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FINAL SPILL PREVENTION, CONTROL,
AND COUNTERMEASURE (SPCC) PLAN
NAVAL SUPPORT FACILITY - BEAUFORT
BEAUFORT, SOUTH CAROLINA
Prepared for:
Naval Hospital Beaufort Beaufort, SC
Under Contract to:
Naval Facilities Engineering Command Southeast Region Headquarters
PO Box 30, Bldg. 903 Jacksonville, FL 32212
NAVFAC Southeast IDIQ Contract
N69450-14-D-0029, Task Order 0010
August 2015
Prepared by:
THIS PAGE INTENTIONALLY LEFT BLANK
NSF BEAUFORT SPCC PLAN
i August 2015
Table of Contents
1. Plan Administration ................................................................................................................... 1-1
1.1 Cross-Reference with SPCC Provisions .................................................................................... 1-1
1.2 Management Approval ............................................................................................................ 1-5
1.2.1 Executive Summary..................................................................................................... 1-7
1.3 Professional Engineer Certification.......................................................................................... 1-9
1.4 Designated Person ................................................................................................................. 1-11
1.5 Location of SPCC Plan ............................................................................................................ 1-11
1.6 SPCC Plan Review ................................................................................................................... 1-11
1.7 Amendments of SPCC Plans ................................................................................................... 1-11
1.7.1 Periodic Amendments .............................................................................................. 1-11
1.7.2 Amendment by Regional Administrator ................................................................... 1-12
2. General Facility Information ....................................................................................................... 2-1
2.1 Facility Description ................................................................................................................... 2-1
2.2 Oil Storage Containers ............................................................................................................. 2-3
2.2.1 High-Risk Oil Storage Facilities .................................................................................... 2-4
2.2.2 Drum Storage Areas .................................................................................................. 2-10
2.2.3 Ancillary Aboveground Storage Containers .............................................................. 2-10
2.2.4 Used Cooking Oil Containers .................................................................................... 2-11
2.2.5 Oil-Filled Operational Equipment ............................................................................. 2-11
2.2.6 Facility Piping ............................................................................................................ 2-11
2.2.7 Oil Water Separators (OWS) ..................................................................................... 2-12
2.2.8 Mobile Refueler and Portable Containers ................................................................ 2-12
2.2.9 Underground Storage Tanks ..................................................................................... 2-12
2.2.10 Other Containers (Out of Service, Permanently Closed, or Temporary Contractor
Containers) ................................................................................................................ 2-12
2.3 Facilities, Procedures, Methods, or Equipment Not Yet Fully Operational ........................... 2-13
3. Conformance and Environmental Equivalence ............................................................................ 3-1
3.1 Conformance with Requirements ............................................................................................ 3-1
3.2 Environmental Equivalence ..................................................................................................... 3-1
4. Predicted Spills and Oil Containing Equipment Failure ................................................................. 4-1
4.1 Discharge Notification and Response Procedures ................................................................... 4-1
4.2 Predicted Direction, Rate of Flow, and Total Quantity of Oil Discharged as a Result of
Equipment Failure .................................................................................................................... 4-1
4.2.1 Bulk Fuel Storage Tank Farm – Facility 14 .................................................................. 4-1
4.2.2 Mobile Refueler Loading and Parking Area – Facility 11 ............................................ 4-3
4.2.3 NEX Service Station – Facility 22 ................................................................................. 4-3
4.2.4 Mobile Tanks and Portable Containers ....................................................................... 4-4
4.2.5 Drum Storage Areas .................................................................................................... 4-4
4.2.6 Oil Filled Operational Equipment ............................................................................... 4-5
4.2.7 Piping .......................................................................................................................... 4-5
4.3 Discharge or Drainage Controls ............................................................................................... 4-6
4.4 Disposal of Recovered Materials ............................................................................................. 4-7
5. Secondary Containment ............................................................................................................. 5-1
5.1 Containment Requirement ...................................................................................................... 5-1
5.1.1 Stationary Tanks ......................................................................................................... 5-1
5.1.2 Portable Oil Storage Containers ................................................................................. 5-1 ii August 2015
5.1.3 Truck Loading/Unloading Racks .................................................................................. 5-1
5.2 Secondary Containment for the Bulk Containers .................................................................... 5-1
