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CHAPTER 2 SPILL PREVENTION AND RESPONSE

2-1 PURPOSE.

This chapter identifies DLA's responsibilities, policies, and procedures for preventing, controlling, and responding to spills of oil and hazardous substances. It provides guidelines for preparing spill prevention and response plans and manuals, and for obtaining Coast Guard "Letters of Adequacy and Certificates of Adequacy." Emergency Planning and Community Right-to-Know issues and underground storage tanks are also explained. In the context of this chapter, spill means any release of oil or hazardous substances into the air, water, or soil. Oily or hazardous substances may refer to liquids, solids, or vapors.

2-2 BACKGROUND

a. Federal agencies and others who are involved with the storage, processing, or transportation of petroleum products or other types of hazardous chemicals are required to develop and implement various plans or programs which would prevent the accidental release of a hazardous substance into the environment or properly respond to releases which may occur. The principal planning mechanisms addressed in this chapter include the following:

(1) Spill Prevention, Control, and Countermeasure (SPCC) Plan. EPA regulation 40 CFR 112, Oil Pollution Prevention, requires the development of engineering plans to prevent the release of oil into navigable waters of the United States. Within DLA, the requirement for a SPCC Plan extends to hazardous materials which could be released into the air, water, or ground. The SPCC Plan describes the specific equipment, structures, (e.g., dikes, curbs, valves) operating procedures, security measures, and maintenance that will prevent spills. In accordance with DLA policies set forth in this manual, these plans are to be developed to prevent the release of both oil and hazardous substances.

(2) Installation Spill Contingency (ISC) Plan. EPA regulation 40 CFR 300, National Oil and Hazardous Substances Contingency Plan (NCP), includes guidance and procedures for responding to releases of hazardous substances. In cooperation with this national strategy, each Federal agency must develop an ISC plan. This plan provides specific procedures that a facility will use to respond to releases of oil or hazardous substances. It designates responsible personnel and contains detailed protocols for notifying the authorities, alerting the public, mobilizing resources, protecting people and property, and cleaning up and removing harmful releases. The ISC plan is intended to address the emergency response to a release of oil or a hazardous substance. The long-term investigation and remediation of contaminated property is set forth in chapter 9, Defense Environmental Restoration Program.

(3) Emergency Planning and Community Right-to-Know Plan. The Emergency Planning and Community Right-to-Know Act was enacted as Title III of the Superfund Amendments and Reauthorization Act (SARA). The purpose of Title III is to protect the public from toxic chemical releases and to provide local citizens with information concerning potential chemical hazards present in their communities. Title III was enacted in response to the catastrophic release of toxic chemical plant vapors in 1984 at Bhopal, India. The law provides for the establishment of state emergency planning commissions and local emergency planning committees. Facilities which process or store designated amounts of hazardous materials are required under 40 CFR 355, Emergency Planning and Notification, to designate a facility emergency coordinator to work with the local planning committee and to provide various reports and inventories. The state and local planning committees must also be promptly notified in the event of a release of a reportable quantity of an extremely hazardous substance as listed in 40 CFR 355.

(4) Underground Storage Tank Program. Underground storage tanks are known to be susceptible to leaks from many causes, including installation mistakes, piping failures, spills, overfills, and corrosion which occurs when unprotected steel is buried in the ground. The EPA program to protect the public health from these kinds of releases is set forth in 40 CFR 280, Underground Storage Tanks. Requirements are established for owners and operators of underground storage tanks regarding leak detection, corrosion protection, spill and overfill protection, recordkeeping, reporting, and closure actions. New tanks must be designed to retain structural integrity for their operating life and installed and repaired using nationally recognized standards. For existing tanks, schedules are established for phasing in release detection, corrosion protection, and spill and overfill protection based on the age of the tank.

(5) Marine Pollution Control Program. Marine terminals such as some DLA Defense Fuel Support Points (DFSPs) that handle oceangoing ships must be capable of receiving oily ballast water. This requirement is established under the International Convention for the Prevention of Pollution from Ships (2 November 1973), as modified by the Protocol of 1978 (17 February 1978), and is collectively referred to as the MARPOL Protocol. A Certificate of Adequacy issued by the Coast Guard is used to verify that the terminal has adequate ballast reception facilities. The purpose of the MARPOL agreement is to prevent the need for vessels to discharge oily ballast into the ocean. The Federal regulations that apply are 33 CFR 151 and 158.

