YARD SPCC Plan_Update_FINAL_2020_Final-Complete_pdf.pdf

SPILL PREVENTION, CONTROL,

AND COUNTERMEASURE PLAN

(SPCC PLAN)

UNITED STATES COAST GUARD YARD

BALTIMORE, MARYLAND

PREPARED FOR:

U.S. Coast Guard Yard 2401 Hawkins Point Road Baltimore, MD 21226-1797

PREPARED BY:

PHE-Baker JV 77 Upper Rock Circle, Suite 302

Rockville, MD 20850

Original Plan: April 2010 Last Revised: August 2020

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TABLE OF CONTENTS

Page

SPCC PLAN CERTIFICATIONS [REF. 40 CFR 112.3]

Facility Management Certification [Ref. 40 CFR 112.7] Professional Engineer Certification Statement [Ref. 40 CFR 112.3(d)] Certification of Substantial Harm Determination Form [Ref. 40 CFR 112.20] SPCC Plan Review Log Sheet SPCC Plan General Information SPCC Plan Copy [Ref. 40 CFR 112.3(e)(1)]

AMENDMENT OF THE PLAN BY REGIONAL ADMINISTRATOR [REF. 40 CFR 112.4]

Information Submittal [Ref. 40 CFR 112.4(a)] Name, Owner or Operator, and Location of the Facility [Ref. 40 CFR 112.4(a)(1-3)] Maximum Storage or Handling Capacity of the Facility [Ref. 40 CFR 112.4(a)(4)] Facility Description [Ref. 40 CFR 112.4(a)(6)] Additional Incident-Specific Information [Ref. 40 CFR 112.4(a)] State Follow-Up [Ref. 112.4(c)]

AMENDMENT OF SPCC PLANS BY OWNERS OR OPERATORS [REF. 40 CFR 112.5]

SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN [REF. 40 CFR 112.7]

General Requirements [Ref. 40 CFR 112.7] Facility Conformance [Ref. 40 CFR 112.7(a)(1-2)] Facility Layout & Diagram [Ref. 40 CFR 112.7(a)(3)]

Type of Oil in Each Container and Storage Capacity [Ref. 40 CFR 112.7(a)(3)(i)] Discharge Prevention Measures [Ref. 40 CFR 112.7(a)(3)(ii)] Discharge or Drainage Controls [Ref. 40 CFR 112.7(a)(3)(iii)] Countermeasures for Discharge Discovery, Response, & Cleanup 112.7(a)(3)(iv) Emergency Contact Lists [Ref. 40 CFR 112.7(a)(3)(vi)] & Reporting Procedures [Ref. 40 CFR 112.7(a)(4)]

Spill Direction and Flow Evaluation [Ref. 40 CFR 112.7(b)] Containment Prevention Controls [Ref. 40 CFR 112.7(c)] Demonstration of Practicability [Ref. 40 CFR 112.7(d)] Inspections and Records [Ref. 40 CFR 112.7(e)] Personnel Training and Spill Prevention Procedures [Ref. 40 CFR 112.7(f)]

Training Criteria [Ref. 40 CFR 112.7(f)(1)] Designated Responsible Personnel [Ref. 40 CFR 112.7(f)(2)] Training Frequency [Ref. 40 CFR 112.7(f)(3)]

Site Security [Ref. 40 CFR 112.7(g)] Facility Fencing [Ref. 40 CFR 112.7(g)] Non-Operation Status [Ref. 40 CFR 112.7(g)] Starter Controls [Ref. 40 CFR 112.7(g)] Loading/Unloading Connections [Ref. 40 CFR 112.7(g)] Facility Lighting [Ref. 40 CFR 112.7(g)]

Facility Tank Car and Tank Truck Loading [Ref. 40 CFR 112.7(h)] Field Constructed Aboveground Containers [Ref. 40 CFR 112.7(i)]

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Other Regulatory Discharge Prevention Requirements Conformance [Ref. 40 CFR 112.7(j)] 17 Alternate Requirements for Any Oil-Filled Operational Equipment [Ref.40 CFR 112.7(k)]

SPCC REQUIREMENTS FOR ONSHORE FACILITIES [REF 40 CFR 112.8]

Meet General 112.7 Plan Requirements and Specific 112.8 Procedures [Ref. 40 CFR 112.8(a)] Facility Drainage for Oils [Ref. 40 CFR 112.8(b)

Secondary Containment Drainage [Ref. 40 CFR 112.8(b)(1)] [Ref. 40 CFR 112.8(b)(2)] [Ref. 40 CFR 112.8(b)(3)] [Ref. 40 CFR 112.8(b)(4)&(5]

Bulk Storage Tanks [Ref. 40 CFR 112.8(c)] Application Compatibility [Ref. 40 CFR 112.8(c)(1)] Secondary Containment [Ref. 40 CFR 112.8(c)(2)] Precipitation Drainage [Ref. 40 CFR 112.8(c)(3)] Buried Metallic Storage Tanks [Ref. 40 CFR 112.8(c)(4)] Partially Buried Metallic Tanks [Ref. 40 CFR 112.8(c)(5)[ Aboveground Containers [Ref. 40 CFR 112.8(c)(6)] Internal Heating Coils [Ref. 40 CFR 112.8(c)(7)] Fail-Safe Engineering Controls [Ref. 40 CFR 112.8(c)(8)] Effluents [Ref. 40 CFR 112.8(c)(9)] Visible Leaks [Ref. 40 CFR 112.8(c)(10)] Mobile Storage Tanks & Containers [Ref. 40 CFR 112.8(c)(11)]