5.2.1 Secondary Containment plus Freeboard .................................................................... 5-1
5.2.2 Field Constructed Tanks .............................................................................................. 5-3
5.2.3 Shop-Fabricated Ancillary Tanks ................................................................................. 5-3
5.3 Secondary Containment for Mobile or Portable Oil Containers .............................................. 5-3
5.3.1 Mobile Generators and Portable Tanks ...................................................................... 5-3
5.3.2 Refueler Trucks ........................................................................................................... 5-4
5.3.3 Drum Storage Areas (including Used Cooking Oil containers) ................................... 5-4
5.4 Secondary Containment for Loading and Unloading Racks ..................................................... 5-4
5.5 Impracticability of Secondary Containment ............................................................................ 5-4
5.5.1 Aboveground Piping.................................................................................................... 5-4
5.5.2 Designated Fuel Transfer Area.................................................................................... 5-5
5.6 Impracticability of Secondary Containment ............................................................................ 5-6
5.7 Secondary Containment for Oil-Filled Operational Equipment ............................................... 5-6
6. Inspections, Tests, and Records .................................................................................................. 6-1
6.1 Recordkeeping ......................................................................................................................... 6-1
6.2 Inspections ............................................................................................................................... 6-1
6.2.1 Aboveground Piping, Valves, and Appurtenances ...................................................... 6-1
6.2.2 Diked Storage Area ..................................................................................................... 6-1
6.2.3 Aboveground Bulk Storage Containers ....................................................................... 6-2
6.2.4 Fuel Transfer Piping .................................................................................................... 6-2
6.2.5 Oil-Water Separators .................................................................................................. 6-2
6.2.6 Emergency Generators ............................................................................................... 6-2
6.2.7 Grease Traps and Food Oil Containers ....................................................................... 6-2
6.2.8 OFOE (Transformers and Elevators) ........................................................................... 6-3
6.2.9 Portable Containers .................................................................................................... 6-3
6.2.10 Integrity Testing .......................................................................................................... 6-6
6.2.11 Underground Storage Tanks ..................................................................................... 6-10
6.2.12 Underground Piping Inspections .............................................................................. 6-10
6.2.13 Aboveground Piping.................................................................................................. 6-10
6.3 Liquid Level Sensing Devices .................................................................................................. 6-10
6.3.1 Field Constructed Tanks (API 650) ............................................................................ 6-11
6.3.2 Shop-Fabricated Ancillary Containers ....................................................................... 6-11
6.4 Mobile Refuelers and Portable Containers ............................................................................ 6-11
7. Oil-Handling Personnel Training ................................................................................................. 7-1
7.1 Initial Training .......................................................................................................................... 7-1
7.2 Annual Discharge Prevention Briefings ................................................................................... 7-2
7.3 State UST Training .................................................................................................................... 7-2
8. Security ..................................................................................................................................... 8-1
8.1 Site Access and Fencing ........................................................................................................... 8-1
8.2 Master Flow and Drain Valves ................................................................................................. 8-1
8.3 Starter Controls ........................................................................................................................ 8-1
8.4 Pipeline Loading and Unloading Connections ......................................................................... 8-2
8.5 Lighting ..................................................................................................................................... 8-2
9. Procedures for Fuel Transfer Areas ............................................................................................. 9-1
9.1 Transfer Procedures for Loading/Unloading Racks ................................................................. 9-1
9.2 Transfer Procedures other than Loading/Unloading Racks ..................................................... 9-1 iii August 2015
9.2.1 Transfer Operations – General ................................................................................... 9-2
9.2.2 Pipeline to Field Constructed Container Transfer Operation ..................................... 9-3
9.2.3 Tank Truck to Container Transfer Operations (including USTs) ................................. 9-3
9.2.4 Used Oil and Cooking Oil Containers Transfer Operations ......................................... 9-4
9.2.5 Containers to Mobile Refueler (Open Port) Transfer Operations .............................. 9-4
9.2.6 Operator to OFOE Hydraulic Containers (Open Port) Transfer Operations ............... 9-5
9.2.7 Aircraft — Refueling/Defueling Transfer Operations ................................................. 9-5