2-3 POLICY

a. Oil or other hazardous substances will not be discharged into ground or surface waters, air, soil, or in a manner which is not allowed by regulatory authorities.

b. Spill Prevention, Control, and Countermeasures Plans and Spill Contingency Plans will be developed and updated at least once every 3 years for DLA activities which could experience an accidental release of oil or hazardous substances.

c. DLA activities which are tenants on Federal or commercial facilities will cooperate with spill response planning programs of the host activity.

d. Spill Prevention Control and Countermeasures Plans prepared for DLA facilities will address potential releases of both oil and hazardous materials in accordance with the procedures and criteria set forth in this chapter.

e. Accidental releases of reportable quantities of oil or hazardous substances will be immediately reported to regulatory authorities under the National Contingency Plan (NCP) and to Emergency Planning Committees established under Emergency Planning and Community Right-To-Know Programs.

f. DLA-managed facilities will establish Emergency Planning Programs which are comparable to the extent practicable to community programs established under the Emergency Planning and Community Right-To-Know Act.

g. DLA SPCC Plans will address environmental releases which may occur during catastrophic events, such as a major warehouse fire.

h. DLA activities may enter into cooperative agreements with local fire and hazardous materials spill response agencies.

i. Underground storage tanks owned or managed by DLA will be periodically monitored for leaks.

2-4 RESPONSIBILITIES

a. Commanders of PLFAs will:

(1) Ensure that the policies and procedures in this chapter are adhered to.

(2) Implement plans for preventing, responding to, controlling and reporting spills.

(3) Respond to spills in an appropriate manner consistent with acceptable guidelines.

(4) Periodically test the effectiveness of the SPCCP and the ISCP.

(5) Ensure that appropriate personnel are properly trained.

(6) Budget sufficient funds for spill prevention and response projects.

b. The Commander, Defense Fuel Supply Center, in addition to responsibilities set forth in paragraph 2-3b above will:

(1) Use the best available technology for monitoring for leaks in bulk underground storage tanks.

(2) Provide deballast facilities at Defense Fuel Support Points serviced by oceangoing ships as provided for under the MARPOL Protocol.

2-5 PROCEDURES

a. Criteria for Spill Prevention Control and Countermeasures (SPCC) Plan. Every installation where any of the following criteria apply must prepare a SPCC plan as well as an ISC plan. The host activity is responsible for preparing and inventorying the plans. Tenant activities will cooperate with the host program and lend appropriate support.

(1) Aggregate above ground oil storage is greater than 1,320 gallons.

(2) A single aboveground oil storage tank is greater than 600 gallons.

(3) Total underground oil storage is greater than 42,000 gallons.

(4) The total quantity of any hazardous substance stored is 10 times greater than the reportable quantity or if the threshold planning quantity of any EPA-listed extremely hazardous substance is stored.A list of reportable quantities is contained in 40 CFR 302 and Appendix I of AEHA TG-136, Hazardous Waste Management. Threshold planning quantities for EPA-listed Extremely Hazardous Substances are set forth in 40 CFR 355.

b. General SPCC Guidance. General guidelines for preparing an SPCC plan are summarized below. Additional guidance is set forth in 40 CFR 112.

(1) Spill Containment

(a) The SPCC plan must identify all sites where a liquid spill of oil or hazardous substances, or release of toxic vapors or fumes could reasonably be expected to occur. The SPCC should describe the sites, the type and quantity of materials stored, the compatibility of the stored materials, and the size and type of containers. For each site, the plan should predict the expected direction of flow, or dispersion, the rate of flow, or dispersion, and the maximum quantity that could spill or be released.

(b) Appropriate secondary containment measures or diversionary structures must be discussed in detail. Containment systems should be capable of collecting and holding the entire contents of the largest single tank inside the system and have sufficient freeboard to allow for precipitation (rain or snow). Some specifics dealing with secondary containment are outlined below:

(1) Containment for multiple containers of hazardous waste must be sufficient to hold 10 percent of the volume of the hazardous waste or 100 percent of the volume of the largest container, whichever is greater. Do not allow containers to sit in spills or accumulated leaks; store drums on pallets if necessary.

(2) Permanent, self-contained buildings with impervious floors and floor/wall abutments, or with floor trenches or drains connected to a holding sump, provide adequate secondary containment for drum storage.

(3) Tank trucks and railroad tank cars do not require secondary containment unless they are used for storage, that is, unless they are immovable.

(4) When secondary containment structures are not practical for the containment of oil and hazardous substances (excluding hazardous waste), this should be clearly demonstrated within the SPCC plan, and dealt with in the spill contingency plan.

(2) Drainage

(a) Drainage from diked storage areas should be controlled by manually operated open-and-close valves or the like which are normally sealed closed. Rainwater collected within the diked areas must be inspected and any contamination must be cleaned up prior to the release of any water. A record of each release will be maintained, and any contamination will be noted in the record.

