TE 12 Spill Prevention Plan for RS outdated.pdf

Rivanna Station 2055 Boulders Road

Charlottesville, VA 22902

SPILL PREVENTION, CONTROL AND

COUNTERMEASURE PLAN

Prepared By:

AMEC Earth & Environmental, Inc.

690 Commonwealth Center 11003 Bluegrass Parkway Louisville, Kentucky 40299

(502) 267-0700

AMEC Project No. 3-2106-0196

OCTOBER 2012

Rivanna Station Spill Prevention Control and Countermeasure Plan Charlottesville, Virginia October 2012 Page i

TTABLE OF CONTENTS

SECTION PAGE NO.

1.0 APPROVAL AND CERTIFICATION

1.1 Management Approval

1.2 Professional Engineer Certification

1.3 Certification of the Applicability of the Substantial Harm Criteria

2.0 INTRODUCTION

2.1 Key Facility Personnel

2.1.1 Spill Prevention and Preparedness

2.1.2 Spill Response and Control

2.2 Material Safety Data Sheets

3.0 SPILL RESPONSE AND CONTINGENCY PLAN

3.1 Initial Spill Response Procedures

3.1.1 Incidental Spill Response Procedures

3.1.2 Major Spill Response Procedures

3.2 Additional Emergency Action

3.3 Off-Site Spills of Oil

3.4 Internal Notification of Spill

3.5 Public Notification of Spill

4.0 POST SPILL ACTIONS

4.1 Amendments

4.2 State Follow-Up

4.3 Federal Follow-Up

5.0 FACILITY DESCRIPTION AND POTENTIAL SPILL LOCATIONS

5.1 Facility Name and Address

5.2 Facility Description

5.3 General Security

5.4 Potential SPCC Spill Sources

5.4.1 Outdoor AST

5.4.2 Outdoor Emergency Generators

5.5 Facility Storage and Compatibility

5.6 General Spill Prevention Measures

6.0 TRAINING, INSPECTIONS, AND RECORDKEEPING

6.1 Training

6.2 Inspections

6.2.1 Oil Storage Site Inspections

6.2.2 Integrity Testing

6.2.3 Inspection of Secondary Containment Systems

6.2.4 Fuel Transfer Inspection

6.3 Recordkeeping

6.4 Required Documentation

7.0 ENVIRONMENTAL GUIDANCE FOR PLAN

7.1 General Applicability and Purpose

7.2 Regulatory Requirements and Applicability

7.3 Review and Amendment of the Plan

7.3.1 Periodic Review and Evaluation

October 2012 Page ii

7.3.2 USEPA Regional Administrative Review

7.4 Certification of Plan and Amendments

7.5 Civil Penalties

7.6 Spill History

TABLES

Table 1 - Installation On-Scene Coordinators Table 2 - Spill Scenarios and Required Notifications Table 3 - Emergency Telephone Numbers and Contact List Table 4 - Facility SPCC-Regulated Oil Storage Sites

APPENDICES

Appendix 1 - Figures Appendix 2 - Facility Spill Control/Emergency Equipment List Appendix 3 - Facility Spill Incident Reporting Form Appendix 4 - Record of Changes, Amendments, and Review Form Appendix 5 - Spill Plan Training Form Appendix 6 - Inspection Forms Appendix 7 - Acronyms and Definitions Appendix 8 - Cross Reference Matrix

October 2012 Page 2

1.3 Certification of the Applicability of the Substantial Harm Criteria

Facility Name: Rivanna Station Facility Address: 2055 Boulders Road Charlottesville VA 22911

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

Yes No

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

X

Yes No

3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located a distance (as calculated using the appropriate formula in Attachment C- III to this appendix or a comparable formula) such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? For further description of fish and wildlife and sensitive environments, see Appendices I, II, and III to DOC/NOAA’s “Guidance for Facility and Vessel Response plans: Fish and Wildlife and Sensitive Environments” (See Appendix E to this part, section 10, for availability) and the applicable Area Contingency Plan.

X

Yes No

4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located a distance (as calculated using the appropriate formula in Attachment C- III to this appendix or a comparable formula) such that a discharge from the facility would shut down a public drinking water intake?

X

Yes No

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

X

Yes No

X

Certification

(Attachment C-II, 40 CFR 112.20e)

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

Signature:

Date:

Name: Patrick McLaughlin

Title: Chief, Environmental and Natural Resource Division, Fort Belvoir

October 2012 Page 3

2.0 INTRODUCTION

This Spill Prevention, Control and Countermeasure Plan (SPCCP) establishes procedures, methods and equipment, and other requirements to prevent the discharge of oil and hazardous substances from the Rivanna Station. This SPCCP identifies potential spill sources, preventive measures, control and response procedures, inspection programs, and required training of personnel. The SPCCP is on-site at all times at Rivanna Station. The exact location of this Plan is known and easily accessed by facility personnel who may handle or potentially be involved in handling oil or hazardous substances.

2.1 Key Facility Personnel

2.1.1 Spill Prevention and Preparedness

The Rivanna Station Environmental Coordinator or designated individual is responsible for spill prevention and preparedness, as described in 40 CFR 112.7 (f)(2). Their primary responsibilities include:

• Keeping this SPCCP updated as changes occur;

• Ensuring current Material Safety Data Sheets are appropriately obtained and maintained;

• Ensuring copies of the SPCCP are distributed to appropriate personnel at the facility and authorized emergency response agencies who request it;

• Ensuring facility personnel designated to handle oil and/or hazardous materials, or respond to spills, have been appropriately trained and coordinating training (Section 5);

• Performing inspections; and

• Reviewing/recertifying the SPCCP once every five years.