10. Brittle Fracture Evaluation ....................................................................................................... 10-1
11. Conformance with State and Local Applicable Requirements .................................................... 11-1
11.1 State Regulatory Standards ................................................................................................... 11-1
11.2 Relevant Regulatory Standards .............................................................................................. 11-1
12. Qualified Oil-Filled Operational Equipment ............................................................................... 12-1
13. Drainage Controls .................................................................................................................... 13-1
13.1 Discharge or Drainage Controls ............................................................................................. 13-1
13.2 Diked Storage Area (Restrain and Inspect Stormwater) ........................................................ 13-1
13.3 Facility Drainage: Design and Equipment .............................................................................. 13-1
13.4 Facility Drainage: Pump Transfer ........................................................................................... 13-2
14. Other SPCC Requirements ........................................................................................................ 14-1
14.1 Container Construction .......................................................................................................... 14-1
14.2 Corrosion Protection for Buried, Partially Buried and Bunkered Storage Tanks ................... 14-1
14.3 Corrosion Protection for Buried Piping .................................................................................. 14-1
14.4 Heating Coils .......................................................................................................................... 14-1
14.5 Overfill Prevention ................................................................................................................. 14-2
14.6 Effluent Treatment Facility .................................................................................................... 14-2
14.7 Terminal Connections ............................................................................................................ 14-2
14.8 Pipe Supports ......................................................................................................................... 14-2
14.9 Vehicle Warning ..................................................................................................................... 14-3
Tables
1-1 Regulatory Cross-Reference Matrix 2-1 Total Oil Storage Capacity 2-2 Regulated Oil Storage Container Inventory and Summary of Conditions 5-1 Secondary Containment Volumes of Bulk Containers 5-2 Secondary Containment Volumes Mobile or Portable Oil Storage Containers 6-1 Inspection Schedule 6-2 Shop Fabricated Tank Category and Inspection Requirements 6-3 STI Based Periodic Testing Requirements 11-1 Relevant Regulatory Standards
Appendixes Appendix A Tank Data Sheets Appendix B Facility Diagrams Appendix C STI and Manufacturer Forms_Checklists Appendix D Record of Initial Training and Annual Discharge Prevention Briefings Appendix E Record of SPCC Plan Five Year Reviews and Amendments Appendix F Assumptions and Calculations iv August 2015
Figures
2-1 Site Vicinity Map 2-2 Steam Plant- Building 13 2-3 Generator House – Building 1A 2-4 NEX Service Station – Facility 20 v August 2015
Acronyms and Abbreviations ANSI American National Standards Institute API American Petroleum Institute ASME American Society of Mechanical Engineers AST Aboveground Storage Tank ATG Automatic Tank Gauge bbl Barrel (of petroleum) (42 United States gallons)
CFR Code of Federal Regulations CMP Centrally Managed Program CNRSE Commander, Navy Region Southeast
DLA-E Defense Logistics Agency – Energy DOT Department of Transportation DSN Defense Switched Network
FIC Facility Incident Commander
GRI Guidance for Regional Inspectors GSE Ground Support Equipment
ID Identification m3 Cubic Meter
N/A Not Applicable NACE National Association of Corrosion Engineers NAS Naval Air Station NAVFAC Naval Facilities Engineering Command NEX Navy Exchange Service NFPA National Fire Protection Association NOAA National Oceanic and Atmospheric Administration NPDES National Pollutant Discharge Elimination System
OLF Outlying Field OFOE Oil-Filled Operational Equipment OWS O-Water Separator
PCB Polychlorinated Biphenyls PWD Public Works Department
SCDHE C South Carolina Department of Heath and Environmental Control SCE&G South Carolina Electric & Gas SOP Standard Operating Procedure SPCC Spill Prevention, Control, and Countermeasures STI Steel Tank Institute
UCO Used Cooking Oil UFC Unified Facilities Criteria UL United Laboratories USEPA United States Environmental Protection Agency UST Underground Storage Tank
WWTP Wastewater Treatment Plant vi August 2015
1-1 August 2015
SECTION 1
1. Plan Administration
1.1 Cross-Reference with SPCC Provisions
TABLE 1-1
Regulatory Cross-Reference Matrix
Regulation Citation
(40 CFR 112)
Regulatory Requirement Description SPCC Plan
Section
112.3(d) Professional Engineer Certification Section 1.3
112.3(e)(1) Location of SPCC Plan Section 1.5
112.4 Amendments by Regional Administrator Section 1.7.2
112.5(a) Amendments Section 1.7, Appendix E
112.5(b) SPCC Plan Review Section 1.6
112.7 Management Approval Section 1.2
112.7 Cross-Reference with SPCC Rule Section 1.1
112.7 Facilities, Procedures, and Methods Section 2.3
112.7(a)(1) Conformance with Requirements Section 3
112.7(a)(2) Environmental Equivalence Section 3.2
112.7(a)(3) Facility Information, Boundary, and Facility Diagram Section 2, Appendix B
112.7(a)(3)(i) Container Storage Capacity and Oil Type Section 2.2
112.7(a)(3)(ii) Discharge Prevention Measures Section 9.2, Appendix A
112.7(a)(3)(iii) Discharge or Drainage Controls Section 4.3
112.7(a)(3)(iv) Discharge Discovery Countermeasures Section 4.3
112.7(a)(3)(v) Methods of Disposal of Recovered Material Section 4.4
112.7(a)(3)(vi) Contact List Section 4.1
112.7(a)(4) Discharge Notification Section 4.1
112.7(a)(5) Discharge Response Procedures Section 4.1
112.7(b) Predicted Direction, Rate of Flow, and Total Quantity of Oil Discharged as a Result of Equipment Failure Section 4.2, Appendix A
112.7(c) Secondary Containment to Address Typical Failure Modes Section 5.2
§112.7 States that a Cross Reference must exist detailing all applicable requirements of this section.