Facility Transfer Operations [Ref. 40 CFR 112.8(d)] Buried Piping [Ref. 40 CFR 112.8(d)(1)] Inactive Service [Ref. 40 CFR 112.8(d)(2)] Pipe Supports [Ref. 40 CFR 112.8(d)(3)] Pipeline Inspections [Ref. 40 CFR 112.8(d)(4)] Pipeline Posting [Ref. 40 CFR 112.8(d)(5)]

FACILITY RESPONSE PLAN [REF. 40 CFR 112.20]

INDEX OF TABLES

Table B-1 Spill Control Equipment List Table C-1 Environmental Emergency Contacts Table C-2 Government Agency Spill Response Emergency Telephone Numbers Table C-3 Local Contractor Emergency Telephone Number Table D-1 Oil Storage Inventory Potential Spill Evaluation -- Drum Storage Table D-2 Oil Storage Inventory Potential Spill Evaluation- Oil-Filled Operational

Equipment and Miscellaneous Items Table D-3 Oil Storage Inventory Potential Spill Evaluation - Bulk Oil Storage Containers Table G-1 Inspection Procedure Summary Table G-2 Inspection Checklist

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LIST OF APPENDICES

Appendix A: Figures Appendix B: Spill Control Equipment List Appendix C: Environmental Emergency Contacts Appendix D: Oil Storage Inventory & Potential Spill Evaluation Appendix E: Oil Spill Reporting Forms Appendix F: Tank Inspection Schedule Appendix G: Inspection Procedure and Checklists

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SPCC PLAN CERTIFICATIONS [REF. 40 CFR 112.3]

The documentation and certifications applicable to the implementation of the SPCC Plan are provided in this section and include the following:

Full approval of management at a level of authority to commit the necessary resources to implement the plan

Professional Engineer Certification for SPCC Plan

Determination of Non-Substantial Harm (Oil Pollution Prevention Act 1990)

SPCC Plan Review (5-Year Interval)

Facility Management Certification [Ref. 40 CFR 112.7] I certify that the Facility SPCC Plan has my full approval and that I, or my designated representative, have the authority to commit all the necessary resources to prepare and implement this plan.

Signature:

Date:

Name:

Title: Chief, Facilities Management Department USCG Yard, Baltimore, MD

LCDR John Adams

10/9/2020

ADAMS.JOHN.CULLEN.124844

Digitally signed by

ADAMS.JOHN.CULLEN.1248446036

Date: 2020.10.09 09:18:20 -04'00'

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Certification of Substantial Harm Determination Form [Ref. 40 CFR 112.20]

Facility Name: US Coast Guard Yard Facility Address: 2401 Hawkins Point Road, Baltimore, MD 21226

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

YES X NO

2. Does the facility have a total oil storage capacity greater than or equal to one million (1,000,000) gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage container plus freeboard to allow for precipitation?

YES NO X

3. Does the facility have a total oil storage capacity greater than or equal to one million (1,000,000) gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C-III or a comparable formula*) such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments**?

YES NO X

4. Does the facility have a total oil storage capacity greater than or equal to one million (1,000,000) gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C-III or a comparable formula*) such that a discharge from the facility would shut down a public drinking water intake?

YES NO X

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

YES NO X

* If an alternative formula is used, documentation of the reliability and analytical soundness of the alternative formula must be attached to this form.

** As defined in Appendices I, II, and III to DOC/NOAA’s “Guidance for Facility and Vessel Response Plans: Fish and wildlife and Sensitive Environments.”

Based on the completed checklist, a Facility Response Plan (as defined in 40 CFR 112.20) is required. Please refer to the Integrated Contingency Plan (ICP) for the Facility Response Plan.

CERTIFICATION

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

Signature:

Date:

Name: Derrick E. Josey

Title: Environmental Engineer

09/08/2020

Digitally signed by

JOSEY.DERRICK.E.1536290679

Date: 2020.09.08 14:01:42 -04'00'

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SPCC Plan Review Log Sheet The log sheet below must be completed every five (5) years. A copy of the log must be maintained with this Plan.

“I have completed a review and evaluation of the SPCC Plan for the Facility on (date) ___________________, and (will/will not) ___________________ amend the plan as a result.”

Signature, Title

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SPCC Plan General Information

The purpose of this Spill Prevention Control and Countermeasures (SPCC) Plan is to describe measures implemented by the Yard to prevent discharges of oil from occurring and to respond in a safe, effective, and timely manner to mitigate the impacts of any discharge. This SPCC Plan is used as a reference for oil storage information, as a tool to communicate practices on preventing and responding to discharges with personnel, as a guide to facility inspections, and as a resource during emergency response.

In accordance with the SPCC rules, 40 Code of Federal Regulations (CFR) Part 112, this facility is required to prepare and implement an SPCC Plan because it meets the following criteria:

It has an aggregate aboveground storage capacity greater than 1,320 gallons; and

There is a reasonable expectation of a discharge into or upon navigable waters of the United States (US) or adjoining shorelines.

This SPCC Plan is regulated by the US Environmental Protection Agency (USEPA) and covers onshore oil storage containers having a capacity of 55 gallons or more. It also covers onshore oil transfer activities such as refueling of vehicles, boats on trailers, and handling of new and used oil. It does not cover oil transfer activities occurring over the water, such as refueling of boats and vessels at a pier, and transfer of new and used oil to or from boats and vessels at a pier.