Spill response materials, including sorbent materials, booms, pads, etc. are located in the fixed generator enclosure. An inventory of spill response materials is maintained in Appendix 2.

2.1.2 Spill Response and Control

Table 1 - Installation On-Scene Coordinators

Primary Alternate Alternate Name: Cpt. Freddie Florentz David Masterson NGIC 24/7 Emergency

Hotline

Title: Rivanna Station Division Commander Project Manager (Alutiiq) NGIC Only

Work: (434) 951-4380 (434) 951-1905 --

Cell: (571) 221-9029 -- --

24-hour:* (434) 951-4379 (434) 951-4379 (434)-980-5555

* Front Gate will contact one of the persons above.

The Rivanna Station Environmental Coordinator or designee is responsible for spill response coordination following a release. Their primary responsibilities include:

• Evacuation of and controlling access to the spill location as required;

• Notifying the appropriate local, state, and federal agencies of reportable quantity spills;

• Notifying appropriate company officials;

October 2012 Page 4

• Serving as the Installation On-Scene Coordinator (IOSC) until arrival of appropriate government agency representatives (i.e., local fire department). This includes directing any available initial response team personnel; and,

• Overseeing non-emergency clean-up activities following spill.

Spill response by Rivanna Station personnel will include measures that can be effected safely and within the scope of the requirements of 29 CFR 1910.1200, and specifically in 29 CFR

1910.1200 sections (b)(2) and (g)(2)(viii).

Appendix 1 includes a site location map and site plan to aid emergency response personnel with transportation to and within the facility.

2.2 Material Safety Data Sheets

Material Safety Data Sheets (MSDSs) are available to personnel during working hours, as required by the Occupational Safety and Health Administration (OSHA) Hazardous Communications (HAZCOM) Program. They contain critical information regarding oils and oil-based substances, including toxicity, reactivity, flammability, personal protective equipment (PPE), health and safety hazards, and emergency medical decontamination and treatment procedures.

In addition, many MSDSs include information related to spill containment and cleanup.

October 2012 Page 5

3.0 SPILL RESPONSE AND CONTINGENCY PLAN

WARNING: Personnel safety and protection of life and limb take precedence over environmental protection

. If there is a threat to personnel safety, the local fire department should be the first official agency notified. Special precautions should be exercised when handling fuels or other materials with low flash points (i.e., gasoline). Facility personnel will not respond to leaks or spills from transformers due to the safety (electrical) risks involved.

Contact the Rivanna Station Environmental Coordinator, who will notify the owning utility responsible for response actions and subsequent cleanup of a release.

Spill response by facility personnel will include measures that can be effected safely and within the scope of the requirements of OSHA’s HAZCOM Standard, 29 CFR 1910.1200, and specifically in sections (b)(2) and (g)(2)(viii). However, basic spill response guidelines are presented for consideration.

3.1 Initial Spill Response Procedures

The initial spill response procedures are as follows:

1. Evaluate the incident and/or spill scene. Identify as best as possible the facility’s ability to handle (i.e., control source and clean up release) the incident and spill internally.

2. If the incident appears to be a threat to human health, evacuate the area.

3. Contact the Rivanna Station Environmental Coordinator (Section 2.1.1) and convey the available incident information (i.e., location, substance spilled, estimated volume, status, injuries, etc.). Receive instructions from the Rivanna Station Environmental Coordinator regarding further actions.

The Rivanna Station Environmental Coordinator is responsible for further evaluation of the spill and to classify the spill as either INCIDENTAL or MAJOR. This evaluation may be performed based on the information provided by the person reporting the spill, or through a first hand evaluation if needed.

INCIDENTAL SPILL (Response actions outlined in Section 3.1.1):

• Personnel have knowledge of the spilled substance through normal day to day activities;

• The spill is less than 25 gallons;

• No immediate threat to life, human health, or the environment is believed present; and

• The spill has not flowed into an indoor or outdoor drain, navigable water, or onto adjacent property.

MAJOR SPILL (Response actions outlined in Section 3.1.2):

• The material released is immediately or potentially threatening to life, human health, or the environment;

• The spill is equal to or larger than 25 gallons;

• Involved personnel have not been trained in initial response actions for hazardous material releases; or

• Involved personnel do not handle the hazardous material(s) as part of their routine job functions.

October 2012 Page 6

3.1.1 Incidental Spill Response Procedures

Incidental spills are spills small enough to be handled using personnel and equipment routinely located in the immediate area of the release. The normal course of action following an INCIDENTAL SPILL is for appropriately trained personnel to contain and clean up the spill using available spill response equipment.

The Rivanna Station Environmental Coordinator, or personnel instructed by the Rivanna Station Environmental Coordinator, will follow these steps when responding to an incidental spill:

• Observe the spill from an upwind location, noting product type and/or appearance, source, volume, status (still leaking or not), and nearby conveyances (i.e., drains). Complete Part 2 of the Spill Incident Report Form (Appendix 3).

• Turn off or extinguish all sources of ignition (pumps, motors, heaters, cigarettes, etc.) when flammable and/or combustible substances are involved

• Review facility records (i.e., MSDSs) and manifests as necessary to identify product(s) released, health hazards, and clean up/recovery procedures.