1-2 August 2015
Regulation Citation
(40 CFR 112)
Regulatory Requirement Description SPCC Plan
Section
112.7(d) Impracticability of Secondary Containment Section 5.6
112.7(e) Inspections, Tests, and Records Section 6
112.7(f)(1) Oil-Handling Personnel Training Section 7.1, 7.2
112.7(f)(2) Designated Person Section 1.4
112.7(f)(3) Discharge Prevention Briefings Section 7.2
112.7(g) Security Section 8
112.7(h)(1-3) Tank Truck Loading and Unloading Racks Section 9.1
112.7(i) Brittle Fracture Evaluation Section 10
112.7(j) Conformance with Applicable State and Local Requirements Section 11
112.7(k) Qualified Oil-Filled Operational Equipment (OFOE) Section 12
112.8(b)(1) Diked Storage Area: Restrain Storm water Section 13.2
112.8(b)(2) Diked Storage Area: Drainage Valves and Inspect Storm water Section 13.2
112.8(b)(3) Facility Drainage: Design Section 13.3
112.8(b)(4) Facility Drainage: Equipment Section 13.3
112.8(b)(5) Facility Drainage: Pump Transfer Section 13.4
112.8(c)(1) Bulk Storage Container Construction Section 14.1
112.8(c)(2) Secondary Containment for Capacity of Largest Bulk Storage Container Plus Freeboard Section 5.2.1
112.8(c)(3) Discharge or Drainage Controls Section 13.1
112.8(c)(3)(i-
iv) Diked Storage Area: Inspection Section 6.2.2
112.8(c)(3)(iv) Diked Storage Area: Recordkeeping Section 6.1
112.8(c)(iv, v) Corrosion Protection for Buried, Partially Buried, and Bunkered Storage Tanks Section 14.2
112.8(c)(6) Inspection of Bulk Storage Containers Section 6.2
Steel Tank Institute (STI) SP001 Monthly and Annual Inspection Checklists
Section 6.3.2, Appendix C
1-3 August 2015
Regulation Citation
(40 CFR 112)
Regulatory Requirement Description SPCC Plan
Section
112.8(c)(7) Heating Coils Section 14.4
112.8(c)(8) Overfill Prevention System Section 14.5
112.8(c)(8)(v) Liquid Level Sensing Device Testing Section 6.3
112.8(c)(9) Effluent Treatment Facilities Section14.6
112.8(c)(10) Correct Visible Discharges Section 4.3
112.8(c)(11) Secondary Containment for Capacity of Largest Mobile or Portable Oil Storage Container Plus Freeboard Section 5.3
112.8(d)(1) Corrosion Protection for Buried Piping Section 14.3
112.8(d)(2) Terminal Connections Section 14.7
112.8(d)(3) Pipe Supports Section 14.8
112.8(d)(4) Piping, Aboveground Valves, and Appurtenances Inspection Section 6.2.1
112.8(d)(5) Vehicle Warning Section 14.9
112.12 (b)(1) Diked Storage Area: Restrain Storm Water Section 13.2
112.12(b)(2) Facility Drainage: Design and Equipment Section 13.3
112.12(c)(1) Bulk Storage Container Construction Section 14.1
112.12(c)(10) Promptly Correct Visible Discharges Section 4.3
112.12(c)(3) Dike Drainage Section 13.2
112.12(c)(6) Inspection of Bulk Storage Containers Section 6.0, Appendix C
1-4 August 2015
1-5 August 2015
1.2 Management Approval
This Spill Prevention, Control, and Countermeasure (SPCC) Plan has the full approval of management at Naval Support Facility Beaufort (NSF Beaufort), at a level of authority to commit the necessary resources to fully implement the Plan. Management will use personnel, equipment, and materials as necessary to prevent and control spills, and to implement SPCC requirements as set forth in this Plan.
The implementation of and compliance with this SPCC plan are subject to the provisions of the Anti- Deficiency Act, as amended in 31 USC section 1341 et seq, and requisite regulations which control funding of operations and activities. Nothing in this plan is intended to make or authorize an expenditure or obligation, exceeding an amount or purpose available in a US Government appropriation or fund, for an expenditure or obligation in violation of the Anti-Deficiency Act. Further, this plan is not intended to involve the US Government in a contract or obligation for payment or any other expense, before an appropriation is adopted, unless otherwise authorized by law.
By virtue of my office, I have the authority to approve this document on behalf of the facility, and to commit resources to implement the corrective actions and improvements needed to comply with applicable federal and state laws.
Signature Date Signed
CAPT Anne Lear Commanding Officer, NSF Beaufort Name Title
§112.7 “The Plan must have the full approval of management at a level of authority to commit the necessary resources to fully implement the Plan.”
1-6 August 2015
1-7 August 2015
1.2.1 Executive Summary
Revised regulations for 40 CFR 112 were published in the Federal Register on 17 July 2002. Rules set forth by the latest amendments were published in November 2009; becoming effective 14 January 2010. The Environmental Protection Agency established these revised rules for the preparation of Spill Prevention, Control, and Countermeasure Plan and are incorporated into this plan.
Naval Facilities Engineering Command (NAVFAC) Southeast Region provided oversight and technical assistance with the preparation of this document through contract NAVFAC Southeast IDIQ Contract N69450- 14-D-0029. AMEC personnel performed inspections at the activity in December of 2014, and collected available information and data for inclusion in the SPCC Plan. This included the visual inspection of all aboveground and underground storage tanks, associated piping, and oil-filled equipment i.e., transformers.
In addition to container inspections, oil-water separators (OWS), fuel transfer operations and inspection procedures were evaluated for effectiveness and industry best management practices.
NSF Beaufort has a program for monthly visual inspections of storage containers; and if needed deficiencies are noted and programmed for correction. The facility also has an effective program for improving regulated oil containers through tank replacements and equipment upgrades to meet industry standards. The Environmental Manger ensures the facility meets federal, state, and local regulations. Facility personnel have been identified and trained for spill prevention and response, and written procedures guide personnel performing inspections and monitoring tank operations. NSF Beaufort provides manpower by the Public Works Department and Environmental Division, Operations and other organizations.
Because the activity is dynamic by nature, it is important to continue the practices of training and monthly inspections for spill prevention as equipment degrades, and personnel rotate through the facility.
NSF Beaufort is presently in substantial conformance with the rule; however, there are existing conditions that should be addressed in order to ensure compliance with 40 CFR 112.
To ensure that NSF Beaufort continues to remain in compliance with 40 CFR 112; tank deficiencies, compliance recommendations, and Best Management Practices are maintained in Appendix H of this plan.
