FINAL_NAVSTA Great Lakes SPCC Plan - August 2021.pdf

SPILL PREVENTION, CONTROL, AND

COUNTERMEASURE PLAN

NAVAL STATION GREAT LAKES

GREAT LAKES, ILLINOIS

August 2021

Prepared by:

Greenbrier Environmental Group, Inc.

Office: (304) 520-4260 Fax: (304) 520-4265

292 Oak Carriage Drive, Lewisburg WV 24901 www.greenbrierenv.com

REPORT SPILLS TO

NATIONAL RESPONSE CENTER

(800) 222-1222

Naval Station Great Lakes SPCC Plan August 2021

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TABLE OF CONTENTS

ACRONYMS AND ABBREVIATIONS ........................................................................................ iv MANAGEMENT APPROVAL ....................................................................................................... v PROFESSIONAL ENGINEER CERTIFICATION ....................................................................... .vi RECORD OF REVIEW AND AMENDMENTS ............................................................................ vii RELEASE RESPONSE / DISCHARGE NOTIFICATION FLOW CHART ................................. viii

1.0 PLAN ADMINISTRATION

1.1 Purpose

1.2 Certification of Substantial Harm Determination [40 CFR 112.209e)]

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

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

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

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

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

1.8 Management Approval [40 CFR 112.7]

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

2.0 GENERAL FACILITY INFORMATION

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

2.1.1 Location and Activities

2.1.2 Facilities That Are Not Yet Fully Operational [40 CFR 112.7]

3.0 GENERAL REQUIREMENTS FOR SPCC PLANS

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

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

3.2.1 Preventing Physical Damage to Aboveground Piping

3.3 Spill Reporting [40 CFR 112.7(a)]

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

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

3.4 Predicted Direction and Total Quantity of Oil Discharged [40 CFR 112.7(b)]

3.5 Secondary Containment to Address Typical Failure Modes [40 CFR 112.7(c)] .. 8

3.5.1 Bulk Storage Containers

3.5.2 Drum Storage Areas

3.5.3 Portable Containers

3.5.4 Mobile Refuelers and Other Non-Transportation Related Tankers

3.5.5 Oil-Filled Operational Equipment

3.5.6 Fuel Transfer Areas

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

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

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

3.8.1 Initial Training [40 CFR 112.7(f)(1)]

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

3.8.3 Underground Storage Tank Operator Training

3.9 Security [40 CFR 112.7(g)]

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

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

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

3.12.1 State Requirements

3.12.2 Consideration of Industry Standards [40 CFR 112.7(j)]

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

4.0 SPCC PLAN REQUIREMENTS FOR ONSHORE FACILITIES (EXCLUDING

PRODUCTION FACILITIES)

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

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

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

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

4.5 Secondary Containment Largest Bulk Storage Container [40 CFR 112.8(c)(2)] 19

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

4.7 Corrosion Protection for Buried Storage Tanks, Partially Buried and Bunkered

Storage Tanks [40 CFR 112.8(c)(4) and (5)]

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

………………………………………………………………………………………….20

4.8.1 Shop-Fabricated Tank Inspection Program

4.8.2 Drum and Portable Equipment Inspection Program

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

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

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

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

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

4.14 Secondary Containment for Capacity of Largest Mobile or Portable Oil Storage ..

Container Plus Freeboard [40 CFR 112.8(c)(11)]

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

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

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

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

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

4.20 Requirements for Animal Fats and Oils and Greases, and Fish and Marine

Mammal Oils; and for Vegetable Oils, including Oils from Seeds, Nuts, Fruits and Kernels [40 CFR 112.12]

5.0 FACILITY INFORMATION

5.1 Oil Container Inventory Summary

5.2 Site-Specific Information Sheets and Maps

6.0 Discharge Prevention

6.1 Discharge Prevention Measures

6.2 Discharge or Drainage Controls

6.3 Discharge Discovery Countermeasures

6.3.1 Roles and Responsibilities

6.3.2 Spill Notification

6.3.2.1 Administrative Process

6.3.2.2 Information to Report

6.3.3 Initial Spill Discovery Actions

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6.3.4 Spill Response Procedures

