N40080-17-D-0314, F4370

Figure 1: NMIC Oil Container Location Diagram

NMIC SPCC 2019 viii N40080-17-D-0314, F4370

Completion of Review/Management Approval

In accordance with 40 Code of Federal Regulations (CFR) 112.5(b), I have completed review and evaluation of this Spill Prevention, Control, and Countermeasure Plan for the National Maritime Intelligence Center 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 xi 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.

G.A. Dicks Date Captain, U.S. Navy Commanding Officer

NMIC SPCC 2019 ix N40080-17-D-0314, F4370

Certification of the Applicability of the Substantial Harm Criteria Checklist

Section 112.20(e) of the Facility Response Plan (FRP) regulation requires that all facilities regulated by the Oil Pollution Prevention Regulation (40 CFR part 112) conduct an initial screening to determine whether they are required to develop an FRP. The criteria in this checklist can be found in 40 CFR 112.20(f)(1). Facilities should include this form with their SPCC Plan.

Facility Name: National Maritime Intelligence Center Facility Address: 4251 Suitland Road, Suitland, Maryland 20746

1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons?

Yes ☐ No ☒

2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation within any aboveground oil storage tank area?

Yes ☐ No ☒

3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the formula in Attachment C-III, Appendix C, 40 CFR 112 or a comparable formula1) such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? For further description of fish and wildlife and sensitive environments, see Appendices I, II, and III to DOC/NOAA's "Guidance for Facility and Vessel Response Environments" (Section 10, Appendix E, 40 CFR 112 for availability) and the Mid- Atlantic Coastal Area Contingency Plan.

Yes ☐ No ☒

4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the appropriate formula (Attachment C-III, Appendix C, 40 CFR 112 or a comparable formula1) such that a discharge from the facility would shut down a public drinking water intake2?

Yes ☐ No ☒

5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a reportable oil spill in an amount greater than or equal to 10,000 gallons within the last 5 years?

Yes ☐ No ☒

Certification

I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate, and complete.

Installation Commanding Officer

Signature Title

CAPT G.A. Dicks Name (Type or Print) Date

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

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

NMIC SPCC 2019 x N40080-17-D-0314, F4370

Professional Engineer Certification [40 CFR 112.3(d)]

The undersigned licensed Professional Engineer (PE) attests:

i. That I am familiar with the requirements of 40 CFR 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 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 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.

MD 52680

Signature License Number

Lauren Greenfield

Civil Engineer Name Title

Rhea Engineers & Consultants, Inc.

31 December 2019 Company Date

NMIC SPCC 2019 xi N40080-17-D-0314, F4370

Record of Review and Amendments

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

Amendment Number Date

Section/ Pages

Affected Description of Changes PE or POC

Name PE or POC Signature

Dec

All New SPCC Plan that supersedes and replaces all prior SPCC Plans

Lauren Greenfield, PE

NMIC SPCC 2019 1-1 Plan Administration

1.0 Plan Administration

1.1 Purpose

The purpose of this Spill Prevention, Control, and Countermeasure (SPCC) Plan is to establish procedures, methods, equipment, and other requirements necessary to prevent the discharge of oil from the National Maritime Intelligence Center (NMIC) from reaching navigable waters of the United States (U.S.) or adjoining shorelines. The term “oil” is defined in Title 40, CFR 112 (SPCC Rule or §112) as oil of any kind or in any form, including, but not limited to: fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and, other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil. The terms “petroleum, oil, and lubricants (POL)” and “oil” may be used interchangeably throughout the document and are intended to include the complete realm of substances regulated under §112. The Plan is intended to prepare the Owner (Commander, Naval Support Activity Washington), hereinafter referred to as Owner, and Operator (Naval Support Activity Washington [NSAW]), 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 NAVFAC Atlantic in accordance with the provisions of §112, various industry standards, and Chief of Naval Operations (OPNAV) Instruction OPNAV M-5090.1 (10 January 2014), Environmental Readiness Program Manual. Facilities located within the facility boundary of NMIC that store and transfer oil in support of Navy activities are included in this plan due to 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 U.S., adjoining shorelines, into the subsurface aquifer, or outside the property onto non-federal land. This SPCC Plan supersedes and replaces all editions of all previous SPCC Plans.

NMIC is required to prepare a Storage Tank Management Plan (STMP) as part of the governing Navy environmental policy as defined by OPNAV M-5090.1. The STMP has similar although not identical requirements as those of the SPCC program. The STMP requirements that are not addressed in the SPCC are presented in Appendix A of this SPCC Plan. The goal of this approach is to meet all SPCC and STMP requirements in a single document.