• Stop the source of a spill

• If trained to respond, contain the spill using spill response equipment (Appendix 2) or whatever means are readily available. Stop or slow the spread of the spill using one or more of the following methods:

. If the source cannot be stopped, request additional assistance using information in Table 3.

o Build a dike around the spill using absorbent material. Only use absorbent material marked as compatible with the hazard class of the spilled material (check the materials MSDS for guidance).

o Dispose of contaminated media, residue, and cleanup materials as waste.

• Complete Parts 3 and 4, Spill Incident Report Form. Completed copies of the form will be inserted into the SPCCP and maintained on-site for at least five (5) years.

• If needed, the Rivanna Station Environmental Coordinator will notify the appropriate environmental authorities after the incident and follow up with a written report according to Section 3.4.

• The Rivanna Station Environmental Coordinator will notify the Rivanna Station-HQ EHS department within 72-hours.

October 2012 Page 7

3.1.2 Major Spill Response Procedures

Major spills are spills that CANNOT be absorbed or otherwise controlled at the time of release by personnel in the immediate release area. These include spills that pose a significant safety or health hazard, such as fire or explosion, or that may reach a water source. Table 2 identifies reporting requirements for specific spill volume and type scenarios. Table 3 includes the telephone numbers for internal and external personnel who may need to be notified of a major spill. Unless otherwise directed, the Rivanna Station Environmental Coordinator will be responsible for notifications.

Table 2 - Spill Scenarios and Required Notifications

Spill Scenario Agencies to be Notified(See Table 3) Any quantity of oil that discharged into or upon a

1. 911 navigable water (including storm water drains) in an amount that causes a visible film or sheen upon the surface of the water.

2. Virginia DEQ

3. National Response Center

1. Virginia DEQ Oil spills equal to or greater than 25 gallons.

Non-petroleum Substances (i.e. water treatment chemicals).

Refer to 40 CFR 302 (hazardous substance reportable quantity table) to identify whether a threshold has been exceeded for reporting to Virginia DEQ and the National Response Center.

Table 3 - Emergency Telephone Numbers and Contact List

Rivanna Station Staff Office 24-Hour Rivanna Station Environmental Coordinator (434) 951-1905/1799 (434) 951-4379

Cpt. Freddie Florentz (434) 951-4380 or

(571) 221-9029 (cell)

(434) 951-4379

Fort Belvoir Staff Office 24-Hour

Mr. Patrick McLaughlin, Chief of the DPW ENRD (703) 806-3193 (703) 739-4916

(703) 927-5597

Ms. Kelly Lease, Acting Compliance Branch Chief, Environmental Compliance Branch (703) 806-0020 (703) 298-8045

Mr. Ben Wallen, PG, DPW ENRD Petroleum Program and Spill Response Manager (703) 806-3694 (571) 232-5784

Outside Agencies Telephone Fire, Medical, & Police 911 Albemarle County Fire & Rescue (Asst. Chief Lagomarsino) 1 434-296-5833 Virginia DEQ Valley Region Office (normal hours) 1-540-574-7800 Virginia DEQ Statewide (24-hours) 1-800-468-8892 National Response Center 1-800-424-8802 1 EPA Region 3 Response Hotline (If NRC is not available) 1-215-814-9016

Emergency Response Contractors Telephone

October 2012 Page 8

The Rivanna Station Environmental Coordinator, or personnel instructed by the Rivanna Station Environmental Coordinator, will follow these steps when responding to a major spill (the sequence of initial response action may be altered depending upon individual spill characteristics (i.e., type of spill, quantity of spill, and/or safety hazards involved)

• Observe the spill from an upwind location. Document basic spill information (i.e., product type and/or appearance, source, volume, status (still leaking or not), and nearby conveyances (i.e., sewer inlets) using Part 2 of the Spill Incident Report Form located in Appendix 3. Answers to some questions about the cause of the spill will not be immediately known, but it is important to quickly gather as much information as possible without putting personnel in danger. Product identification number, shipping manifests, and placard information are essential for the identification of the spilled or leaked material. First responders should use DOT's Emergency Response Guidebook to help identify hazardous substances, and for guidance on initial precautionary and containment steps.

• Secure the area

• Turn off or extinguish all from non-essential employees.

sources of ignition (pumps, motors, cigarettes, etc.) when flammable and/or combustible substances are involved

• IF NEEDED, i nitiate evacuation

• Notify Fort Belvoir staff identified in Table 3, and convey information to them. Fort Belvoir staff will advise what additional actions and notifications are needed.

and notify facility personnel of the threat. Fire evacuation route maps are posted through the buildings at the facility.

• IF NEEDED, Immediately notify the local emergency response agencies by dialing 911.

• IF NEEDED, request assistance from the Emergency Response Contractor, to aid in stopping and containing the spill.

• If directed by Fort Belvoir staff, notify state, and federal regulatory agencies if the spill is reportable. The Rivanna Station Environmental Coordinator and Fort Belvoir staff will determine if the spill is a reportable spill, using spill scenarios in Table 2 as a guide.

Emergency agency telephone numbers are included in Table 3. The Rivanna Station Environmental Coordinator will convey information recorded on Part 2 of the Spill Incident Report Form (as required by 40 CFR 112), and will document notifications for future reference.

• Stop spill flow when possible without undue risk of personal injury. Attempt to stop the source of a spill only if sufficiently familiar with the substance and equipment and can provide an effective response without undue risk of personal injury.