6.4 Spill Response Capability

6.4.1 Assistance from Federal, State, and Local Agencies

6.5 Methods of Disposal of Recovered Material

6.6 Post Discharge Review Procedures for NSGL

Tables

Table I Cross-Reference with SPCC Provisions……………………………….………….vi Table 5.1 Aboveground Storage Tanks………………………………………………………26 Table 5.2 Underground Storage Tanks ……………….…………..…………………………27 Table 5.3 Portable Containers/Drum Storage Areas……….……………………………… 27 Table 5.4.1 Oil-Filled Operational Equipment – Transformers…….…………………………28 Table 5.4.2 Oil-Filled Operational Equipment – Hydraulic Lift Elevator Reservoirs…..……35 Table 5.4.3 Oil-Filled Operational Equipment – Process Vessels……………………………36 Table 5.5 Total Facility Capacity………………………………………………………………36 Table 6.1 Emergency Contact Information…………….…………..…………………………38 Table 6.2 Officials Approved to Contact Local Emergency Response Resources………42 Table 6.3 Disposal Contact Information………………..…………..…………………………43

Figures

Figure 1 Quadrant Index Map Figure 2 Quadrant Maps

Appendices

Appendix A SPCC Deficiencies Appendix B Tank Systems Information Sheets and Maps Appendix C Drum Storage Area and Portable Container Information Sheets and Maps Appendix D Assumptions and Calculations Appendix E Standard Operating Procedures Appendix F Inspection Forms Appendix G Integrity Testing Program

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ACRONYMS AND ABBREVIATIONS

AST Aboveground Storage Tank CFH Cubic Feet Per Hour CFM Cubic Feet Per Minute CFR Code of Federal Regulations CO Commanding Officer CNIC Commander, Navy Installations Command CRDM Continuous Release Detection Method DOT Department of Transportation DSA Drum Storage Area EDO Emergency Dispatch Operator ECATTS Environmental Compliance & Assessment Training & Tracking System EPA Environmental Protection Agency EV Environmental Division FES Fire and Emergency Services FIC Facility Incident Commander FR Federal Register FRP Facility Response Plan FRT Facility Response Team GEG Greenbrier Environmental Group, Inc.

GPM Gallons Per Minute GRI Guidance for Regional Inspectors HAZMAT Hazardous Materials HPDE High Density Polyethylene IC Incident Commander IAC Illinois Administrative Code IEPD Installation Environmental Program Director MABUS Mutual Aid Alarm Box System NAVFAC Naval Facilities Engineering Systems Command NFPA National Fire Protection Association NOSC Navy On Scene Coordinator NOV Notice of Violation NRC National Response Center NSGL Naval Station Great Lakes OFOE Oil-Filled Operational Equipment O&M Operations and Maintenance OPNAV Chief of Naval Operations OSFM Office of the State Fire Marshal P.E. Professional Engineer POC Point of Contact POL Petroleum, Oil, and Lubricants PWD Public Works Department QI Qualified Individual RDC Regional Dispatch Center ROC Regional Operations Center RPB Release Prevention Barrier SDS Safety Data Sheets SFO Senior Fire Official SOP Standard Operating Procedure SPCC Spill Prevention, Control, and Countermeasure STI Steel Tank Institute U.S. United States UST Underground Storage Tank

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MANAGEMENT APPROVAL

In accordance with 40 CFR 112.7

Naval Station Great Lakes (NSGL) is committed to the prevention of discharges of oil to navigable waters and the environment, and maintains the highest standards for spill prevention, control, and countermeasures through regular review, updating, and implementation of this Spill Prevention, Control and Countermeasure (SPCC) Plan. Full approval and implementation of the SPCC Plan, as herein described, is extended by NSGL management, at a level with authority to commit the necessary resources. 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 as needed, to comply with applicable federal and state laws.

The implementation of and compliance with this SPCC plan at NSGL 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.

The NSGL Commanding Officer (CO) is the Designated Person described in §112.7(f)(2) who reports to the facility management and is accountable for discharge prevention.

Signature Date

Printed Name Title

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RECORD OF REVIEW AND AMENDMENTS

In accordance with 40 CFR 112.3(d)

All reviews and amendments to this plan will be summarized below and signed by a P.E. or Point of Contact (POC). A P.E. must certify technical amendments in accordance with § 112.3(d). Refer to Section 1.7 of this Plan for a description of the types of changes that constitute a technical amendment.