1.2 Facility Response Plan [40 CFR 112.20(a)]

§112.20(a) The owner or operator of any non-transportation-related onshore facility that, because of its location, could reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines shall prepare and submit a facility response plan to the Regional Administrator.

NMIC SPCC 2019 1-2 Plan Administration

NMIC does not require an FRP as defined by the Substantial Harm Criteria required by §112.20.

The Certificate of Substantial Harm Determination is located on page xi of the Plan.

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 NSAW Installation Environmental Program Director (IEPD) for NMIC is the Designated Person described in §112.7(f)(2) who reports to facility management and is accountable for discharge prevention.

See Section 6.0 of this Plan for additional contact information.

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

Professional Engineer (PE) Certification is located on page x 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 oversight is provided through the NSAW IEPD. In accordance with §112.3(e), a complete copy of this Plan is maintained at the PWD Environmental Office, to be referred as “Environmental Office,” at 1013 O St. SE, Suite 100-NE-22, Washington, D.C. 20734 and at the NMIC Facilities Management Office (Building 1) hereinafter referred to as the “Facilities Office”. The Facilities 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.”

NMIC SPCC 2019 1-3 Plan Administration

The Commander, NSAW, in conjunction with the IEPD, is responsible for initiating and coordinating comprehensive reviews of the SPCC Plan at least once every five years. The IEPD will amend this Plan within six months of the review and will implement the amended Plan within six months of the amendment. The amendment will 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 and Amendments located on page xi 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 NMIC IEPD or his/her designee 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 xi).

Deficiencies and recommended corrective actions noted during preparation of this Plan are listed in Appendix B. When deficiencies are corrected in accordance with the recommended actions, the deficiency list should be noted with a date and signature to document completion of the corrective

NMIC SPCC 2019 1-4 Plan Administration 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 xi) as administrative updates.

1.8 Management Approval [40 CFR 112.7]

Management Approval Acknowledgement is located on page viiii 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 across-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 1.7 112.5(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 0

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, Figure 1, and Figure 2

112.7(a)(3)(i) Container Storage Capacity and Oil Type Section 3.3 112.7(a)(3)(ii) Discharge Prevention Measures Section 3.3 112.7(a)(3)(iii) Discharge or Drainage Controls Section 3.4 112.7(a)(3)(iv) Release Countermeasures Section 3.5 112.7(a)(3)(v) Methods of Disposal of Recovered Material Section 3.6 112.7(a)(3)(vi) Contact List Section 3.7 112.7(a)(4) Discharge Notification Section 3.8 112.7(a)(5) Discharge Response Procedures Section 3.8

112.7(b) Predicted Direction, Rate of Flow, and Total Quantity of Oil Discharged as a Result of Equipment Failure Section 3.9

NMIC SPCC 2019 1-5 Plan Administration

112.7(c) Secondary Containment to Address Typical Failure Modes Section 3.10

112.7(d) Practicability of Secondary Containment Section 3.11 112.7(e) Inspections, Tests, and Records Section 3.12 112.7(f)(1) Oil-handling Personnel Training Section 3.13 112.7(f)(2) Designated Person Section 1.3 112.7(f)(3) Discharge Prevention Briefings Section 3.13 112.7(g) Security Section 3.14 112.7(h) Tank Truck Loading/Unloading Racks Section 3.15 112.7(i) Brittle Fracture Evaluation Section 3.16

112.7(j) Conformance with Applicable State and Local Requirements Section 3.17

112.7(k) Qualified Oil-filled Operational Equipment Section 3.18 112.8(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

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 4.19 112.12(b)(1) Diked Storage Area: Restrain Stormwater Section 4.1

NMIC SPCC 2019 1-6 Plan Administration

112.12(b)(2) Diked Storage Area: Drainage Valves and Inspect Stormwater Section 4.1

112.12(b)(3) Facility Drainage: Design Section 4.2 112.12(b)(4) Facility Drainage: Equipment Section 4.2 112.12(b)(5) Facility Drainage: Pump Transfer Section 4.3 112.12(c)(1) Bulk Storage Container Construction Section 4.4

112.12(c)(2) Secondary Containment for Capacity of Largest Bulk Storage Container Plus Freeboard Section 4.5

112.12(c)(3) Dike Drainage Section 4.6

112.12(c)(4),(5) Corrosion Protection for Buried, Partially Buried and Bunkered Storage Tanks Section 4.7