Report to senior management upon their arrival to the scene

• Complete Parts 2, 3, and 4 of the Spill Incident Report Form (Appendix 3) to document the release. The report will identify the type of equipment and methods used in spill cleanup, the names of personnel involved, and a description of assistance received from emergency response agencies. Completed copies of the form will be inserted into the SPCCP and maintained on-site for at least five (5) years.

October 2012 Page 9

3.2 Additional Emergency Action

• In case of fire/explosion, activate the fire alarm system, telephone local fire department, and evacuate the area.

• Do not allow smoking or open flames within the potential area of the spill.

• Do not use equipment with magneto-sparked engines or equipment that produce sparks or static electricity in potential spill risk areas.

• Do not

• Place chemical soaked sorbent and soil in metal, leak-tight drums, label and dispose of properly and promptly.

use any material that would cause oil to sink or disperse in water.

For releases originating outside of the facility, Figure 2 located in Appendix 1 will be consulted to determine the potential flow direction of the spill. Outfalls through which spills could be discharged may need to be monitored. In the event additional personnel and/or services are required, the local fire department or outside contractors may be employed.

3.3 Off-Site Spills of Oil

Off-site spills will be reported following the procedure outlined in 3.1 for on-site spills of oil. If the spilled material flows past the property boundary of the facility or occurs off-site, the Rivanna Station Environmental Coordinator shall ensure that information, records, and samples adequate for legal purposes are obtained and safeguarded for future use.

3.4 Internal Notification of Spill

Facility personnel will be notified of a spill that could pose an immediate threat to their health through the facility-wide intercom system in accordance with the Rivanna Station Emergency Plan.

3.5 Public Notification of Spill

If necessary, following coordination with the Public Affairs Office at Fort Belvoir and/or Rivanna Station, an authorized representative will make appropriate statements to the media concerning an oil spill event. The extent and nature of the hazard, as well as the steps being taken to safeguard life and property will be explained to prevent or reduce widespread public alarm.

Follow-up information will be provided to interested media as it becomes available.

October 2012 Page 10

4.0 POST SPILL ACTIONS

The Rivanna Station Environmental Coordinator will submit a completed copy of the Spill Incident Report Form, included in Appendix 3, to appropriate local, state, and federal agencies as requested. Clean-up actions will be performed by Rivanna Station and/or response contractors according to the requirements of the agency with jurisdiction. Contaminated media and spill response materials shall be properly containerized and analyzed to identify applicable disposal requirements.

4.1 Amendments

After a spilled substance has been removed and the site remediated, consideration will be given to ways of preventing the reoccurrence of the spill. This may involve one or more of the following:

1. Reviewing equipment inspection records;

2. Reevaluating procedures for certain operations, (i.e., tank filling, tank inspecting, emergency response); and,

3. Investigating options such as:

i. Purchasing more spill contingency resources;

ii. Installing monitoring/ warning devices;

iii. Constructing new secondary containment devices; and,

iv. Updating storage equipment.

Any changes made related to resources or procedures, which affect the potential for a spill, shall be incorporated into this SPCCP as an amendment. These changes shall be documented on the Record of Changes, Amendments, and Reviews Form located in Appendix 4.

4.2 State Follow-Up

Immediately following a reportable quantity release of oil, Virginia DEQ shall be notified of the release. A follow-up or written report is not required, unless requested by Virginia DEQ.

4.3 Federal Follow-Up

If a 1,000-gallon single discharge event or two 42-gallon oil discharge event occurs within a 12-month period, the following information is required to be submitted to the Regional Administrator of EPA Region 4 within 60 days (40 CFR Part 112.4(a)):

1. A detailed description of the facility;

2. The reporter’s name;

3. Location of the facility;

4. Maximum storage or handling capacity of the facility and normal daily throughput;

5. Corrective action and countermeasures you have taken, including a description of equipment repairs and replacements;

6. An adequate description of the facility, including maps, flow diagrams, and topographical maps, as necessary;

7. The cause of such discharge, including a failure analysis of the system or subsystem in which the failure occurred;

8. Additional preventive measures you have taken or contemplated to minimize the possibility of recurrence;

9. Such other information as the Regional Administrator may reasonably require pertinent to the SPCCP or discharge; and

October 2012 Page 11

10. A complete copy of the SPCC Plan.

The above information will be sent to the USEPA at the address below. The shipping envelope/container label will clearly indicate that the package is to be submitted to the USEPA Region 3 official in charge of the SPCCP program. A complete copy of all information sent to USEPA will also be simultaneously sent to the Virginia DEQ, as required by 40 CFR Part 112.4 (c).

Office of the Regional Administrator U.S. EPA Region 3 1650 Arch Street

Attn: EPA Region 3 Official in Philadelphia, PA 19103

Charge of SPCC Program

Virginia DEQ Valley Region

4411 Early Road P.O. Box 3000

Harrisonburg, VA 22801

Following the receipt and review of the spill and SPCCP information at the state and federal (EPA) levels, either of these agencies may contact Rivanna Station requiring changes or amendments be made to the SPCCP.

Oil spills which result in a discharge to a U.S. navigable water may also require the submission of a written report to the U.S. EPA. If the U.S. EPA is notified of a discharge or threatened discharge of oil(s) or hazardous substance(s) into surface waters from the facility, a "Clean Water Act Section 308 Letter - Information Required for Oil Spills" notice may be sent to the facility. The required information must be submitted within a specific time frame (i.e. 20 calendar days) after receipt of the information request. A written request for an extension to the time limit for responding must be made within five (5) calendar days after receipt of the information request. Due to the level of detail contained in the information request, it is critical that all activities and persons involved in the spill and subsequent response are documented as thoroughly as possible.