AMENDMENT

NUMBER

DATE SECTION/PAGES

AFFECTED

DESCRIPTION

OF CHANGES

PE OR

POC

NAME

PE OR POC

SIGNATURE

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RELEASE RESPONSE / DISCHARGE NOTIFICATION FLOW CHART

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TABLE I - CROSS-REFERENCE WITH SPCC PROVISIONS

In accordance with 40 CFR 112.7

40 CFR 112 Regulatory Requirement Description Location

112.3(d) Professional Engineer Certification Page vi and Section 1.4

112.3(e) Location of SPCC Plan Section 1.5

112.5(a) Amendments Page vii and Section 1.7

112.5(b) SPCC Plan Review Page vii and Section 1.6

112.7 Management Approval Page v and

Section 1.8

Cross-Reference with SPCC Rule Pages ix-x and Section 1.9

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

Section 2.1.2

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

112.7(a)(2) Environmental Equivalence Section 3.2

112.7(a)(3) Facility Information, Boundary and Facility Diagram Section 2.1, Section 5.1, Figure 1 112.7(a)(3)(i) Container Storage Capacity and Oil Type Section 5.1

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

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

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

112.7(a)(3)(v) Methods of Disposal of Recovered Material Section 6.5

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

112.7(a)(4) Discharge Notification Section 3.3.2

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

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

Section 3.4

112.7(c) Secondary Containment to Address Typical Failure Modes

Section 3.5

112.7(d) Practicability of Secondary Containment Section 3.6

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

112.7(f)(1) Oil-handling Personnel Training Section 3.8

112.7(f)(2) Designated Person Section 1.3

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

112.7(g) Security Section 3.9

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

112.7(i) Brittle Fracture Evaluation Section 3.11

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40 CFR 112 Regulatory Requirement Description Location

112.7(j) Conformance with Applicable State and Local Requirements

Section 3.12

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

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

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

Section 4.1

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

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

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

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

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

Section 4.5

112.8(c)(3) Dike Drainage Section 4.6

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 Requirements for Animal Fats and Oils and

Greases, and Fish and Marine Mammal Oils; and for Vegetable Oils, including Oils from Seeds, Nuts, Fruits and Kernels

Section 4.20

112.20(e) Certification of Substantial Harm Determination Section 1.2

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1.0 PLAN ADMINISTRATION

1.1 Purpose

The purpose of this SPCC Plan is to establish procedures, methods, equipment, and other requirements necessary to prevent the discharge of oil from Naval Station Great Lakes (NSGL) 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 liquid 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.

A SPCC Plan, in accordance with the provisions of 40 CFR 112 and Office of the Chief of Naval Operations (OPNAV) M-5090.1, is required at NSGL because it is a facility which stores, transfers, and uses oil to support its operations in quantities that exceed the 1,320 gallon applicability threshold for aboveground oil storage. This SPCC Plan is intended to prepare the owner, Commander, Navy Installations Command (CNIC), hereinafter referred to as Owner, and operator, Commanding Officer (CO) NSGL, 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 SPCC Plan. The Operator is responsible to accomplish all actions directed in this SPCC Plan.

This Plan was prepared by Greenbrier Environmental Group, Inc. (GEG) in accordance with the provisions of §112, various industry standards, including applicable fire codes, and OPNAV M- 5090.1E, Environmental Readiness Program Manual (3 Sep 2019). The ultimate responsibility for SPCC lies with the CO, NSGL. The NSGL CO relies upon his delegate, Commander Naval Facilities Engineering Systems Command (NAVFAC) Mid-Atlantic Public Works Department (PWD) NSGL to implement the program who then in turn delegates to the NAVFAC Mid-Atlantic PWD NSGL Installation Environmental Program Director (IEPD) to manage the NSGL SPCC Program.

1.2 Certification of Substantial Harm Determination [40 CFR 112.209e)]

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

NSGL has prepared a Facility Response Plan (FRP) which is kept on file in the Environmental Office.

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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 CO is the Designated Person described in §112.7(f)(2) who reports to the facility management and is accountable for discharge prevention.

See Section 6 of this Plan for additional contact information.