1-8 August 2015
1-9 August 2015
1.3 Professional Engineer Certification
The undersigned licensed Professional Engineer1 attests:
In accordance with 40 Code of Federal Regulations (CFR) 112.3(d), I hereby certify that I or my agent has visited and examined the facility, and being familiar with the provisions of 40 CFR 112, Environmental Protection Agency Regulations on Oil Pollution Prevention, attest that the SPCC Plan for NSF Beaufort has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of this part, the procedures for required inspections and testing have been established, and that, with the correction of the listed deficiencies, the Plan is adequate for NSF Beaufort.
The SPCC Plan supersedes the previous NSF Beaufort Spill Prevention, Control, and Countermeasures Plan dated May 2011.
19937 Signature License Number
Robert Scott Taylor 2015-August-4 Name Date
§112.3(d) “a licensed Professional Engineer must review and certify a Plan for it to be effective to satisfy the requirements of this part”.
1-10 August 2015
1-11 August 2015
1.4 Designated Person
The Environmental Manager (EM) , LCDR Tom Nelson; Telephone (843-228-5436) is the Designated Person described in 40 CFR 112.7(f)(2) who reports to Facility Management and is accountable for discharge prevention.
1.5 Location of SPCC Plan
A complete copy of this Plan is maintained at the Environmental Management Office in Building 14, 1 Pinckney Blvd, Beaufort, SC 29902. The Environmental Management Office is generally attended 0700 to 1600, except during lunch breaks, 5 days per week (closed on Saturdays and Sundays).
1.6 SPCC Plan Review
The Designated Person identified in Section 1.4 is responsible for initiating and coordinating reviews of the SPCC Plan. The Facility Owner/Operator must complete a review and evaluation at least once every five (5) years or when changes in the Facility occur. The completed review and evaluation must be followed by a signed statement as to whether the Plan will be amended. A Professional Engineer must certify technical amendments in accordance with § 112.3(d). The record of the SPCC Plan Five-Year Reviews and Amendments is contained in Appendix E.
The Facility Owner/Operator must amend the SPCC Plan within six (6) months of the review and evaluation to include more effective field-proven prevention and control technology that will significantly reduce the likelihood of a discharge from regulated oil containers, oil transfers, or the use of regulated oil. The site must implement any amendment as soon as possible, but not later than six (6) months following the preparation of any amendment.
1.7 Amendments of SPCC Plans
1.7.1 Periodic Amendments
In accordance with §112.5(a), the Plan will be periodically reviewed and evaluated for 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.
§112.7(f)(2) “Designate a person at each applicable facility who is accountable for discharge prevention and who reports to facility management.”.
§112.3(e)(1) “Maintain a complete copy of the Plan at the facility if the facility is normally attended at least four hours per day…..”
§112.5(b) “…complete a review and evaluation of the SPCC Plan at least once every five years…..”
§112.5(a) “Amend the SPCC Plan for your facility in accordance with the general requirements in §112.7.…when there is a change in the facility design, construction, operation, or maintenance..”
1-12 August 2015
• Changes of product or service.
• Revision of standard operation, inspection, or maintenance procedures.
An amendment made under this section must be made within six (6) months, and implemented as soon as possible, but not later than six (6) months following preparation of the amendment. Amendments to the Plan made to address changes of this nature are considered technical amendments and must be certified by a Professional Engineer.
Non-technical amendments can be made by the Designated Person and must be documented in the appropriate section of the Plan. Non-technical amendments include a change in the name or contact information (such as telephone numbers) of individuals responsible for the implementation of the Plan and/or a change in the name or contact information of spill response or cleanup contractors.
The record of SPCC Plan Five-Year Reviews and Amendments are contained in Appendix E.
1.7.2 Amendment by Regional Administrator
A facility must submit their SPCC Plan with any amendments to the United States Environmental Protection Agency (USEPA) for review whenever:
• A discharge of oil into navigable waters in a single spill event occurs from an SPCC tank or other SPCC facility of more than 1,000 gallons.
• A discharge from a SPCC of oil into navigable waters in two (2) reportable spill events of 42 gallons or greater occurs within any 12-month period from an SPCC facility.
As of this date, no changes to the Plan by the Regional Administrator have been required, as neither of these stated events have occurred.
Within 60 days of the occurrence of either of these two conditions, a facility must submit the following to the USEPA Regional Administrator:
• Name of the facility.
• Name of the owner or operator of the facility.
• Location of the facility.
• Date of initial facility operation.
• Maximum storage or handling capacity of the facility and current normal daily throughput.
• Description of the facility, including maps, flow diagrams, and topographical maps.
• A complete copy of the SPCC Plan with any amendments.
• The cause of such spill, including a failure analysis of the system or subsystem in which the failure occurred.
• The corrective actions and/or countermeasures taken, including an adequate description of equipment repairs and/or replacements.
• Additional preventive measures taken or contemplated to minimize the possibility of reoccurrence.
• Such other information as the USEPA Regional Administrator may require.
When USEPA proposes to require an amendment to the SPCC Plan, the facility will be notified by certified mail or by personal delivery. The USEPA will specify the terms of such amendment.