October 2012 Page 12

5.0 FACILITY DESCRIPTION AND POTENTIAL SPILL LOCATIONS

5.1 Facility Name and Address

Rivanna Station 2055 Boulders Road Charlottesville, VA 22911

5.2 Facility Description

Rivanna Station is located in northern Albemarle County, Virginia, just east of US Route 29 at its intersection with Boulders Road, approximately 10 miles north of Charlottesville, Virginia.

Figure 1 in Appendix 1 shows the location of Rivanna Station (Topographic Map).

Location

Storm water inlets are located throughout the property, primarily in the parking area. The inlets associated with Building 2010 convey water to an underground drainage system which discharge into a retention pond southwest of the building. When the water level in the retention pond reaches a certain height, water is discharged from the pond south into the North Fork of the Rivanna River. The approximate surface drainage patterns and important inlet locations are identified in Figure 2.

Storm Water Drainage System

5.3 General Security

A fence exists around the entire property. Additionally, security operates 24 hours a day, 7 days a week. The aboveground oil storage containers are double-walled. Master valves and starter controls for oil transfer systems do not exist. Lighting is sufficient at all potential spill locations to identify unauthorized entrants, vandalism, spills, or activities that may create the potential for a spill.

5.4 Potential SPCC Spill Sources

The site has several significant locations with a potential source of oil spills. The following narrative describes potential oil spill sources.

5.4.1 Building 2000 ASTs (Day Tanks)

Diesel Fuel ASTs (2 @ 500 gallons)

Two (2) 500-gallon capacity ASTs (day tanks) containing diesel fuel are located inside an enclosure northwest of the northwest corner of Building 2000. The ASTs are constructed of double-walled steel, which constitutes secondary containment. The diesel fuel is used to supply emergency electrical power generators immediately to the east within the enclosure. Transfers to the ASTs occur as needed through underground piping from a 10,000 gallon underground storage tank (UST) outside (east of) the southeast corner of the enclosure.

Spills from the ASTs or UST transfer area may occur due to drips and leaks from the AST systems or transfers. The largest probable spill is anticipated to be less than one gallon, resulting from minor incidents. A larger spill from one of the ASTs would likely flow west, outside the enclosure and to a surface drainage ditch that conveys liquid south to the North Fork Rivanna River. A larger spill during transfers to the UST would flow northeast, towards a

October 2012 Page 13 storm water inlet in the pavement. The inlet is connected to underground piping that would convey liquid northwest and discharge to a surface drainage ditch north of the enclosure. This ditch would convey liquid west to another surface drainage ditch that conveys liquid south to the North Fork Rivanna River. Spills would be contained and/or removed by appropriately trained personnel using spill response equipment maintained inside Building 2000.

5.4.2 Building 2010 AST

Diesel Fuel AST (1 @ 5,000 gallons)

A 5,000-gallon AST containing diesel fuel is located outside the southeast portion of the Joint Use Intelligence Analysis Facility (JUIAF), Building 2010. The AST is constructed of double-walled steel that constitutes secondary containment. The diesel fuel is supplied to the fixed emergency electrical power generator via aboveground piping. The AST is surrounded on two

(2) sides by fencing. Access ports to the AST are locked with a key. Transfers to the AST occur as needed.

Spills from the AST system or transfer area may occur due to drips and leaks from the AST system or fuel transfer operations. The largest probable spill is anticipated to be less than one gallon, resulting from minor incidents. Large spills would flow south, over the asphalt parking lot and into a storm drain, which is connected to the storm sewer system which discharges into a retention pond southwest of the building. Spills would be contained and/or removed by appropriately trained personnel using spill response equipment located near the AST.

5.4.3 Building 2010 Emergency Generator ASTs

Diesel Fuel ASTs (2 @ 6,000 gallons)

Two (2) 6,000-gallon capacity ASTs containing diesel fuel are also located outside the southeast portion of the Joint Use Intelligence Analysis Facility (JUIAF), Building 2010. The ASTs are constructed of double-walled steel that constitutes secondary containment and are integral to the generator enclosure cabinets. The diesel fuel is supplied to the fixed emergency electrical power generators via aboveground piping which is integral to the generator cabinet. A leak sensor located in the interstitial space between each AST’s primary and secondary containment would trigger an alarm monitored by Emcor if diesel fuel enters the interstitial space.

Spills from the AST systems or transfer area may occur due to drips and leaks from the AST systems or fuel transfer operations. The largest probable spill is anticipated to be less than one gallon, resulting from minor incidents. Large spills would flow south, over the asphalt parking lot and into a storm drain, which is connected to the storm sewer system which discharges into a retention pond southwest of the building. Spills would be contained and/or removed by appropriately trained personnel using spill response equipment located near these ASTs.

5.4.4 Building 2020 Emergency Generator AST

Diesel Fuel AST (1 @ 250 gallons)

A 250-gallon capacity AST containing diesel fuel is located on the eastern portion of the property, outside the building. The AST is constructed of double-walled steel that constitutes secondary containment and is integral to the generator cabinet. The diesel fuel is supplied to the fixed emergency electrical power generator via aboveground piping which is integral to the

October 2012 Page 14 generator cabinet. The tank is equipped with leak detection located inside the generator cabinet. Access ports are located inside a panel on the generator, which is locked with a key.