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

P.E. Certification is located on Page vi 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 to NSGL through the NAVFAC Mid-Atlantic PWD NSGL IEPD. In accordance with §112.3(e), a complete copy of this Plan is maintained at the Environmental Office at 310 Seabee Way, Great Lakes, Illinois hereinafter referred to as the “Environmental Office”. The Environmental Office is attended 0630 to 1500 (closed on Saturdays and Sundays). A copy of this Plan is maintained at the NSGL Fire Department.

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

§112.5(b) Notwithstanding compliance with paragraph (a) of this section, complete a review and evaluation of the SPCC Plan at least once every five years from the date your facility becomes subject to this part; or, if your facility was in operation on or before August 16, 2002, five years from the date your last review was required under this part. As a result of this review and evaluation, you must amend your SPCC Plan within six months of the review to include more effective prevention and control technology if the technology has been field-proven at the time of the review and will significantly reduce the likelihood of a discharge as described in §112.1(b) from the facility. You must implement any amendment as soon as possible, but not later than six months following preparation of any amendment. You must document your completion of the review and evaluation, and must sign a statement as to whether you will amend the Plan, either at the beginning or end of the Plan or in a log or an appendix to the Plan. The following words will suffice, “I have completed review and evaluation of the SPCC Plan for (name of facility) on (date), and will (will not) amend the Plan as a result.”

The NAVFAC Mid-Atlantic Environmental Compliance Department, in conjunction with the NAVFAC Mid-Atlantic PWD NSGL IEPD, is responsible for initiating and coordinating comprehensive reviews of the SPCC Plan at least once every five years. The NAVFAC Mid- Atlantic Environmental Compliance Department (Code EV11) will amend this Plan within six months of the review and will implement the amended Plan within six months of the amendment to include more effective prevention and control technology if such technology will significantly reduce the likelihood of a spill event and if such technology has been field proven at the time of the review. Such updates are considered technical amendments and must be certified by a P.E.

Reviews and amendments of the Plan will be documented in the Record of Reviews located on Page vii of this Plan.

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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 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 will be certified by a P.E. Non-technical amendments 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, will be recorded in the Record of Review and Amendments page of this Plan (Page vii).

Deficiencies and recommended corrective actions noted during preparation of this Plan are listed in Appendix A – SPCC Deficiencies. When deficiencies are corrected in accordance with the recommended actions in Appendix A – SPCC Deficiencies, the Deficiency List should be noted with a date and signature to document completion of the corrective action.

1.8 Management Approval [40 CFR 112.7]

Management Approval Acknowledgement is located on page v 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. A cross-reference of Plan sections relative to applicable parts of the SPCC Rule is included on pages ix-x of this plan.

Section headings identify, where appropriate, the relevant section(s) of the SPCC Rule.

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2.0 GENERAL FACILITY INFORMATION

Facility Name: Naval Station Great Lakes

Mailing Address: Building 1H

310 Seabee Way Great Lakes, Illinois 60088

Physical Location: Building 1H 310 Seabee Way Great Lakes, Illinois 60088

Owner: Commander, Navy Installations Command

Operator: Commanding Officer, Naval Station Great Lakes

Primary contact: Mr. Matthew Wollert SPCC Program Manager Public Works Department Environmental Office Building 1H, 310 Seabee Way Great Lakes, Illinois 60088 Office Phone: (847) 688-5395 x 270 Mobile Phone: (630) 715-8765 Fax: (847) 688-6910 matthew.wollert@navy.mil

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

2.1.1 Location and Activities

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

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

NSGL is located in Lake County, Illinois, north of the city of Chicago. The Facility borders Lake Michigan which is located directly east of the base. The natural environment include: lakefront beaches, rare dune ecosystems, coastal wetlands, inland ravines and hardwood forests. The NSGL is the largest training center in the Navy. The base includes approximately 1,153 buildings on 1,628 acres and uses approximately 50 miles of roadway to provide access to the Station’s facilities. The main mission of the base is the training and education of Naval enlisted personnel.

This includes facilities, housing, environmental compliance, port services, bachelor quarters and housing for the 29,000 military personnel and their families at NSGL.

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The majority of petroleum handled at NSGL is diesel fuel and unleaded gasoline for motor vehicles, diesel fuel for emergency power generation, lubricants, and used motor oils. Fuels and oils are stored in drums, generators, transformers, aboveground storage tanks (ASTs), and underground storage tanks (USTs) throughout the Facility.