(b) Drainage from undiked areas should be intercepted, if possible, by ponds, lagoons, or coachman basins.

(3) Storage Tanks and Containers

(a) General

(1) The tank or container must be compatible with the fluid stored.

(2) To avoid spills while filling large bulk storage or hazardous waste tanks, appropriate fail safe features should be considered; these include high liquid level alarms or pump shut offs, direct communications between tank gauger and pumping station, and automatic level readouts. For smaller storage tanks filling should take place, if possible, only when the tank can accept a full truck load.

(3) Internal steam coils in POL tanks will be monitored for leakage or, where appropriate, discharged directly into a skimming device.

(b) Aboveground Tanks

(1) All tanks, appurtenances, and containment systems will be visually inspected for leaks at least once per month; tanks and containers of hazardous waste will be inspected at least once per week.

(2) Aboveground tanks will be subject to periodic integrity testing using such techniques as hydrostatic pressure testing, internal inspections, or nondestructive shell thickness testing.

(c) Underground Tanks must be tested and monitored in accordance with 40 CFR 280 and applicable state or local regulations.

(4) Bulk Pipeline Transfer Operations

(a) Buried pipelines will be wrapped and coated to reduce corrosion, and cathodic protection must be provided if soil conditions warrant. When a section of buried pipeline is exposed, it must be inspected for corrosion. Corroded areas should be scraped down to bare metal and repainted.

(b) Pipeline terminal connections will be capped or blank flanged and marked if the pipeline is not in service or is in standby service for a long period.

(c) Pipeline supports will be designed to minimize abrasion and corrosion, and will allow for expansion and contraction.

(d) All aboveground valves and pipelines will be inspected on a scheduled basis. Annual pressure testing is warranted in areas (e.g., near water) where a failure would lead to a major spill.

(e) Drivers entering the facility will be warned verbally or by posted sign of vulnerable aboveground piping.

(5) Railroad Car and Tank Truck Loading/Unloading Racks

(a) The loading/unloading rack area will have a quick drainage and containment system which will hold the maximum capacity of the largest compartment of the tank trucks or rail tank cars that operate at the facility.

(b) Warning lights, signs, or physical barriers will be provided in the loading/unloading rack area to prevent vehicles from departing before the transfer lines are disconnected.

(c) Drains and outlets on rail cars and tank trucks will be checked for leakage before and after loading/unloading operations.

(6) Inspections. All potential spill sites where oil or hazardous materials are stored or handled must be inspected frequently on a regular basis. Specific inspection procedures and schedules must be described in the SPCC plan. The inspection results must be recorded in a permanent record (e.g., bound notebook) and kept on file for at least 3 years. At hazardous waste facilities, areas subject to spills, such as loading and unloading areas, must be inspected daily in accordance with 40 CFR 264.

(7) Security

(a) Installations or individual sites that store or handle oils and hazardous substances will be secured to prevent unauthorized entry. Entrance gates must be locked or guarded when the facility is unattended. Any valves which allow the direct emptying of a tank to the environment must be locked closed when not operating. Similarly, the starter controls on all pumps should be locked in the off position or electrically disconnected when not in use.

(b) Lighting will be commensurate with the type and location of the facility. It must be sufficient to allow discovery of spills at night and to discourage vandalism.

(8) Training. Personnel will be properly instructed in the operation and maintenance of equipment to prevent discharges and in the applicable pollution control laws, rules, and regulations. Spill prevention briefings for operating personnel will be conducted at least once per quarter. A record of training will be maintained.

(9) Review and Amendment.

a. The installation will review and evaluate the SPCC plan at least once every three years and whenever there are any significant changes in facility design or operations. The amended SPCC plan must be recertified by a Licensed Professional Engineer.

b. Installation Spill Contingency (ISC) Plan. General guidelines for preparing an ISCP are presented below. Consult 40 CFR 109, 40 CFR 300 and the National Response Team's "Hazardous Materials Emergency Planning Guide" for additional guidance. Also, see AEHA Environmental Quality Information Paper No. 12, Oil and Hazardous Substance Spill Plans.

(1) Emergency Contacts. Persons and agencies to be contacted must be listed in a discrete section of the ISC plan. Examples of who should be listed are as follows: spill response team leaders and members, cleanup contractors, police and fire department, the Coast Guard, the Chemical Transportation Emergency Center (800-424-9300), the USAEHA Hazardous Substance Spill Response Team DSN 584-3554/2024/4375), the National Response Center (800-424-8802), the local Emergency Response Committee, and the State Emergency Response Commission. In addition, most states have a 24-hour emergency response telephone line.