Spills from the AST system or transfer area may occur due to drips and leaks from the AST system or fuel transfer operations. The largest probable spill is anticipated to be less than one gallon, resulting from minor incidents. Large spills would flow east, over the asphalt parking lot and into a storm drain, which is connected to the storm sewer system which discharges into a surface drainage ditch to the south. The ditch discharges to a retention pond further southwest, west of Building 2010. Spills would be contained and/or removed by appropriately trained personnel using spill response equipment located south of Building 2010.

5.5 Facility Storage and Compatibility

Table 4 provides a summary of the facility oil storage sites. No field-constructed aboveground containers, pipelines, partially buried tanks, portable tanks, mobile tanks, or tanks with internal heating devices, are currently used by this facility. The containers utilized for bulk fluid storage are constructed of materials compatible for the liquids they contain. Pipe supports are assumed to be properly designed and constructed to minimize abrasion and corrosion and to allow for expansion and contraction. No buried pipes are associated with the ASTs. Figure 2 in Appendix 1 show approximate locations of oil storage areas, including an underground storage tank that is regulated by 40 CFR Part 280/281.

The outdoor ASTs are considered to be well-designed, shop-manufactured containers.

Integrity testing of these ASTs is not required1 because they are not in direct contact with soil and are double-walled. Product transfer areas do not meet the definition of a loading/unloading “Rack”, since no hard piped systems are used during the transfers.

1 Well-designed shop-built containers with a shell capacity of 30,000 gallons or less are exempted through the “SPCC Settlement Issues” dated 31 March 2004 by the EPA as produced through the Oil Program Staff.

Table 4 - Facility SPCC-Regulated Oil Storage Sites

Storage Type Qty Location Product Capacity

(gallons) Container

Type/Material Secondary

Containment Equipment Failure

Rate of Flow

AST 2

Outside NW

Building 2000 Corner

Diesel Fuel 500 Steel Double-Wall <1 gpm to instantaneous

AST 1

Outside SE

Building 2010 Corner

Diesel Fuel 5,000 Steel Double-Wall <1 gpm to instantaneous

AST 2

Outside SE

Building 2010 Corner

Diesel Fuel 6,000 Steel Double-Wall <1 gpm to instantaneous

AST 1

Outside E Building

2020 Corner Diesel Fuel 250 Steel Double-Wall <1 gpm to instantaneous gpm = Gallon per minute

5.6 General Spill Prevention Measures

The following measures have been taken to reduce the potential for environmental contamination from its activities:

October 2012 Page 15

• Use of a double-walled tank for oil products stored aboveground and outdoors.

October 2012 Page 16

6.0 TRAINING, INSPECTIONS, AND RECORDKEEPING

This section provides information for required training, inspections, and recordkeeping.

6.1 Training

Specific training requirements included in 40 CFR 112.7(f) related to oil releases are described below.

Facility personnel must be properly instructed in the operation and maintenance of containers and/or equipment to prevent the discharges of oil to the environment. The Spill Prevention Coordinator is responsible for coordination of the following personnel training:

• Operating personnel - spill prevention and response briefings at least once a year;

and,

• Supervisors - spill prevention briefings at least annually (since personnel could be subject to evacuation notices) to assure understanding of the plan.

Training of facility personnel is required to ensure proper response to spills or releases. Facility personnel involved with management and handling of oil are also required to participate in Occupational Safety and Health Administration hazardous communication training.

Personnel are instructed in the use of the inspection forms and the parameters to be assessed in an on-the-job training format.

The Spill Plan Training Form, included in Appendix 5, may be used to record personnel trained, units assigned, and date of training for the annual spill prevention training, and periodic briefings. Completed copies of the forms will be kept on-site for at least five (5) years.

6.2 Inspections

Inspections are required as a component of a spill plan. Written records of the inspections are outlined in Sections 6.2.1 - 6.2.2 and documented through forms located in Appendix 2 (spill response equipment) and Appendix 6 (oil storage). These records are kept on file at the site for at least five (5) years. If the parameter inspected is in satisfactory condition, the appropriate designation is placed in the appropriate line. In addition to these recorded inspections, undocumented inspections are performed periodically in or near work areas through the natural course of performing normal duties at the facility. If a deficiency is noted, it will either be described on the appropriate line or written up and attached to the form.

6.2.1 Oil Storage Site Inspections

The Oil Storage Container Inspection Form (Form 1) included in Appendix 6, is used to document monthly visual inspections of the emergency power generator ASTs and the associated transfer areas. Aboveground containers undergoing repair, alteration, or change in service that might affect the risk of a discharge or failure due to brittle fracture or other catastrophe, will be evaluated at the time servicing is performed.

October 2012 Page 17

6.2.2 Integrity Testing

Bulk storage containers are defined in 40 CFR 122.2 (and through a telephone conversation with Mr. Pete Reich, USEPA Region 9) as

“any container used to store oil. These containers are used for purposes including, but not limited to, the storage of oil prior to use, while being used, or prior to further distribution in commerce. Oil-filled electrical, operating, or manufacturing equipment is not a bulk storage container.”