Diesel-powered generators are used to supply electricity during electrical emergencies. Diesel fuel for these generators is stored in either an exterior AST near the generator or an exterior tank adjacent to or beneath the generator unit.

USTs that are fully regulated under 40 CFR 280 are included in this plan only for inventory and deficiency recording purposes. Spill release scenarios relating to transfer of oil into and out of these tanks are assessed and appropriate secondary containment measures are specified.

The Operator has determined the extent of the Facility boundary as defined in the SPCC Rule based on the ownership and operation of equipment at NSGL. The Facility consists of all the operations and land area encompassed by the security perimeter of NSGL. The vicinity location and facility boundary are depicted on Figure 1 – Quadrant Index Map.

Figure 1 – Quadrant Index Map is a NSGL facility map that provides the physical location for each SPCC-regulated asset. Site-specific information such as oil storage container details, contents, capacity, discharge prevention measures, potential release scenarios with appropriate secondary containment assessments, and discharge controls can be found in Appendix B – Tank Systems Information Sheets and Maps and Appendix C – Drum Storage Area and Portable Container Information Sheets and Maps. Spill response procedures, disposal, and contact lists can be found in Section 6.

2.1.2 Facilities That Are 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.

There are no immediate plans for additional storage containers as of the writing of this Plan and the oil storage containers and operations included in this Plan are fully operational. This Plan will be amended as new equipment or procedures are placed into service.

No additional discussion is required per §112.7.

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3.0 GENERAL REQUIREMENTS FOR SPCC PLANS

NSGL stores more than 1,320 gallons of oil products in aboveground containers, therefore meeting the applicability threshold of §112 to develop and maintain an SPCC Plan. Additionally, NSGL must meet applicable policy requirements related to oil storage and spill prevention of the U.S. Navy.

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

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, drums, mobile equipment, mobile refuelers, oil filled operational equipment, 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 Deficiency List included as Appendix A – SPCC Deficiencies.

There are no field-erected ASTs covered by this SPCC Plan; therefore, portions of the SPCC Rule specific to field-erected ASTs will not be discussed.

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

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

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

For instances where this Plan deviates from the requirements in the SPCC Rule, this section includes the reasons for nonconformance, detailed alternate methods, and an explanation of how equivalent environmental protection will be achieved. Per the SPCC Guidance for Regional Inspectors (GRI), (2013 edition) (p. 3-1), “environmental equivalence need not be a mathematical equivalence, but it must achieve the same desired outcome, though not necessarily through the same mode of operation (see 67 Federal Register (FR) 47095, July 17, 2002).”

3.2.1 Preventing Physical Damage to Aboveground Piping

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

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Reason for Nonconformance Verbal warnings are less effective than physical barriers such as fencing, barriers, or curbing in providing protection against vehicular damage.

Environmentally Equivalent Alternative The primary protection for above ground piping connected to bulk storage containers against vehicular collision is by routing piping runs away from traffic. In those cases where tank and/or pipe systems are located in areas susceptible to damage from vehicles, protective measures are in place. This approach provides superior environmental protection as compared to verbal or written warnings to drivers by physically preventing vehicular damage to piping systems. Any sites with inadequate protection are included in the Deficiency List in Appendix A – SPCC Deficiencies.

3.3 Spill Reporting [40 CFR 112.7(a)]

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

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

The contact list and phone numbers for the NSGL Fire Department, 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. Also refer to the Release Response / Discharge Notification Flow Chart on Page viii. A list of cleanup contractors that have a response agreement with NSGL is maintained by the NAVFAC Mid-Atlantic PWD NSGL IEPD.

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

§112.7(a)(4) Unless you have submitted a response plan under §112.20, provide information and procedures in your Plan to enable a person reporting a discharge as described in §112.1(b) to relate information on the exact address or location and phone number of the facility; the date and time of the discharge, the type of material discharged; estimates of the total quantity discharged; estimates of the quantity discharged as described in §112.1(b); the source of the discharge; a description of all affected media; the cause of the discharge; any damages or injuries caused by the discharge; actions being used to stop, remove, and mitigate the effects of the discharge; whether an evacuation may be needed; and, the names of individuals and/or organizations who have also been contacted.