SPCC Plan Copy [Ref. 40 CFR 112.3(e)(1)]

A complete copy of the SPCC Plan is maintained in the US Coast Guard (USCG) Yard Environmental Management System Manual and with the Environmental Branch (Building 4). An electronic copy is available for all members/employees on the USCG Yard data network.

Additional information related to contingency planning and response activities can be found in the facility’s Integrated Contingency Plan (ICP), which also functions as its Facility Response Plan (FRP). This SPCC Plan has been prepared to meet the requirements outlined in 40 CFR 112.

AMENDMENT OF THE PLAN BY REGIONAL ADMINISTRATOR [REF. 40 CFR 112.4]

Information Submittal [Ref. 40 CFR 112.4(a)]

The owner or operator shall submit the following information within 60 days to the Regional Administrator of the USEPA (Region III at 1650 Arch Street, Philadelphia, PA 19103-2029) and to the State agency in charge of water pollution control activities (Maryland Department of the Environment [MDE]) if:

1. The facility has discharged more than 1,000 U.S. gallons of oil into or upon navigable waters or adjoining shorelines in a single spill event; or

2. The facility has discharged more than 42 U.S. gallons of oil in each of two discharges occurring within any 12-month period.

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Name, Owner or Operator, and Location of the Facility [Ref. 40 CFR 112.4(a)(1-3)]

Name: U.S. Coast Guard Yard

Owner: U.S. Coast Guard

Location: 2401 Hawkins Point Rd Baltimore, MD 21226-1797

Designated Spill Prevention and Control Coordinator: Ms. Brandace T. Timbers, Environmental Protection Specialist, Facilities Management Department.

Maximum Storage or Handling Capacity of the Facility [Ref. 40 CFR 112.4(a)(4)]

The facility has a total oil and oil-related material storage capacity of approximately 87,000 gallons in aboveground bulk material storage tanks or equipment reservoirs. The facility also typically stores approximately 28,000 gallons of oil/oil-related material in drums and totes. Due to the nature of operations at the Yard, the total volume may fluctuate as inventories of stored oil will vary, primarily with the change in inventory of 55-gallon drums present onsite.

Facility Description [Ref. 40 CFR 112.4(a)(6)]

The facility was originally built in 1899. This facility currently operates as a non-transportation-related facility with marine transfer related operations. The property is located on the north shore of Curtis Creek in Anne Arundel County, Maryland, south of Baltimore City. Additionally, the site borders Arundel Cove. The Yard is comprised of approximately 113 acres of land and is located in an area of land use that is primarily industrial.

Figures 1a and 1b show the location of the facility, and Figure 2 shows access routes to the site (Appendix A). Site plans showing the property fence line, on-site buildings, truck entrance, loading and unloading areas, secondary containment systems, and areas where oils, oil-related materials, and hazardous substances/waste are used or stored are included as Appendix A, Figure 3 through Figure 6.

Additional Incident-Specific Information [Ref. 40 CFR 112.4(a)]

A submittal required by a USEPA Regional Administrator will also include the following information, to be completed at the time of or subsequent to the incident:

Corrective actions and countermeasures taken, including description of equipment repairs and replacements [112.4(a)(5)];

The cause(s) of such discharge, including a failure analysis of the system or subsystem in which the failure occurred [112.4(a)(7)];

Additional preventive measure(s) taken or contemplated to minimize the possibility of recurrence [112.4(a)(8)]; and

Such other information as the USEPA Regional Administrator may reasonably require pertinent to the Plan or discharge [112.4(a)(9)].

the Facility [Ref. 40 CFR 112.4(a)(1-3)] rdinator: , Degrees Minutes Seconds

Latitude 39 12 0

Longitude 76 34 11

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State Follow-Up [Ref. 112.4(c)]

The report of an oil spill or discharge shall be made to the MDE immediately, but not later than 2 hours after detection of the spill. This report shall include:

Time of discharge;

Location of discharge;

Mode of transportation or type of facility involved;

Type and quantity of oil spilled;

Assistance required;

Name, address, and telephone number of persons making the report; and

All other pertinent and necessary information requested by the Department.

Based on the type and extent of the reported spill of oil or other materials, a written follow-up report may be required by the Code of Maryland Regulations, Title 26 Department of the Environment (COMAR 26.10.01.03). This report must be submitted within 10 days of the request to:

Maryland Department of the Environment Oil Control Program

1800 Washington Boulevard, Suite 620 Baltimore, Maryland 21230

The report must contain information such as that listed below:

Date, time, and place of spill;

Amount and type of oil spilled;

A complete description of circumstance contributing to the spill;

A complete description of containment, removal, and clean-up operations including disposal sites and costs of the operations;

Procedures, methods, and precautions instituted to prevent recurrence of an oil spill from the facility involved;

Any other information considered necessary or required by the MDE for a complete description of the spill incident; and

A certification that the information provided is true and correct to the knowledge of the persons signing the report.

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AMENDMENT OF SPCC PLANS BY OWNERS OR OPERATORS [REF. 40 CFR 112.5]

Owners or operators have the following obligations with respect to amending the SPCC Plan:

1. The SPCC Plan shall be amended no later than 6 months following a change in;

Facility design (Including installation or decommissioning of oil-filled equipment or containers);

Construction (including reconstruction, replacement, or installation of piping systems);

Operation or maintenance that materially affects the potential for discharge of oil; or

Changes of product or service, revisions to standard operation, modification of testing/inspection procedures, and use of new or modified industry standards or maintenance procedures.

2. The SPCC Plan shall be reviewed by the owner or operator at least once every 5 years. The owner must amend the plan to include more effective prevention and control technology if evaluation of the plan shows that:

The technology will significantly reduce the likelihood of a spill event, and

The technology has been field proven at the time of the review.