§112.4 “Amendment of Spill Prevention, Control, and Countermeasure Plan by Regional Administrator requirements.”
1-13 August 2015
Within 30 days from receipt of the notice, the facility may submit written information, views, and arguments on the proposed amendment. After considering all material presented, USEPA will either notify the activity that an amendment is required or will rescind the notice.
Any USEPA proposed amendment becomes a part of the SPCC Plan 30 days after such notice, unless the activity appeals. The amendment should be implemented as soon as possible, but not later than six (6) months after the amendment becomes a part of the SPCC Plan.
1-14 August 2015
2-1 August 2015
SECTION 2
2. General Facility Information Facility Owner/Operator: Commanding Officer Facility Name: Naval Support Facility Beaufort Address: 1 Pinckney Blvd.
Beaufort, SC 29902 Telephone (843)-228-5600
2.1 Facility Description
NSF Beaufort opened in 1949 and is situated on 127 acres of government-owned property along the west shore of the Beaufort River within the city limits of Port Royal, SC. NSF Beaufort is situated in southeastern South Carolina, located 40 miles northeast of Savannah, GA (See Figure 2-1). The hospital is located between the Marine Corps Air Station Beaufort (MCAS Beaufort) and the Parris Island Marine Recruit Depot. The hospital provides general clinical and hospitalization services for active duty military personnel and their dependents.
Petroleum products are stored at the site for fueling the boilers at the steam plant, fueling the emergency generators for the hospital, and for government-owned and personal-owned vehicles. The products managed at NSF Beaufort are diesel, fuel oil, lubricating oil, and gasoline.
The facility diagrams, indicating the location of all ASTs, Oil-Filled Operational Equipment (OFOE), and Drum Storage Areas (DSA), are presented in Appendix B.
§112.7(a)(3) “Describe in your Plan the physical layout of the facility and include a facility diagram.”
2-2 August 2015
FIGURE 2-1
Site Vicinity Map
NSF Beaufort
2-3 August 2015
2.2 Oil Storage Containers
NSF Beaufort uses a variety of oil products for steam plant fuel, vehicle use, as well as back-up fuel for emergency electricity generation. These fuels are stored in a variety of ASTs and USTs throughout the facility (reference Appendix A and Appendix B for site and data-specific figures for USTs, ASTs, and drum storage sites). Various types of Oil-filled operational equipment (OFOE), which include pad-mounted electrical transformers and elevators, are found on NSF Beaufort. In addition, 55-gallon drums containing new and used lubrication oils are located near Building 15. Other oil storage containers or transport areas such as mobile equipment, loading areas, an OWS, fuel distribution piping, and diesel generator day tanks are found at NSF Beaufort and are also discussed in this Plan, where appropriate.
Information about the locations of ASTs, USTs, drum storage areas, OWS, and electrical transformers at the facility that meet the criteria specified in §40 CFR 112 can be found in Table 2-2.
The total oil storage capacity for the NSF Beaufort is 102,465 gallons. Oil storage capacity is summarized as follows:
Aboveground Storage
Containers (gallons)
Underground Storage
Containers (gallons)
Mobile & Portable
Containers (gallons)
Drum Storage Areas
(gallons)
OFOE
(Hydraulic
Containers) (gallons)
OFOE
(Pad-mounted Transformers
(gallons)
77,091 24,000 706 275 250 2,515
NSF Beaufort contains a variety of ancillary shop fabricated, mobile and portable containers, and OFOE, which are listed in Table 2-2. Each of these items is addressed in this Plan, in the following order:
1. High-Risk Oil Storage Facilities
2. Drum Storage Areas
3. Aboveground Storage Containers (Including Generators)
• Shop Fabricated Containers
• Generators and Day Tanks
4. Oil-Filled Operational Equipment (transformer, hydraulic containers, and elevator tanks)
5. Bulk Fuel Piping
6. Oil Water Separators
7. Mobile and Portable Containers (Mobile Tanks, Generators, and Ground Support Equipment)
8. Underground Storage Tanks
9. Other Containers (Out of Service, Permanently Closed, or Temporary Contractor Containers)
§112.7(a)(3) “You must also address in your Plan: (i) The type of oil in each fixed container and its storage capacity.”
2-4 August 2015
2.2.1 High-Risk Oil Storage Facilities
NSF Beaufort high-risk oil storage sites were established based upon review of both the volume of oil stored at each location and the frequency of transfer operations completed at that facility. The sites include:
• Steam Plant – Building 13
• Generator House – Building 1A
• Navy Exchange (NEX) Gasoline Station – Building 20
2.2.1.1 Steam Plant – Building 13
The Steam Plant is considered a high-risk facility due to the quantity, size of transfers, as well as the size and quantity of containers. Twin 25,000-gallon ASTs containing #2 fuel oil are located on the northeast side of Building 13. This facility contains a contained loading/unloading area.
Secondary containment for the tanks at Building 13 is as follows:
• Shop fabricated tanks 43 and 44 are single walled contained inside an appropriate sized concrete containment berm that encompasses part of the piping, as well. The containers receive #2 fuel oil for use within the adjacent Steam Plant. The containment area is controlled by a locked valve that is connected to an OWS and sanitary sewer.