112.12(c)(6) Inspection of Bulk Storage Containers Section 4.8 112.12(c)(7) Heating Coils Section 4.9 112.12(c)(8) Overfill Prevention System Section 4.10 112.12(c)(8) Liquid Level Sensing Device Testing Section 4.11 112.12(c)(9) Effluent Treatment Facilities Section 4.12 112.12(c)(10) Correct Visible Discharges Section 4.13

112.12(c)(11) Secondary Containment for Capacity of Largest Mobile or Portable Oil Storage Container Plus Freeboard Section 4.14

112.12(d)(1) Corrosion Protection for Buried Piping Section 4.15 112.12(d)(2) Terminal Connections Section 4.16 112.12(d)(3) Pipe Supports Section 4.17

112.12(d)(4) Piping, Aboveground Valves and Appurtenances Inspection Section 4.18

112.12(d)(5) Vehicle Warning Section 4.19 112.20(a) Facility Response Plan Section 1.2

NMIC SPCC 2019 2-1 General Facility Information

2.0 General Facility Information

Facility Name: National Maritime Intelligence Center

Mailing Address: National Maritime Intelligence Center

4251 Suitland Road Suitland, Maryland 20395

Physical Location: National Maritime Intelligence Center

4251 Suitland Road Suitland, Maryland 20395

Type: Military Intelligence Operations

Owner: Commander, Naval Support Activity, Washington

Operator: Naval Support Activity Washington 1013 O St. SE Suite 100-NE-22 Washington, D.C. 20734

Primary contact: Installation Environmental Program Director 1013 O St. SE Suite 100-NE-22 Washington, D.C. 20734

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;

NMIC is headquartered in Suitland, Maryland in Prince George County approximately four miles southwest of Washington, DC, near the intersection of Suitland Parkway and Interstate 495. The facility is also located approximately two miles east of the Anacostia River. NMIC does not represent a single command but brings together several military intelligence operations for the

NMIC SPCC 2019 2-2 General Facility Information

U.S., including the Navy, Marine Corps, and the Coast Guard. Facilities at NMIC are used primarily for intelligence operations, research, and development. The Navy is the dominant tenant at NMIC, which is the home of the Office of Naval Intelligence (ONI). NMIC also houses offices for the Naval Information Warfare Activity (NIWA) and the principal intelligence agencies of two smaller services, the Marine Corp Intelligence Activity (MCIA) and the Coast Guard Intelligence Coordination Center (ICC).

NMIC occupies 42 acres of the 226-acre Suitland Federal Center property and is situated on the Metro’s Green Line alongside the Census Bureau, the Washington National Records Center, and the National Atmospheric and Oceanic Administration. NMIC is housed in a 603,000 square foot facility that contains the headquarters of ONI, NIWA, MCIA, and ICC. The Suitland Federal Center is bordered along the west by residential and wooded property, along the south by the Suitland Parkway, along the east by Silver Hill Road, and along the north by Suitland Road. See Figure 2 for a map depicting the general geographic location and facility boundary.

Figure 1 (page vii) is the NMIC facility map that provides the physical location for each SPCC-regulated asset. Due to security reasons, no figure was made to depict the physical location for each piece of Oil-Filled Operational Equipment (OFOE) regulated under the SPCC Program for NMIC. The only drum storage location was added to Figure 1. Individual diagrams for buildings with tanks are located in Section 5.2.1 and include site-specific compliance information such as oil storage container details, contents, capacity, piping, discharge prevention measures, potential release scenarios with appropriate secondary containment assessments, and discharge controls.

Spill response procedures, disposal, and contact lists can be found in the Spill Contingency Plan (SCP). Immediate response actions are summarized in Section 6.0 of this Plan.

Underground storage tanks (USTs) fully regulated under the Code of Maryland Annotated Regulations (COMAR) 26.10 are included in this plan in order to use the inventory and deficiency list as elements of the STMP required by Navy Policy (OPNAV M-5090.1 Chapter 31- 3.1). Spill release scenarios relating to transfer of oil into and out of these tanks are assessed and appropriate secondary containment measures are specified.

NMIC SPCC 2019 2-3 General Facility Information

Figure 2: Site Location Map

NMIC SPCC 2019 2-4 General Facility Information

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.

As of the writing of this Plan, there are four new ASTs currently under construction at NMIC, with an estimated construction completion date of December 2021. Operational start-up is estimated to occur in January 2022. The four ASTs will store fuels (diesel and gasoline) and are constructed within a concrete containment berm. There is also a planned dispenser and filling station. Other construction and tank details are not known as of the writing of this Plan.