Integrity testing of these containers was initially required by 40 CFR 112.8(c)(6), which entailed a visual examination plus a non-destructive evaluation (NDE) testing technique on a regular schedule. However, on March 31, 2004, a settlement with EPA was reached on several SPCC-specific issues included in the 2002 rule, including integrity testing. The EPA generally believes that for well-designed shop-built containers with a shell capacity of 30,000 gallons or under, combining appropriate visual inspection with the measures described below would generally provide environmental protection equivalent (as allowed by 40 CFR 112.7(a)(2)) to that provided by visual inspection plus another form of testing. Included in this settlement was the following language:

“We generally believe that visual inspection plus elevation of a shop-built container in a manner that decreases corrosion potential (as compared to a container in contact with soil) and makes all sides of the container, including the bottom, visible during inspection (e.g., where the containers are mounted on structural supports, saddles, or some forms of grillage) would be considered “equivalent.” In a similar vein, we generally believe an approach that combines visual inspection with placement of a barrier between the container and the ground, designed and operated in a way that ensures that any leaks are immediately detected, to be considered “equivalent.” For example, we believe it would generally provide equivalent environmental protection to place a shop-built container on an adequately designed, maintained, and inspected synthetic liner.”

Rivanna Station is deviating from the integrity testing provision of 40 CFR 112.8(c)(6) and establishing this “equivalent environmental protection” for bulk storage containers (believed to be well-designed shop-built containers with shell capacities of less than 30,000 gallons) based on the 2004 EPA settlement guidance, which allows such after considering the tank installation, the requirements of Steel Tank Institute (STI) Standard SP-001, and alternative measures (i.e.

good engineering practices) implemented by the facility. Rivanna Station’s bulk storage containers feature double-walled construction. Under STI’s SP-001 standard, such a tank is considered a Category 1 tank (aboveground storage tank with spill control and with continuous release detection method) and therefore requires only periodic inspection. Section 3 identifies the contingency plan to be implemented during a release or threatened release.

The personnel performing these inspections are knowledgeable of storage facility operations, characteristics of the liquid stored, the type of aboveground storage tank and its associated components. Facility personnel perform periodic inspections as described in Section 6.2.1 of the Plan. The scope of inspections and procedures is covered in the training provided to employees involved in handling oil at the facility. The routine inspections focus specifically on detecting any change in conditions or evidence of product leakage from the tank, piping system, and appurtenances.

In accordance with inspection procedures outlined in this Plan, if evidence of leakage from a tank or deterioration of a tank system is observed by facility personnel, the tank is to be inspected by a tank inspector certified by the American Petroleum Institute or STI to assess its suitability for continued service, according to SP-001.

October 2012 Page 18

The tank’s physical configuration, combined with inspections identified in Section 6.2.1, ensures that any small leak that could develop in the tank inner shell will be detected before it can become significant, escape secondary containment, and reach the environment. This approach provides environmental protection equivalent to the non-destructive shell evaluation component of integrity testing required under 40 CFR 112.8(c)(6) since it provides an appropriate and effective means of assessing the condition of the tank and its suitability for continued service.

6.2.3 Inspection of Secondary Containment Systems

The double-wall secondary containment systems associated with the outdoor emergency power generator fuel tanks have been constructed to contain the volume of the primary tank. Since the systems are closed, sufficient freeboard to allow for precipitation is not necessary. The containment systems have been constructed of materials compatible with the substances the systems are designed to contain.

The containment systems are inspected simultaneously with the bulk storage systems to check to ensure they have not degraded or been damaged in a manner that would prevent the containment of a spill. The Oil Container Inspection Form (Form 1), included in Appendix 6, is used to document the condition of the containment systems.

6.2.4 Fuel Transfer Inspection

Transfers of diesel fuel to the emergency power generator tanks are performed in the presence of a Rivanna Station employee, along with an employee of the delivery company. Visual monitoring of the receiving containers (volume gauge) is performed to identify when to discontinue the transfer to prevent overfilling. No hard pipes are involved in transfers (i.e., no “Rack”), and no oil transfer or storage piping is located underground. The Oil Transfer Container Inspection Form (Form 2) is used to document these inspections.

6.3 Recordkeeping

Completed copies of the following documentation spills and related emergency response actions are maintained on-site in the Rivanna Station Environmental Coordinator’s office for at least five

(5) years:

• Spills, and related emergency response/cleanup actions;

• Local, state, or federal agency spill notifications;

• Inspection forms; and,

• Training forms.

6.4 Required Documentation

Blank forms to perform the documentation required to maintain the plan have been included in Appendices 2-6. Locally generated forms may be used as long as they contain the same information. Plan certifications have been executed in Section 1.0.

October 2012 Page 19

7.0 ENVIRONMENTAL GUIDANCE FOR PLAN

7.1 General Applicability and Purpose

This Plan fulfills the requirements for a SPCCP as required by the United States Environmental Protection Agency (USEPA) Regulation Title 40, Code of Federal Regulations, Part 112 (40 CFR 112), and describes spill detection, reporting, containment, cleanup and disposal procedures.

7.2 Regulatory Requirements and Applicability

This Plan has been prepared and implemented in accordance with 40 CFR 112, Oil Pollution Prevention, and Title 35 Virginia Statutes §§ 6021.101-6021.2104 (Virginia Storage Tank and Spill Prevention Act). This Plan also incorporates oil spill reporting requirements in accordance with 40 CFR Part 110. The procedures described in Section 3 are consistent and comply with SPCCP requirements. The SPCCP component of this Plan shall be implemented when oil is accidentally (i.e., un-permitted) released to the environment, including indoor spills having the potential to impact the environment. A copy of this Plan is located in the Rivanna Station Environmental Coordinator’s office and is available for review by the USEPA during normal business hours.

The SPCCP has been prepared and certified for this facility because the following conditions exist (40 CFR 112.1(d)):

• There is a reasonable potential for discharging oil from fixed facilities into waters of the

United States.