The AST tanks (43 and 44) utilize above ground steel piping to transfer fuel from the tank area to Building 13 via two 3” transfer pipelines. Approximately ten (10) feet of pipe is not protected by containment. This uncontained section of pipe contains several fittings. The remainder of the pipeline is within the containment.
Both tanks are equipped with high level alarms. The high level alarms are tested monthly as part of the Bulk Storage Tank Routine In-Service Inspection Checklist. The checklist is located in Appendix G Facility Specific Standard Inspection Checklists.
The tanks receive fuel from commercial 8,000-gallon tank trucks. After passing a safety inspection at a security-controlled entrance of the Main Gate, the tank trucks are directed to the Steam Plant. The tank trucks are directed to the concrete unloading area where the fuel is off-loaded using flexible hoses into the tanks. The unloading area is contained in a concrete containment parking area that is sloped toward a center drain. The basin has a capacity of approximately 16,400 gallons and is secured by an isolation valve that prevents discharge. The basin is connected by a pipe to an OWS which is connected to the sanitary sewer.
For the location of the above-mentioned containers and facilities, see Figure 2-2 and Appendix B. Detailed information for the containers in this area is located in Table 2-2 and Appendix A.
The shop fabricated tanks (14-4, 14-5, and 14-6) are inspected by the DLA-E contractor and are repaired by Public Works. See Section 6.3.2 Shop Fabricated Tanks for additional information.
All shop fabricated tanks are subject to inspection provisions outlined in Table 6-1 Inspection Schedule.
The facility has multiple spill kits for handling a wide variety of discharges. The site has spill kits rated at 50 gallons or less of cleanup capability. Larger spills would require the NSF Beaufort response team to respond.
2-5 August 2015
FIGURE 2-2
Steam Plant – Building 13
Fuel Off-loading Area
OWS
AST 44
EDG13
AST 43
2-6 August 2015
2.2.1.2 Generator House – Building 1A
The Generator House Area is considered a high risk facility due to the size and quantity of containers located in this area. The Generator House is located on the east side of Saunders Road adjacent to the hospital (Building 1) and houses three (3) emergency generators for the hospital, all powered with diesel fuel; this area is completed fenced. This facility provides backup electric power to the hospital. Located at this site is a 25,000-gallon double-wall steel horizontal AST for diesel (1A-D). This site also houses two 400-gallon double-wall steel day tanks (DT1 and DT2), a 400-gal double-wall steel tank (1A-F), and a 250-gal steel AST (1A-E) within its own fenced enclosure. The entire site is normally not manned. See Figure 2-3 and Appendix B for diagrams of this area.
The tanks receive fuel from commercial 8,000-gallon tank trucks. After passing a safety inspection at a security-controlled entrance of the Main Gate, the tank trucks are directed to the Generator House. The tank trucks are parked along Saunders Road where the fuel is off-loaded using flexible hoses into Tank 1A-D.
Smaller 2,000-gallon trucks are used to refill Tank 1A-E. The remaining 400-gallon tanks are filled via underground piping from the main larger 25,000-gallon tank. These shop fabricated tanks are subject to inspection provisions outlined in Table 6-1, Inspection Schedule. In addition to the inspection provisions, this container is maintained by DLA-E. Additional information about the container is provided in Appendix A.
Additional containment measures are provided by spill kits located in the delivery vehicles (rated at 9-20 gallons). On-site spill kits are located at Building 15. The on-site spill kits are rated at 50 gallons.
2-7 August 2015
FIGURE 2-3
Generator House – Building 1A
AST 1A-E
AST 1A-D
AST 1A-F
AST DT1
AST DT2
2-8 August 2015
2.2.1.3 NEX Gasoline Station – Building 20
The NEX Gasoline Station operates 24 hours per day, 7 days per week and is located on the south side of Willis Road, approximately 600 feet from the intersection of Willis Road and Pinckney Blvd. This facility is considered high risk due to the large number of vehicle fuel (unleaded and premium unleaded) transfers at the dispensers by untrained personnel and multiple drops from trained personnel using mobile refuelers at USTs 010 and 011. See Figure 2-4 and Appendix B for diagrams of this area. Detailed information for the containers is found in Table 2-2 and Appendix A
The containers at Facility 20 are double-walled fiberglass underground storage tanks.
The automotive dispensers use automatic shutoff nozzles and are monitored by NEX personnel from 0700- 1700 to facilitate the cleanup of any spill that occurs. The dispensers remain open after hours for credit card sales only. This does pose an additional risk of spills occurring without trained personnel present to conduct cleanup operations.
Piping at the facility consists of underground double walled piping. The piping is completely buried from the USTs to the dispenser sump. The dispensers are constructed with compliant breakaway couplers and fire-rated shutoff valves.
The fuel for USTs 10 and 11 is transferred from commercial tank trucks to the tank fill ports via hoses. The transfer is conducted by an off-site contracted tank truck and is conducted by the driver of the vehicle. The operation is monitored by NEX personnel utilizing in-place SOPs that address usage of the container, spill response, security, and inventory control. A copy of the SOP is found in Appendix G. Off-load procedures should follow the procedures outlined in Section 9 Procedures for Fuel Transfer Areas.