NMIC SPCC 2019 3-1 General Requirements for SPCC Plans

3.0 General Requirements for SPCC Plans

NMIC meets the definition of a “non-transportation-related” facility and stores more than 108,118 gallons of oil products in aboveground containers. The facility meets the applicability threshold of §112 and is therefore subject to the U.S. Environmental Protection Agency (EPA) SPCC Regulations and must develop an SPCC plan. Additionally, NMIC must meet Maryland Oil Pollution and Tank Management regulations contained in COMAR 26.10 et seq. and applicable U.S. Navy policy requirements related to oil storage and spill prevention.

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

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, drum and portable containers, OFOE, and all associated POL 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 SPCC 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).

This Plan does not deviate from the requirements in §112.

3.3 Discharge Prevention [40 CFR 112.7(a)(3)(ii)]

(ii) Discharge prevention measures including procedures for routine handling of products (loading, unloading, and facility transfers, etc.);

Standard Operating Procedures (SOPs) are implemented at NMIC. These procedures are written and posted in the work areas. Written procedures specifically required by 40 CFR 112 include inspections, proper loading and unloading operations, and secondary containment drainage. In

NMIC SPCC 2019 3-2 General Requirements for SPCC Plans addition to these specific SOPs, NMIC supervisors should identify any additional operations at the Facility that may require standard procedures to avoid a spill.

The discharge prevention procedures during fuel transfer are summarized as follows:

Prior to off-loading, the type and quantity of fuel being received is verified to ensure product is off-loaded into the proper tank. The delivery driver will position the vehicle in a manner that will enable off-loading of fuel with the least amount of hose necessary. The tank truck driver uses wheel chocks to chock the delivery vehicle and sets the parking brake at each location prior to off-loading. If the substance being transferred is flammable or combustible, the tanker trailer shall be grounded. The area is cordoned off with cones that are placed at the front, rear, and side of the vehicle where the off-loading hoses are to be laid on the ground.

Drivers are responsible for connecting and disconnecting transfer hoses on the tanker trailer and storage valves. Hoses are visually inspected for damage before use. Spill containment devices (i.e.absorbent pads or drip pan) are placed below the valve-hose fitting connection on the tanker trailer to absorb to catch any product that may leak due to a loose connection. If more than once hose is needed for the transfer, then the same type of spill containment shall be employed at each hose connection. At least one portable “B-C” type fire extinguisher is readily available at all times during transfer operations in the event of an emergency. All tanker trucks are equipped with spill kits. No smoking is allowed within 50 feet of the operations.

The tank is gauged prior to off-loading to ensure that there is capacity to receive the delivery. Tank filling operations are continuously monitored to ensure that the tank is not overfilled. Minor spills from a tank overfill would be contained and cleaned-up by absorbents on the delivery truck. Major leaks or spills shall result in immediate termination of transfer operations and the initiation of spill containment measures, including initial spill response notifications. At least one person shall stay on-site at the spill to control the perimeter of the spill area.

3.4 Discharge or Drainage Controls [40 CFR 112.7(a)(3)(iii)]

(iii) Discharge or drainage controls such as secondary containment around containers and other structures, equipment, and procedures for the control of a discharge;

Refer to the site-specific information sheets and site maps in Section 6.2.1 of this Plan for a description of the containment or diversionary structures and discharge or drainage controls at each storage tank facility. Sections 5.2.2 and 5.2.3 contain information on sized and general secondary containment for drum and portable container storage areas, and OFOE, respectively.

3.5 Release Countermeasures [40 CFR 112.7(a)(3)(iv)]

(iv) Countermeasures for discharge discovery, response, and cleanup (both the facility's capability and those that might be required of a contractor);

NMIC SPCC 2019 3-3 General Requirements for SPCC Plans

Immediate action must be taken to control, contain, and recover discharged product. Refer to Sections 5.2.1 to 5.2.3 , General Secondary Containment Compliance sheet for a summary of countermeasures for specific discharge discovery, response, and cleanup scenarios at each container site. Detailed instructions for discharge discovery, response, and clean up are provided in the NMIC SCP and summarized in Section 6.0 of this document.

3.6 Recovered Material Disposal [40 CFR 112.7(a)(3)(v)]

(v) Methods of disposal of recovered materials in accordance with applicable legal requirements; and

The NMIC SCP and Hazardous Waste Management Plan addresses containment, drainage, and disposal plans for materials (hazardous and non-hazardous) recovered during a discharge response.

NMIC must comply with all applicable federal, state, and local regulatory requirements pertaining to the disposal of materials recovered during discharge response and cleanup operations. The PWD Environmental Office will maintain a copy of all disposal manifests for documentation.

3.7 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 contact list and phone numbers for the Facility Response Coordinator, National Response Center (NRC), 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 6.0, Table 6.

3.8 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…