• The oil storage capacity on-site in containers with capacities equal to or greater than 55 gallons exceeds 1,320 gallons of total aboveground storage.

The facility is not required to prepare a Facility Response Plan (FRP) because it does not meet any of the FRP preparation thresholds as identified in 40 CFR 112.20. The underground storage tank on the property is regulated by 40 CFR 280, and is not required to be included in this plan other than noting the location on Figure 2. The facility does not have pipelines, partially buried tanks, or underground transfer piping, and therefore is not required to cap and blank flange out of service pipelines, or maintain cathodic protection or wrapping for buried materials. No piping associated with oil at the facility is in a location that could be damaged by large vehicles, so warning signs related to aboveground piping have not been installed. No tanks have internal heating coils.

7.3 Review and Amendment of the Plan

7.3.1 Periodic Review and Evaluation

The Rivanna Station Environmental Coordinator is responsible for:

• Conducting a review of the SPCCP at least once every five years (40 CFR 112.5(b));

• Updating the SPCCP whenever there is a change in facility design, construction, operation, or maintenance that affects the facility's potential for the discharge of oil or hazardous substances into or upon navigable waters or adjoining shorelines (40 CFR 112.5(a)); and,

• Monitoring any corrective actions related to the SPCCP.

October 2012 Page 20

The Plan will be amended if it is determined that:

1. Equipment or procedure changes are recommended by the above periodic review process;

2. More effective, field-proven prevention and control technology becomes available at the time of above review (40 CFR 112.5(b)); or

3. The USEPA requires revisions.

The Plan amendment must be implemented as soon as possible, but not later than six months following preparation of any amendment, unless an extension [40 CFR 112.3(f)] has been requested and granted.

Review of the Plan and any resulting amendments or changes shall be documented on the Record of Changes, Amendments and Review form in Appendix 4.

7.3.2 USEPA Regional Administrative Review

This Plan will be reviewed by an USEPA Regional Administrator if the facility discharges oil into or upon navigable waters of the United States or adjoining shorelines, or as otherwise described in 40 CFR 112.1(b), in excess of the following quantities:

• 1,000 U.S. gallons in a single spill event; or

• 42 U.S. gallons in each of two spill events within any 12-month period.

The administrator may require an amendment to bring the Plan into compliance with the regulations and to prevent and contain discharges of oil from the facility. Plan amendments will be documented using the Record of Changes, Amendments and Review form in Appendix 4.

7.4 Certification of Plan and Amendments

A professional engineer (PE) must certify the Plan and Plan Amendments (40 CFR 112.5(c).

Non-technical amendments, such as administrative type revisions and deletions to the Plan, which do not materially affect the facility’s potential for a discharge of oil, do not require PE certification.

7.5 Civil Penalties

Owners or operators of facilities subject to 40 CFR 112.3 (a), (b) or (c) who violate the requirements of this part 112 by failing or refusing to comply with any of the provisions of 112.3,

112.4 or 112.5 are liable for a civil penalty for each day such violation continues.

7.6 Spill History

The spill history for this facility is no longer required by 40 CFR 112. However the facility has not experienced spill events as defined by 40 CFR 110 (oil discharged in harmful quantities to navigable waters of the United States). Future spill events will be appropriately documented and records maintained for legal purposes.

October 2012 Appendix 1

Appendix 1 - Figures

Project Area

Legend

Rivanna Project Area µ

0 500 1,000

Feet

TOPOGRAPHIC MAP

SOURCE NOTE:

ALL BASE MAP INFORMATION

IS FROM THE FORT BELVOIR

GIS, JUNE 2004.

ALL UNDERGROUND FEATURES

ARE APPROXIMATE AND ARE

SHOWN FOR VISUALIZATION

PURPOSES ONLY.

SPILL PLAN FEATURES ARE

FROM FIELD INSPECTIONS,

JUNE-JULY 2004.

PETROLEUM MANAGEMENT

PROGRAM

FORT BELVOIR, VIRGINIA

MASTER SPILL PLAN

5,000 Gal. AST

DIESEL FUEL

(2) 6,000 Gal. ASTs

DIESEL FUEL

SURFACE DITCH

SURFACE FLOW

10,000 Gal. UST

DIESEL FUEL

500 Gal.

DIESEL FUEL

DAY TANKS

EMERGENCY

GENERATORS

250 Gal. AST

DIESEL FUEL

October 2012 Appendix 2

Appendix 2 - Facility Spill Control/Emergency Equipment List

October 2012 Appendix 2

FACILITY SPILL CONTROL/ EMERGENCY EQUIPMENT LIST

The following table includes the available spill control and emergency response equipment located on-site. The equipment is inspected and/or tested ANNUALLY (at a minimum) to ensure the equipment is available and/or operational. Additional inspections unrelated to this plan may be performed on this equipment periodically. The completed inspection form shall be forwarded to the Rivanna Station Environmental Coordinator. Faulty equipment or spent supplies will be replaced or repaired as soon as practical following completion of a spill response event or the inspection.

Building 2000 On-Hand Spill Response Kit (indoors):

Serial Noun Size Quantity Inspections Follow-up

Completed Date & Initials Actions Needed 1 Ever Soak Absorbent Rolls 8 sq ft 2 2 Absorbent Oil Socks Case 1 3 Ever Soak Absorbent Pads Box (8 sq ft) 4 4 Snake/Spill Containment 3 feet 4 5 Snake/Spill…