(2) Initial Response Action. Describe the actions that should be taken when a release is first discovered. The person who discovers a release should stop the flow if possible, report the release through his immediate supervisor to the installation on-scene coordinator, and contain the release using whatever means are available. At sites where untrained individuals may discover a spill, a placard will be posted to indicate the spill emergency telephone number and the spill response action. Leaks and minor spills which are contained and cleaned up by the first person on the scene or by the suppler should be reported so that appropriate action can be taken to correct the deficiency or malfunction which caused the discharge.

(3) Installation Spill Response Team

(a) Installation on-scene coordinator. The ISC plan will designate an installation on-scene commander. This individual is responsible for coordinating the activities of the installation response team during the containment, control, and cleanup of a spill. The on-scene coordinator determines whether a spill is reportable and ensures that the appropriate state and Federal authorities are advised. The installation on-scene coordinator is the prime point of contact in the event of a spill.

(b) Installation Response Team (IRT). The Installation Spill Contingency Plan will specify the composition of the IRT, identifying individuals wherever possible. The installation on-scene coordinator is in charge of the IRT. The Installation Spill Contingency Plan should identify a preplanned location for an installation response operations center and provide for access to a reliable communications system for directing the coordinated overall response actions. Key elements of an effective IRT include:

(1) Facility Engineering
(2) Fire Department
(3) Security
(4) Environmental Office
(5) Safety Office
(6) Health Clinic
(7) Public Affairs Office

(4) Resources. Identify the quantities and locations of manpower, equipment, and materials that are available on the installation to contain and clean up a spill. Indicate also the availability of resources from nearby DoD installations and private cleanup contractors and any arrangements made with local sources for mutual assistance.

(5) Reporting Procedures

(a) The installation on-scene coordinator will determine whether the release should be reported to appropriate Federal, state, or local authorities. Reportable releases must be reported immediately, by telephone, to the National Response Center (NRC). Releases that could affect persons outside the installation must be reported by telephone to the local Emergency Planning Committee and the State Emergency Planning Commission.

(b) A subsequent written report must be submitted to the local committee and state commission, but not to the NRC, as soon as practicable after the telephone report. In addition, notify the DLA Environmental Office (DLA-W) of any reportable spills by submitting DLA Form 1685, Oil and Hazardous Substance Spill Report.

(c) A subsequent written report must be submitted to the EPA Regional Administrator under the following circumstances:

(1) Within 60 days after a single large oil discharge (1,000 gallons or more). In addition, if two smaller reportable oil spills (less than 1,000 gallons each) occur within a 12-month period, a report must be filed within 60 days after the second spill.
(2) Within 15 days after a reportable discharge of a hazardous waste from a hazardous waste treatment, storage or disposal facility (40 CFR 26.4). For other reportable hazardous substance spills, the EPA will determine the need for a written incident report on a case-by-case basis.

(d) The reportable quantity for oil on surface water is a "visible sheen." Reportable quantities of CERCLA hazardous substances are listed in 40 CFR 302. Reportable quantities for SARA Title III extremely hazardous substances are listed in 40 CFR 355. If in doubt, report.

(6) Spill Response Procedures. This section outlines response procedures for each type of spill, i.e., aboveground oil spill, underground oil leak, PCB transformer leak, pesticide spill, etc. Although the actual response will vary on the location and the magnitude of the spill, the method of response should be the same. The type of information to be provided should include special precautions (for example, no smoking or open flames), protective equipment to be worn or used, and instructions on how to contain and cleanup spills and dispose of wastes.

(7) Training. The IRT members and other appropriate personnel will receive spill response training that includes practical exercises under professional direction. Because of quantities of hazardous materials in storage, IRT members at DDOU, DDMT, and DGSC will receive 40 hours of such training annually. Training requirements set forth in 29 CFR 1910.120 also apply. In addition, DFSC environmental coordinators and superintendents of GOCO DFSPs must complete a 40-hour course on oil spill control.

(8) Plan Review and Amendment. The Installation Spill Contingency Plan will be reviewed and evaluated at least once every three years or whenever the plan fails under emergency or training conditions or whenever there is a change in applicable regulations; change in design construction, operation, or maintenance at a potential spill site that could materially increase the chance of a release; change of installation on-scene coordinator or IRT members; or change in available response equipment.