3. If a technical amendment is made to the plan, it must be certified by a Professional Engineer.

Note: The following additions or revisions to the SPCC Plan are not considered amendments to the SPCC Plan and do not require certification by a Professional Engineer:

Changes to the Storage Tank Information which do not materially affect the potential to discharge oils.

Changes to the inventory of oils, hazardous substances, and hazardous wastes.

Updates to the SPCC Plan’s contact list names and telephone numbers.

4. Completion of the SPCC Plan Review Log Sheet must be documented by the owner or operator, or a person at a management level with sufficient authority to commit the necessary resources. Documentation of the review and amendment (if necessary) is located in the SPCC Plan Certifications Section.

5. Any amendments must be implemented as soon as possible, but no later than 6 months following preparation of any amendment.

SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN [REF. 40 CFR 112.7]

General Requirements [Ref. 40 CFR 112.7]

The spill prevention control and countermeasures requirements are presented in the following sections.

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Facility Conformance [Ref. 40 CFR 112.7(a)(1-2)]

Included within this SPCC Plan is a discussion of this facility’s conformance with the requirements listed within 40 CFR 112. References to portions of 40 CFR 112 have been included to document this conformance. This facility is in complete conformance to the SPCC regulation that became effective on November 10, 2011, with the exceptions noted in Appendix H.

Facility Layout & Diagram [Ref. 40 CFR 112.7(a)(3)]

The facility layout is discussed in Section 112.4(a)(6), Facility Description. A facility diagram showing the location and contents of each container, transfer stations, connecting pipes, and sewer layout, is included in Appendix A.

Oil is stored and used at the Yard for the following activities:

Fueling of government-owned vehicles;

Fueling forklifts, cranes, and other industrial equipment;

Fueling of small boats (under 65 feet in length) by Curtis Bay Station;

Used oil generated by general ship repair activities;

Various hydraulic and lubricating oils associated with oil-filled equipment maintenance;

and

Mineral oil in electrical transformers and elevators for power distribution.

Type of Oil in Each Container and Storage Capacity [Ref. 40 CFR 112.7(a)(3)(i)]

The type of oil in each container and its storage capacity is identified in Appendix D.

Discharge Prevention Measures [Ref. 40 CFR 112.7(a)(3)(ii)]

The facility relies on a number of measures to aid in the prevention of a discharge. The type and use of each prevention measure is discussed further in the latter sections of this plan (40 CFR 112.7(e),(f),(g),(h),(i),(j), and 112.8(b) and (c)). The facility receives bulk liquid deliveries of fuel oil, diesel, and gasoline in tank trucks. Tanks may contain multiple compartments with a capacity of up to 6,000 gallons each. The Yard has established procedures that meet the Department of Transportation requirements for loading and unloading of tank trucks. Deliveries are made as needed, and there are no permanent rack structures used for the full-time loading/unloading of trucks. Additionally, in accordance with the facility’s Oil Operations Permit (2014-OPT-5018), personnel are required to measure and record in writing the liquid levels of storage tanks at this facility prior to filling in accordance with COMAR 26.10.01.12B (9).

Fueling of ships (over 65 feet in length) is performed by a licensed fuel contractor and is covered under 33 CFR 154. These fueling activities are not covered under this SPCC Plan but are included in the FRP/ICP maintained by the Yard.

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The Yard does not include any oil production facilities or conduct any onshore or offshore drilling, production, or workover activities; therefore, CFR 40 112.9, 40 CFR 112.10, and 40 CFR 112.11 are not applicable.

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

The Yard uses multiple discharge prevention measures. These measures are specified in Section 112.7(c) Containment Prevention Controls.

Countermeasures for Discharge Discovery, Response, & Cleanup 112.7(a)(3)(iv)

1. The on-site emergency response team is on call 24 hours per day and is trained to respond to spills. Specific spill response procedures used by the emergency response team are in the ICP, maintained by the Environmental Office. On-site equipment and materials, including spill kits, shovels, and absorbent materials, and their locations are described in Appendix B.

2. Cleanup contractors are utilized to handle large spills. At a minimum, contractors identified to assist in a spill response have the capabilities to provide emergency response, industrial power vacuuming, tank and pipeline cleaning, building decontamination, excavation/earthmoving, and waste transportation/disposal services.

3. In the event of an oil spill that results in, or has potential to cause, injury to persons or the environment, the actions listed below will be followed by facility personnel to the extent practicable. After appropriate emergency corrective actions are initiated, do not delay notification of the emergency contacts.

Employees

a. Extinguish or deactivate ignition sources and suspend operations as necessary.

b. Activate the extension 3000 emergency phone system (X3000 system) or call Security.

c. Notify the immediate supervisor and all potentially affected persons.

d. Isolate spill area to prevent persons from contacting liquid until Incident Commander(s) arrives.

e. Assist as appropriate in stopping the release and then containing and cleaning up the spill if appropriate.

Emergency Contacts

a. Review safety hazards and response actions with the Facilities Engineer.

b. Call the National Response Center and MDE if required. Note name of person in agency contacted, date, and time of calls. Document information on MDE Spill Report Form located in Appendix E.

d. Escort government inspectors who may visit the site.

e. Keep notes, take pictures, and record times, dates, people, and places. Document information on Oil Spill Reporting Form located in Appendix E.

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f. Determine cause(s) and initiate appropriate corrective and/or preventative actions.

g. Prepare reports to government agencies.

h. Approve outside support and expenses.

i. Supervise the clean-up and repair efforts until completion.