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

Refer to Section 6, as well as to the Release Response / Discharge Notification Flow Chart on Page viii, for spill notification procedures and emergency contacts.

3.4 Predicted Direction and Total Quantity of Oil Discharged [40 CFR 112.7(b)]

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

Experience indicates a reasonable potential for equipment failure (such as loading or unloading equipment, tank overflow, rupture, or leakage, or any other equipment known to be a source of a discharge) for all bulk storage containers included in this Plan. Therefore, for each container site

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In addition, site-specific compliance summary sheets and site maps for individual tank sites included in Appendix B – Tank Systems Information Sheets and Maps depict flow direction in the event of a release.

Appendix D – Assumptions and Calculations is a list of general assumptions and calculations used to develop the numerical data presented in the data package for each individual container in Appendix B – Tank Systems Information Sheets and Maps and Appendix C – Drum Storage Area and Portable Container Information Sheets and Maps.

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

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

(1) For onshore facilities:

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

(ii) Curbing or drip pans;

(iii) Sumps and collection systems;

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

(v) Weirs, booms, or other barriers;

(vi) Spill diversion ponds;

(vii) Retention ponds; or

(viii) Sorbent materials.

Methods of secondary containment intended to comply with the provisions of §112.7(c) are included in Appendix B – Tank Systems Information Sheets and Maps and Appendix C – Drum Storage Area and Portable Container Information Sheets and Maps of this Plan.

3.5.1 Bulk Storage Containers

Methods of passive and active secondary containment intended to comply with the provisions of §112.7(c) for containers included in this Plan include a combination of structures that serve as passive containment measures (e.g., dike, spill pallet, or built-in secondary containment) and active spill response methods (e.g., drain cover, sorbent, oil-dry, or kitty litter) to prevent the most likely quantity of oil discharged during a typical failure mode from reaching navigable waters and adjoining shorelines. For each container, the active or passive methods of secondary containment, typical failure modes, and most likely quantities of oil that would be discharged during typical failure modes are included in Appendix B – Tank Systems Information Sheets and Maps. Passive secondary containment methods have been designed to contain oil to prevent the escape of oil from the containment system before cleanup occurs.

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3.5.2 Drum Storage Areas

Methods of secondary containment intended to comply with the provisions of §112.7(c) for drum storage areas (DSAs) are presented in Appendix C – Drum Storage Area and Portable Container Information Sheets and Maps. The active or passive methods of secondary containment, typical failure modes, and most likely quantities of oil that would be discharged during typical failure modes are presented on individual data sheets for each DSA.

3.5.3 Portable Containers

Methods of secondary containment intended to comply with the provisions of §112.7(c) for portable containers with an internal storage capacity of non-motive power oil greater than or equal to 55 gallons are presented in Appendix C – Drum and Portable Container Information Sheets and Maps.

3.5.4 Mobile Refuelers and Other Non-Transportation Related Tankers

Fuel delivery trucks and fuel pods which meet the definition of mobile refuelers in §112.8(c)(2) at NSGL are owned and operated by off-site contractors, which are subject to U.S. Department of Transportation (DOT) regulations. The general secondary containment requirements for fuel transfers into and out of the mobile refuelers at each individual container site are addressed in Appendix E – Standard Operating Procedures. Additionally, Appendix B – Tank Systems Information Sheets and Maps provides direction of flow and likely discharge scenarios applicable to each tank system.

3.5.5 Oil-Filled Operational Equipment

Oil-filled operational equipment (OFOE) is equipment that includes an oil storage container in which the oil is present solely to support the function of the apparatus or device. OFOE at NSGL includes electrical distribution equipment such as transformers, circuit breakers, electrical switches, hydraulic systems, lubricating systems, and elevator hydraulic reservoirs.

40 CFR 112.2 specifically excludes OFOE from the definition of bulk storage container. The effect of this distinction is that OFOE is not subject to the sized secondary containment requirements of 112.8(c)(2). However, OFOE is subject to the general secondary containment requirements of

112.7 (b) and (c) which is based on volume and flow rate of the most likely release of oil from the OFOE. 40 CFR 112.7 (c) requires that general secondary containment be provided for the most likely quantity of oil that would be released from OFOE unless the facility meets the qualification criteria and chooses to implement alternate requirements for qualified OFOE in §112.7(k)(1) in lieu of general secondary containment. Secondary containment for all OFOE at NSGL has been determined to be impracticable, therefore alternative measures, including periodic inspections, have been implemented to meet the requirements of §112.7(k)(2).