The USTs are maintained by the Navy Exchange via off-site contractors on an as-needed basis. Active containment measures are provided by spill kits located in the delivery vehicles (rated at 9-20 gallons) and at the dispenser area which is composed of absorbent material.
2-9 August 2015
Figure 2-4
NEX Service Station – Building 20
UST 010 &
UST 011
Fuel Pumps
2-10 August 2015
2.2.2 Drum Storage Areas
NSF Beaufort has two drum storage areas (Building 15 (Motor Pool) and Building 13 (Steam Plant). Both are located within buildings away from doorways/pathways to environment or provided with adequate secondary containment. The location and container contents for the DSAs are listed in Table 2-2. The diagram located in Appendix B include the location of both sites; both Table 2-2 and Appendix B categorize the drum storage areas with the prefix of DSA.
Figure 2-5 Drum Storage Area– Building 15
2.2.3 Ancillary Aboveground Storage Containers
2.2.3.1 Field Constructed Tanks (API 650)
No field constructed tanks exist at NSF Beaufort.
2.2.3.2 Shop Fabricated Containers
NSF Beaufort has numerous shop-fabricated containers as listed in Table 2-2, Appendix A, and as located on the base diagrams located in Appendix B. These containers support a wide range of purposes including ancillary generator supply, fuel for boilers, and storing used petroleum products.
The shop fabricated ASTs are typically built to UL 142 or UL 2085 Standards. In cases where the standard of a container cannot be determined, an engineering analysis should be performed to determine compatibility for use as fuel container.
The shop fabricated containers are inspected monthly and manned during transfers from and to mobile refuelers. Shop fabricated containers used for generator support should be inspected during the operation or testing to minimize leaks under pressure.
The shop fabricated containers use several types of fuel level sensing equipment which are detailed in Section 6.4.2 Shop-Fabricated Ancillary Containers.
The shop-fabricated containers are filled by DLA-E contractors and the Public Works Department. The containers holding used oil are emptied by off-site contractors. Personnel transferring regulated oil to or
2-11 August 2015 from a shop-fabricated container are required to follow contractor established SOPs and, as a minimum, use procedures in Section 9.2 Procedures for Containers Other Than Loading and Unloading Areas.
Maintenance is provided by the Public Works Department.
2.2.4 Used Cooking Oil Containers
NSF Beaufort has no used cooking oil containers.
2.2.5 Oil-Filled Operational Equipment
2.2.5.1 Hydraulic Oil Storage Equipment Containers
NSF Beaufort utilizes two hydraulic containers for elevator operations. Both are located within Building 1.
These containers are considered OFOE. The elevators are distinguished with the prefix of ELEV and are as follows: ELEV05-P1 and ELEV06-P1. The elevator hydraulic containers are listed in Table 2-2. Data Sheets for the containers are located in Appendix A. The locations of the elevators are shown in Appendix B.
The elevator hydraulic containers are inspected by the Public Works Department on a monthly basis.
The hydraulic containers are filled by opening the top of the container and using visual methods to determine the level of fluid in the container.
Hydraulic containers that are used in the role of elevator OFOE, are filled by portable drums or cans by off-site contractors. Hydraulic fluid would be transferred by the drum attached to a dolly car with a hand pump or by small unregulated containers, depending on the amount to be transferred.
Secondary containment for all the hydraulic lifts (elevators) is provided by concrete floors which are located in the Basement of the Building 1.
2.2.5.2 Electrical Transformers
NSF Beaufort utilizes 17 pad-mounted oil-filled transformers that contain greater than 55 gallons of non-polychlorinated biphenyl (non-PCB) mineral oil. The transformers are regulated by the SPCC Rule. A list of these transformers are presented in Table 2-2 and their locations identified in Appendix B with a triangular symbol.
Transfer Operations for Electrical Transformers OFOE are not conducted on the grounds of NSF Beaufort. Any transfer of mineral oil to and from base oil-filled transformers is conducted offsite by the contractor.
A maintenance and inspection program has been developed for all transformers located on NSF Beaufort by the off-site contractor, South Carolina Electric and Gas (SCE&G), and the Public Works Department. The Public Works Department manages transformers on NSF Beaufort. Inspections of transformers are performed regularly and any leaks or spills documented with unsatisfactory conditions are promptly corrected by the off-site contractor.
2.2.6 Facility Piping
Aboveground and underground facility piping associated with the significant fuel systems is shown in the facility diagrams in Appendix B. Oil contained within this piping at NSF Beaufort is petroleum based and includes:
• #2 Fuel Oil
• Unleaded gasoline
• Diesel (vehicular and generator)
2-12 August 2015
2.2.7 Oil Water Separators (OWS)
NSF Beaufort utilizes one (1) OWS at Building 13 for draining of the containment dike (Tanks 43 and 44) and off-loading area. The physical condition and effluent of the OWS is inspected regularly by Public Works personnel and the oil is removed as necessary.
OWS are not required by 40 CFR 112 to be listed in the SPCC plan, but they are included in this plan for Navy inventory and management purposes. OWS that are used exclusively for waste water treatment, are exempt from SPCC regulations. However, if any OWS or other type of collection basin can be used for spill control purposes, then the secondary containment capacity should be listed.
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