Methods of Disposal of Recovered Materials 112.7(a)(3)(v)

Materials recovered during a spill event will be appropriately containerized. Solids will be placed in 55-gallon drums or roll-off containers, as appropriate. Liquids will be placed in 55-gallon drums or in a tank truck using industrial power vacuuming. Recovered materials will be labeled, characterized, and disposed/recycled in accordance with applicable federal, state, and local requirements.

Emergency Contact Lists [Ref. 40 CFR 112.7(a)(3)(vi)] & Reporting Procedures [Ref. 40 CFR 112.7(a)(4)]

Response to any discovered oil release from a bulk oil storage container or piece of oil-filled equipment would follow the ICP developed by USCG for the Yard and its tenant units.

Environmental Emergency Contacts are included in Appendix C.

Notification of responding agencies must be made immediately upon knowledge of a reportable release. Efforts to control or stop the release, if practicable, or to abate an extreme hazard to employees or the general public may be conducted prior to notification.

State - All liquid releases to the environment (which includes outdoor open secondary containment systems) shall constitute a reportable release and shall be reported to the MDE (Appendix C). Formal written report to the State of Maryland shall utilize the MDE Spill Report Form attached in Appendix E.

Federal - Discharges of oil into or upon the navigable waters of the United States or adjoining shorelines in such quantities that it has been determined may be harmful, such as discharges that:

Violate applicable water quality standards;

Cause a film or sheen upon or discoloration of the surface of the water or adjoining shorelines; or

Cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines.

These discharges shall be reported to the National Response Center (Appendix C).

Spill Direction and Flow Evaluation [Ref. 40 CFR 112.7(b)]

The SPCC regulations require the plan to include a prediction of the direction, rate of flow, and total quantity of oil that could be discharged where experience indicates a reasonable potential for equipment failure.

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The Yard is located on a relatively flat parcel of land with land cover including vegetated grassy/forested areas, graveled areas, and concrete or asphalt pavements. Surface water flow is collected in various storm drains and perimeter drains before being released to Curtis Creek or Arundel Cove under the existing National Pollutant Discharge Elimination System (NPDES) permit (Permit No. MD0067300).

The experience at the Yard indicates a potential for spillage exists during bulk liquid transfers due to overfill of receiving vessels, flexible transfer line ruptures, or product mishandling.

The largest single source of a release at the site would potentially be from one of the two 10,000-gallon used oil aboveground storage tanks (ASTs) (UO01 or UO02, see Appendix A). These tanks are constructed of double-walled steel and located south of Building 62B. The three 8,000-gallon ASTs at Building 7 are interconnected via a piping manifold equipped with electronically controlled valves to supply oil to the boilers at Building 15. However, the design of the piping manifold is such that a release from one of the three ASTs will not result in the discharge of oil contained in the other two tanks. An inventory of all bulk storage containers and their contents, as well as tank construction details, are located in Appendix D.

The Yard contains five pier cranes and five additional mobile cranes stationed at Building 66 when not in use. Pier cranes 1, 3, and 5 have been converted to electric power and are not subject to the requirements of 40 CFR 112. Pier cranes 2 and 4 each have a single-walled steel tank containing approximately 500 gallons of diesel fuel for operational purposes. Pier crane 4 also has a single-walled steel tank containing approximately 400 gallons of hydraulic oil for operational purposes. Each mobile crane has both a single-walled steel tank containing approximately 100 gallons of diesel fuel and 100 gallons of hydraulic oil each. These tanks contain oil solely to support the function of the cranes and are therefore considered to be oil-filled operational equipment under 40 CFR 112.2. These tanks meet the requirements for qualified oil-filled operational equipment as listed in 40 CFR 112.7(k) as the facility:

a. Has had no single discharge as described in 40 CFR 112.1(b) from any oil-filled operational equipment exceeding 1,000 U.S. gallons; or

b. Has had no two discharges as described in 40 CFR 112.1(b) from any oil-filled operational equipment each exceeding 42 U.S. gallons within any 12-month period in the last 3 years. As secondary containment is not provided for the qualified oil-filled equipment, the Yard has developed a monitoring program to detect equipment failure and/or a discharge (Appendix F) and an ICP.

Oil spill abatement equipment is maintained in the vicinity of these cranes, as shown in Figure 3 through Figure 6 in Appendix A, due to the high potential for discharge during refueling or operation and the proximity to navigable waters.

In addition to various ASTs, oil present at the facility is contained within numerous in-service electrical transformers and switches with volumes ranging from 55 to 900 gallons. A list of each transformer and its location is located in Appendix D. The oil-filled electrical equipment located in the various substations throughout the Yard meet the criteria to be a qualified piece of oil-filled operational equipment based on the requirements set forth in 40 CFR 112.7(k). Therefore, in lieu of an engineered secondary containment measure, USCG has committed sufficient manpower, equipment, and materials to quickly identify, control, and remove a potential discharge of oil from this oil-filled equipment as outlined in this SPCC Plan and the ICP for the USCG Yard and its Tenant Units which is incorporated into this SPCC Plan by reference. The Facility Response

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Plan, included as part of the ICP, satisfies the requirements for contingency planning set forth in

40 CFR 109.5.

Manned oil transfer operations are conducted at the following locations:

Adjacent to ASTs located at Buildings 62B, 66, and 91

At the remote fill station for the ASTs located in Building 7

At the fueling station maintained by Curtis Bay Station near Building 30 and fuel station at Building 20

Adjacent to any portable bulk storage container (portable ASTs and/or 55-gallon drums)

Descriptions of the bulk load/unload locations and the tank/containment locations at this facility which present a reasonable potential for a spill are provided in Appendix D. Each container is referenced by a unique location identifier marked on the facility plans location in Appendix A.