3.5.6 Fuel Transfer Areas

Spill prevention practices for fuel transfer from a tanker truck to bulk tanks maintained at NSGL adhere to the spill prevention protocols in this Section. In addition to secondary containment dikes, berms, or drainage systems, each fuel loading area and storage facility is located within an acceptable range of spill response equipment or personnel, and signs are posted indicating an emergency number to call should a release occur. NSGL spill response training, procedures, equipment and notification procedures are discussed in greater detail in the FRP.

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U.S Department of Transportation Regulations

All NSGL truck fuel loading and unloading operations meet the minimum requirements and regulations established by U.S. DOT. Tank truck unloading and loading is conducted in accordance with standard operating procedures described throughout this SPCC Plan.

If a discharge occurs outside of containment areas, other than approved rainwater discharges from secondary containment, the Fire Department will be notified and the appropriate spill control procedures will be promptly implemented.

These additional requirements apply when the transporter is loading/unloading materials with flash points below 140°F. These materials meet the U.S. DOT definition of a Class 3 flammable liquid. Combustible materials with flash points from 140 to 200°F are not subject to these requirements.

Unless the engine of the tank truck vehicle is to be used for the operation of a pump, the engine will not be running during the loading/unloading of the material, Bonding and grounding procedures for tanks trucks and containers during the transfer of material are to be implemented according to 49 CFR 177.837 (b) and (c). The current process for loading/unloading meets these requirements.

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

§112.7(d) Provided your Plan is certified by a licensed Professional Engineer under §112.3(d), or, in the case of a qualified facility that meets the criteria in §112.3(g), the relevant sections of your Plan are certified by a licensed

INDUSTRY STANDARD CONSIDERATION

Transporters who load/unload material at this facility must comply with the following requirements: All transporters of oil to and from this facility are required to meet the minimum requirements and regulation established by the U.S. DOT.

Loading/unloading procedures of hazardous materials, as defined in 49 CFR 172, at this facility are to meet the requirements of 49 CFR 177 Subpart B. Transporters who load/unload material at this facility must comply with the following requirements:

Provide a qualified person to be in attendance at all times when a tank truck is loaded/unloaded.

The attendant must be awake, have an unobstructed view of the tank truck, and be within 25 feet of the tank truck throughout the event.

The attendant must be aware of the nature of the hazardous material which is to be loaded/unloaded, trained on the procedures to be followed in emergencies, authorized to move the tank truck, and have a means to move the cargo tank.

Manholes and valves must be closed and secured during transport.

INDUSTRY STANDARD CONSIDERATION

The fuel loading operations are in general conformance with industry standards. NFPA 30 specifies that “loading and unloading facilities shall be provided with drainage systems or other means to contain spills”. The raised edge should be sloped or rounded to facilitate truck access. Concrete joints should be sealed with petroleum resistant sealants to prevent leaks to subgrade. Pavement should be sloped toward catch basins and drains that are piped to containment or treatment facilities.”

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

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

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

Secondary containment has been deemed practicable at all locations at NSGL, with the exception of OFOE. All containers with inadequate containment are included in Appendix A – SPCC Deficiencies.

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

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

Inspections and tests of each bulk storage container with a capacity 55 gallons or greater are mandated in §112.8(c)(6) and described in Section 4.8 of this Plan. The recordkeeping associated with the container inspection/testing program and inspector training is as follows:

Inspections are to be performed for each tank and conducted by the tank operator in accordance with the industry standard inspection method Steel Tank Institute (STI) – SP001 6th Edition (January 2018). Operator inspection records for all tanks greater than or equal to 55 gallons are maintained in accordance with usual and customary business practices.

All other tank and training records will be maintained by the Tank Program Manager at the Environmental Office. All shell thickness testing and certified inspection reports, including STI formal external and formal internal inspection reports, will be retained for the life of the container.

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

In accordance with §112.7(f), all oil-handling personnel receive initial SPCC training and annual Discharge Prevention Briefings. Oil-handling personnel include emergency response personnel, AST inspectors, and personnel engaged in operation and management of oil storage containers and associated equipment.