(9) Catastrophic Releases. Installation Spill Contingency Plans must address all types of potential releases including catastrophic releases. An example of a potentially catastrophic release would be a major warehouse fire involving toxic vapor emissions and toxic fire-fighting runoff. In addition, contingency plans for hazardous waste facilities must address hazards to human health or the environment from fires, explosions, or any napalmed sudden or non-sudden release to air, soil, or surface water (Subpart D of 40 CFR 264).

c. Emergency Planning and Community Right-To-Know

(1) DLA-managed activities will establish Emergency Planning and Community Right-To-Know Programs, or Title III Programs, which are comparable to the extent practicable to the local programs established under Title III. DLA activities are not required to comply with the procedural requirements established under Title III, such as reporting requirements. This means that inventories, lists of materials, and annual reports need not be submitted. However, DLA activities will appoint representatives to community planning committees as appropriate and ensure that these groups are notified of any DLA spill in excess of the reportable quantity.

(2) DLA-managed activities will establish Emergency Planning Committees analogous to the Title III committees established by local civilian communities. The committee will be chaired by the environmental officer and will include representatives from the safety and health office, facility engineer, security office, fire department, DRMO, and activities which store, use, or generate oil or hazardous substances. The committee will generally be responsible for coordination of PLFA planning for spills and releases of hazardous substances into the environment, including releases which might occur during catastrophic incidents such as a major warehouse fire. The committee will also:

(a) Establish procedures for receiving and processing requests for information.

(b) Ensure that SPCC and installation spill contingency plans address all sites at which a catastrophic release of hazardous substance could occur.

(c) Maintain an inventory of sites at which MSDS chemicals are stored on base. Ensure that this inventory is updated annually.

(d) Meet at least annually to review and update emergency plans.

(3) Emergency Notification is a key element of Title III Programs. Emergency plans should address all types of environmental releases, including releases to the air, surface water, groundwater, and soil. The installation spill contingency plan will provide for immediate notification to state emergency response commissions, local emergency planning committees, and other affected community members, as appropriate, wherever reportable quantities of hazardous materials are released. Hazardous materials include any substance listed by EPA in 40 CFR 355 or 40 CFR 302. A written follow-up notice is also required.

(4) Contractor-operated Government facilities (e.g., DFSPs, DIPEF and DNSS Rolla) must, by law, fully comply with all appropriate aspects of Title III, including reporting requirements and other procedural requirements established under the Act. This means that inventories, lists of materials, and annual reports will be submitted to states or local emergency planning committees. These activities will appoint representatives to local emergency planning committees where appropriate. Further, these activities will fully notify local emergency planning committees in the event of a DLA release that might result in exposure to persons outside the DLA fenceline.

(5) Regulations that apply include 40 CFR 355 and 40 CFR 370. In addition, the National Response Team has published the "Hazardous Materials Emergency Planning Guide." The EPA has established an information hotline; call 1-800-535-0202. Various publications are available from EPA.

d. Underground Storage Tanks

(1) Facilities with underground storage tanks are required by law to manage tanks in an environmentally sound manner and to take measures to protect the quality of groundwater resources. In most cases, this means developing a program of leak testing, soil monitoring, groundwater monitoring, and inventory reconciliation or some combination thereof in accordance with RCRA and various state laws.

(2) Tanks that store heating oil for use on the premises are not covered by the Federal law.

(3) EPA's 8 November 1986 rule on notification, at 40 CFR 280, required owners of existing tanks to notify their designated state or local agencies by 8 May 1986. Notification for new tanks is required within 30 days after the tanks are installed. An expanded, comprehensive version of 40 CFR 280 that covers all aspects of underground tank construction and management was published on 23 September 1988. Technical standards in the new rule do not cover field-constructed tanks (e.g., large bulk fuel tanks); with regard to technical standards, EPA has deferred the regulation of these tanks until some undetermined future time.

(4) A growing number of states now have their own laws with implementing regulations. It is expected that the state regulations will be more stringent than the Federal regulations.

(5) Underground tanks will be included in the installation SPCC Plan and the ISC Plan.

(6) Underground storage tanks may not be abandoned to avoid regulation. Storage tanks may be closed by either removal or by leaving them in place after they are drained, cleaned, and filled with an inert substance. Regulatory authorities must be notified 30 days before action is taken to close out an underground tank.

e. Oil Pollution Prevention Operations Manual (OPPOM)

(1) Oil terminals (DFSPs) that transfer fuel to or from barges or ships will develop and maintain an OPPOM in accordance with 40 CFR 154.

(2) A Letter of Adequacy (indicating Coast Guard approval of the OPPOM) must be attached to the OPPOM.

(3) All fuel transfers that involve ships or barges will be conducted in accordance with the procedures in the OPPOM.

f. MARPOL Protocol Compliance. Oil terminals (DFSPs) that handle oceangoing ships larger than 400 gross tons will obtain a Certificate of Adequacy from the Coast Guard in accordance with the international MARPOL agreement and 40 CFR 158.

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