The prediction of the direction, the rate of flow, and total material is included in the descriptions.

Containment Prevention Controls [Ref. 40 CFR 112.7(c)]

Outside Facility - A number of spill prevention measures are used to reduce the potential for oil or other materials to be released to navigable waters of the state from material storage installations located outside the facility structures. These include curbing, diking, blind sumps, sumps to the oil separation system, contained pits with grating, and absorbent booms or other absorbent materials. The Yard does not utilize automatic leak detection systems. The AST at Curtis Bay Station (Building 30), the three ASTs at Building 7, and the one AST at the Gas Station (adjacent to Building 20) are equipped with overfill alarms. When an overfill alarm sounds, the filling operation is stopped. If material is spilled during a fueling operation, the ICP will be activated.

The type and volume of containment are presented in Appendix D. Figures 3 through Figure 6 (Appendix A) present the site plan along with the location of storm drainage basins and discharge points.

Inside Facility - All interior floor drains flow to the sanitary sewer system, with the exception of Building 20 that has floor drain containment system with an 80,000-gallon capacity. Spill equipment locations are presented on Figure 3 through Figure 6 (Appendix A) and in Table B- 1.

Oils and other materials that are stored or used inside the facility in bulk tanks or containers are located such that any spillage from these sources would be contained in the following manner:

On paved areas, Within a building with concrete floors;

Sumps and collection systems Absorbent materials.

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Demonstration of Practicability [Ref. 40 CFR 112.7(d)]

The Yard has determined that use of the containment and diversionary structures and the use of readily available spill equipment to prevent discharged oil from reaching navigable water is practical and effective at this facility.

Inspections and Records [Ref. 40 CFR 112.7(e)]

The Yard conducts inspections according to the procedures listed in Appendix G (Table G-1).

The SPCC inspections are conducted by the Environmental Branch or their designee on a regular basis. Inspection sheets used to conduct these inspections are included in Appendix G. The Environmental Branch is responsible to ensure that the inspections are conducted, corrective actions taken, and documentation kept on file.

Daily inspections are conducted prior to use of any bulk storage container or fueling transfer equipment. The operator conducts an undocumented visual inspection evaluating the condition of all equipment, tank shells, connections, supports, liquid level indicators, hoses, valves, nozzles, and containment structures. Additionally, safety and security patrols are conducted every 2 hours by Yard personnel daily. Yard personnel perform undocumented visual inspections of areas where oil is used or stored. In the event that a discharge of oil is identified, the Yard spill response system is activated. Any bulk oil storage container or oil-filled equipment found to have damage or excessive wear will not be used and will be reported to the Environmental Protection Specialist for repair or disposal.

Monthly inspections are performed on all bulk oil storage containers, oil-filled equipment, fuel transfer stations, and associated piping as described in Appendix G. Monthly inspections are documented and cover the following:

Visual inspection of exterior of ASTs, portable containers, pipes, and other oil-filled equipment for signs of deterioration, leaks, corrosion, or thinning.

Visual inspection of tank foundations and supports for signs of instability or excessive settlement.

Visual inspection of secondary containment measures to ensure the area is free of debris and structurally sound, all drainage valves are locked and are tight, and adequate storage volume is available.

Visual inspection of tank fill and discharge pipes for signs of poor connection that could cause a discharge.

Visual inspection of tank vent for obstructions and proper operation.

Verifying the proper functioning of overfill prevention systems.

Checking the inventory of discharge response equipment and restocking as needed.

All problems regarding tanks, piping, containment, or response equipment must immediately be reported to Facilities Management. Visible oil leaks from tank walls, piping, or other components

8/21/2020 15 must be repaired as soon as possible to prevent a larger spill or a discharge to navigable waters or adjoining shorelines. Pooled oil is removed immediately upon discovery.

When conducted in accordance with good engineering practices, monthly visual inspections provide equivalent environmental testing as compared to other forms of non-destructive testing.

This is applicable to tanks and storage containers with a capacity of 30,000 gallons or less, which are not installed with the shell in direct contact with soil or another source of corrosion. All tanks at the Yard, both portable and stationary, are constructed with rails or permanent support structures that hold the tank off of the ground surface. Drums are kept either indoors on buildings with concrete floors or on spill pallets or weatherproof containment structures if outdoors, preventing contact with soil or other corrosive materials.

Inspection sheets are signed by the inspector and kept by the inspector. These records are maintained for a minimum of 3 years, as required by 40 CFR 112.7(e).

Personnel Training and Spill Prevention Procedures [Ref. 40 CFR 112.7(f)]

The training provided to Yard personnel regarding implementation of the SPCC Plan for this facility is described below.

Training Criteria [Ref. 40 CFR 112.7(f)(1)]

SPCC training is conducted for all employees who handle or transport oils. Electronic training records are kept in the Environmental Files and are maintained by the Environmental Branch.

At a minimum, the SPCC training includes:

Operation and maintenance of equipment to prevent the discharge of oil, Following discharge procedure protocols, General facility operations, Applicable pollution control laws, rules, and regulations, and

The contents of the Yard’s SPCC Plan.

Designated Responsible Personnel [Ref. 40 CFR 112.7(f)(2)]

Chief, Facilities Management Department, is the Designated Person who is accountable for oil spill prevention at the facility and has the authority to commit the necessary resources to implement this plan. The Chief, Facilities Management Department, reports to USCG Yard management.

The Yard Environmental Branch is the facility designee and is responsible for oil discharge prevention, control and response preparedness activities at this facility. The Yard has designated person(s) who are accountable for spill prevention and who report to Facilities Management. The designated person(s) are identified in Table C-1.

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

The Yard conducts annual discharge prevention training for oil handling personnel to ensure understanding of the SPCC Plan, known discharges or failures of equipment (if any), malfunctioning equipment components, recently developed precautionary measures, and any changes since the previous training.

The Yard incorporates the following objectives in conducting their discharge prevention briefings and employee training sessions:

To point out the employee’s responsibilities in the event of a spill including notification to Environmental Branch, personal protection, containment, clean up, and disposal.

Assist the employees in maintaining the ability to:

o Recognize the impact of environmental regulations on each employee’s job, company, and society.

o Recognize the potential consequence of spills to personal health, environment, and fire/explosion.

o Recognize the application of SPCC Plan to the duties of appropriate job classifications.

Site Security [Ref. 40 CFR 112.7(g)]

The security measures used at this facility are described below.

Facility Fencing [Ref. 40 CFR 112.7(g)]

The Yard is located within a secured fenced area with security personnel patrolling the Facility 24 hours per day, 365 days per year. The Facility has controlled access through manned security gate. Some ASTs and low-voltage transformers are also secured within their own fence and locked compounds. The Officer of the Day (OOD) and the Security Watch stander have keys to all locks. The fence is inspected by the Security Officer on a periodic basis.

Non-Operation Status [Ref. 40 CFR 112.7(g)]

Master flow and drain valves and any other valves that will permit direct outward flow of the tank’s contents to the surface are in the closed position when in non-operating or non-standby status.

Valves associated with the two 10,000-gallon ASTs (Locations UO01 and UO02) are locked when not in use. The key is kept by Pipe Shop employees in Building 62B. Additionally, the secondary containment drainage valve for the 4,000-gallon AST (Location T006) is locked to prevent unauthorized operation. The key for this lock is kept in Building 6A. Refueling activities at Building 20 and Building 30 require keyed access to operate the dispenser pumps to prevent unauthorized usage.

Starter Controls [Ref. 40 CFR 112.7(g)]

Starter controls on all oil pumps are located at a site accessible only to authorized personnel when the pumps are in a non-operating or non-standby status. The two refueling areas require keys to

8/21/2020 17 operate the pumps. All other pumps are portable and require electrical and physical connections be made before use.

Loading/Unloading Connections [Ref. 40 CFR 112.7(g)]

The loading and unloading connections are capped when not in service or in a non-stand by status. The quick connect caps release tabs can be locked together. Piping systems that convey oil or oil-based materials are drained, capped, and marked as to the piping system origin when abandoned or taken out of service for an extended period. Most tanks must use a pump to cause liquid to flow into or out of them.

Facility Lighting [Ref. 40 CFR 112.7(g)]

The facility utilizes both pole-mounted and building-mounted lights that assist in the discovery of discharges and the prevention of discharges occurring through accidentally striking an oil storage container. Additionally, flashlights are utilized as needed by security patrols and inspection personnel during hours of darkness. The lighting is maintained by facilities maintenance staff.

Facility Tank Car and Tank Truck Loading [Ref. 40 CFR 112.7(h)]

The Yard does not have a tank truck loading/unloading rack therefore, the requirements of 40 CFR 112.7(h) do not apply.

Field Constructed Aboveground Containers [Ref. 40 CFR 112.7(i)]

The Yard does not utilize field constructed aboveground storage containers for oil storage.

Other Regulatory Discharge Prevention Requirements Conformance [Ref. 40 CFR 112.7(j)]

40 CFR Parts 112.10, 112.11, & 112.12 are not applicable to this facility. The Yard is in conformance with 40 CFR Part 112.8, which is applicable to the Yard, and is discussed in following subsections. Bulk oil storage containers have secondary containment, and leak detection methods have been implemented including overflow alarms, and regular inspections.

Containment systems are compatible with the material they are designed to contain. Tank inspections are performed as outlined in Appendix G.

Bulk storage tanks at the Yard are registered with the state and all tanks are in compliance with Oil Operations Permit 2014-OPT-5018 issued by the MDE’s Oil Control Program. This permit has since expired on May 27, 2019; however, MDE has not yet issued a new permit. Therefore, the Yard continues to operate under the existing permit.

Alternate Requirements for Any Oil-Filled Operational Equipment [Ref.40 CFR 112.7(k)]

The Yard meets the qualification criteria as defined in 40 CFR 112.7(k) and elects to employ alternate requirements to secondary containment for all oil-filled operational equipment units as defined by 40 CFR 112.7(k)(2).

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SPCC REQUIREMENTS FOR ONSHORE FACILITIES [REF 40 CFR 112.8]

Meet General 112.7 Plan Requirements and Specific 112.8 Procedures [Ref. 40 CFR 112.8(a)]

This SPCC Plan meets the requirements included in 40 CFR 112.7. This section presents a discussion of conformance with the guidelines of 40 CFR 112.8. Specific sections discussed include:

Facility drainage (112.8(b));

Bulk storage containers (112.8(c)); and

Facility transfer operations and pumping (112.8(d)).

Facility Drainage for Oils [Ref. 40 CFR 112.8(b)

Overland flow of storm water at the Yard is collected by various interconnected storm drains on the property. These storm drains ultimately discharge to Curtis Creek via one NPDES-permitted outfall and multiple unregulated outfalls (see Figure 3 to Figure 6 in Appendix A).

Secondary Containment Drainage [Ref. 40 CFR 112.8(b)(1)]

All secondary containments have valves and/or plugs to prevent contaminated water and/or oil from entering the environment. Secondary containment accumulation is discharged manually.

Prior to transfer of any fluid from the containment areas, the water is inspected for the presence of oil. If detected, the oil is removed and collected for recycling. In the event of a spill from a tank, the oil should remain contained within the containment or tank double wall.

[Ref. 40 CFR 112.8(b)(2)]

The containment structures associated with the bulk oil storage containers and oil-filled electrical equipment located at the Yard are drained of accumulated precipitation via manually operated valves or sump pumps. Prior to transfer of any fluid from the containment areas, the water is inspected for the presence of oil. If detected, the oil is removed and collected for recycling.

[Ref. 40 CFR 112.8(b)(3)]

Drainage from the vehicle washing activities adjacent to Building 66 is normally directed through an oil-water separator prior to discharge to the sanitary sewer system. This drainage system has the option to discharge to the storm sewer system, but a seal over this catch basin is maintained under normal operating conditions. The oil-water separator at this location is used for the purpose of removing oil and grease from equipment prior to the discharge of rinse water to the sanitary sewer system.

Other oil-water separators are also maintained at the rinse areas adjacent to Building 5 and Building 30. These oil-water separators are installed for the purpose of removing trace amounts of oil and grease from equipment prior to the discharge of rinse water to the sanitary sewer system.

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The oil-water separators are not subject to the requirements of 40 CFR 112. Each oil-water separator is inspected monthly to ensure proper operation and to evaluate the need to remove the accumulated volume of oil and grease to ensure proper operation of the system.

[Ref. 40 CFR 112.8(b)(4)&(5]

Not applicable to this facility.

Bulk Storage Tanks [Ref. 40 CFR 112.8(c)]

Bulk tanks and containment used for the storage of oils and polluting materials and location of bulk tank installations are identified in Appendix D. Spill prevention measures developed for bulk storage tanks at this facility are provided in the “Secondary Containment” section discussed below.

Application Compatibility [Ref. 40 CFR 112.8(c)(1)]

The following information regarding bulk tank installations is presented in Appendix F:

Tank/Container type, Capacity, Containment capacity Material of construction.

The container material and construction are compatible with the respective material stored based on visual inspection and engineering knowledge of current conditions.

Secondary Containment [Ref. 40 CFR 112.8(c)(2)]

The capacity of secondary containment and imperviousness for each aboveground bulk storage tank is presented in Appendix D.

Secondary containment capacity for all ASTs or containers that do not have a double wall and are located outdoors in a location exposed to precipitation should be equal to the capacity of the largest single tank in the containment system plus sufficient freeboard to allow for precipitation.

The secondary containment structures are compatible with the materials stored in the respective containers.

Precipitation Drainage [Ref. 40 CFR 112.8(c)(3)]

Rainwater from containment basins is manually inspected for the presence of oil. If detected, the oil is removed and collected for recycling.

Buried Metallic Storage Tanks [Ref. 40 CFR 112.8(c)(4)]

There are no buried tanks at this facility.

Partially Buried Metallic Tanks [Ref. 40 CFR 112.8(c)(5)[

There are no partially buried tanks at this facility.

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Aboveground Containers [Ref. 40 CFR 112.8(c)(6)]

Aboveground containers or ASTs at this facility are identified in Appendix D. The locations of ASTs installed at this facility are provided in Appendix A (Figure 2).

On March 31, 2004, a settlement with USEPA was reached on several SPCC-specific issues included in the 2002 rule, including integrity testing. The USEPA 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).

As such, this facility has established “equivalent environmental protection” for bulk storage containers (e.g., well-designed shop-built containers with shell capacities of less than 30,000 gallons) to that required by 40 CFR 112.8(c)(6). The majority of bulk oil storage containers are located on steel stands or saddles within secondary containment systems to contain any releases, allowing all sides of the container to be visible during inspection, or are double-walled. Under the Steel Tank Institute Standard for the inspection of Aboveground Storage Tanks SP001, a tank is considered a Category 1 tank (aboveground storage tank with spill control and with continuous release detection method) and therefore requires periodic inspection only.

The personnel performing these inspections are knowledgeable of storage facility operations, characteristics of the liquid stored, the type of aboveground bulk storage containers, and its associated components. The scope of inspections and procedures is covered in the training provided to employees involved in handling oil at the facility.

The physical configuration of the majority of the facility’s bulk storage containers, combined with inspection program outlined by this plan, ensures that any small leak that could develop will be detected before it can 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 bulk storage containers and its suitability for continued service.

ASTs are normally monitored monthly for leakage by visual inspection (working liquid levels are monitored by direct visual gauges on the outside of the tank or by inspection through open tops).

Visual inspection records are maintained for 3 years.

Equipment operators who transfer portable or mobile storage containers throughout the facility conduct container inspections to identify leaks or container damage (i.e., dents, bulges, or significant rust). Secondary containment for these storage containers and devices is provided through spill pallets, double-walled containers, etc. Spill response equipment is readily available throughout the facility to contain releases from containers and/or devices. These secondary containment areas are inspected monthly and documented. Visual inspection records are maintained for 3 years.

Internal Heating Coils [Ref. 40 CFR 112.8(c)(7)]

No tanks at this facility have internal heating coils.

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Overfill Prevention [Ref. 40 CFR 112.8(c)(8)]

Tank levels are obtained by visually inspecting the level of liquid or the tank is measured, using a graduated stick or with…