SPILL PREVENTION CONTROL & COUNTERMEASURE (SPCC) PLAN

Transcription

1 SPILL PREVENTION CONTROL & COUNTERMEASURE (SPCC) PLAN Prepared For: Otterbein University Located at 1 S. Grove July A Green Crest Drive Westerville, OH P 614*865*1874 F 614*865*1879 mail@stoneenvironmental.com

2 TABLE OF CONTENTS 1. REGULATORY CROSS-REFERENCE... 1 A. SPCC PLAN REGULATORY CROSS-REFERENCE... 1 B. LOG OF REVIEW AND AMENDMENTS PURPOSE PLAN AVAILABILITY PLAN ADMINISTRATION AND CERTIFICATION FACILITY INFORMATION... 6 A. Name & Address of Facility... 6 B. Name & Address of Owner... 6 C. Designated Emergency Coordinators... 6 D. Other Identifying Information... 7 E. Description of Facility Location... 7 F. Internal Communication System... 7 G. Spill Reporting Phone Numbers... 8 H. Other Emergency Telephone Numbers... 9 I. When an Emergency Occurs... 9 J. Policies for Notification of Correct Agency... 9 K. List of Required Information When Making an Emergency Call L. Post-Emergency Reporting Requirements SPILL PREVENTION, CONTROL AND COUNTERMEASURE A. Conformance B. Discharge Sources and Prevention Measures C. Countermeasures D. Tank Integrity Testing SPILL RESPONSE EMPLOYEE TRAINING PROGRAM A. Designated Emergency Coordinators B. Training for New Employees Stone Environmental i July 2014

3 Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 Figure 6 Figure 7 Figure 8 Figure 9 Figure 10 Figure 11 Figure 12 Figure 13 Figure 14 Figure 15 Figure 16 Figure 17 LIST OF FIGURES Location Map Location Map Equine Center Location Map Collegeview Center Building Map Equine Center Building Map Collegeview Center Building Map Service Building Building Map Roush Hall Building Map Towers Hall Building Map Science Center Building Map Clements Rec Center Building Map- Rike Building Building Map DeVore Hall Building Map Courtright Memorial Library Building Map Batelle Fine Arts Center Building Map 25 West Home Building Map Home Commons Building Map Campus Center Appendix A Appendix B Appendix C Appendix D Appendix E APPENDICES Quarterly Inspection Form Annual City Transformer Inspection Form Reportable Quantities of Hazardous Substances Written Follow-Up to Emergency Release Notification Training Documentation Form Spill Reports Stone Environmental ii July 2014

4 1. REGULATORY CROSS-REFERENCE A. SPCC PLAN REGULATORY CROSS-REFERENCE Citation Description Section Subpart A Applicability, Definitions, and General Requirements for All Facilities and All Oil Types (d)(1) Professional Engineer Certification (b) Management of Five Year Review Foreword 1.B General requirements for SPCC Plans for all facilities and all oil types 2,5,6, Figures 112.7(a) General requirements: discussion of Facility s conformance with rule requirements; deviations from Plan requirements; Facility characteristics that must be described in the Plan; spill reporting information in the Plan; emergency procedures 1,2,5,6 & Appendices 112.7(b) Fault analysis NA 112.7(c) Secondary containment (d) Spill Contingency planning 5, (e) Inspections, tests, and records 6, Appendix A 112.7(f) Employee training and discharge prevention procedures 7, (g) Security (excluding oil production facilities) 5.E 112.7(h) Loading/unloading (excluding offshore facilities) (i) Brittle fracture evaluation requirements NA 112.7(j) Conformance with State requirements 2,4 Subpart B Requirements for Petroleum Oils and Non-Petroleum Oils, Except Animal Fats and Oils and Greases, and Fish and Marine Mammal Oils; and Vegetable Oils (Including Oils from Seeds, Nuts, Fruits, and Kernels) Requirements for onshore facilities (excluding production facilities) NA 112.8(a) General and specific requirements (b) Facility drainage 5, Figures 112.8(c) Bulk storage containers (d) Facility transfer operations, pumping, and Facility process Requirements for onshore production facilities NA Requirements for onshore oil drilling and workover facilities NA Requirements for offshore oil drilling, production, or workover facilities NA Subpart C Requirements for Animal Fats & Oils and Greases, & Fish & Marine Mammal Oils; &Vegetable Oils, including Oils from Seeds, Nuts, Fruits, & Kernels - Subpart D Response Requirements Facility response plans 5, Facility response training and drills/exercises 8 Stone Environmental 1 July 2014

5 B. LOG OF REVIEW AND AMENDMENTS NONTECHNICAL AMENDMENTS Non-technical amendments are not certified by a Professional Engineer (P.E.). Examples of changes include, but are not limited to, phone numbers, name changes, or any non-technical text change(s). TECHNICAL AMENDMENTS Technical amendments are certified by a Professional Engineer ( 112.5(c)). Examples of changes include, but are not limited to, commissioning or decommissioning containers; replacement, reconstruction, or movement of containers; reconstruction, replacements, or installation of piping systems; construction or demolition that might alter secondary containment structures; changes of product or service; or addition/deletion of standard operation or maintenance procedures related to discharge prevention measures. It is the responsibility of the Facility to determine, and confirm with the regulatory authority as necessary, what constitutes a technical amendment. The preamble of the rule states that an amendment is required only when there is a change that materially affects the Facility s potential to discharge oil (67 FR 47091). An amendment made under this section will be prepared within six months of the change and implemented as soon as possible but not later than six months following preparation of the amendment. Technical Amendments affecting various pages within the plan can be certified by a Professional Engineer on those pages, certifying those amendments only, and will be documented on the log form below. MANAGEMENT REVIEW Management will review this SPCC Plan at least every five (5) years and will document the review on the form below ( 112.5(b)). Review/ Amend Date Signature Amend Plan (will/will not) Description of Review Amendment Affected Page(s) P.E. Certification (Y/N) Stone Environmental 2 July 2014

6 2. PURPOSE The purpose of this Spill Prevention Control and Countermeasures Plan (SPCC Plan) is to prevent spills of diesel fuel, new and used motor oil, transformer oil, cleaning chemicals, concentrated products, cooking oil or other hazardous materials from entering the City of Westerville publicly owned treatment works (POTW), or storm sewers or drainage ditches, from Otterbein University. This plan is designed to address measures to prevent spills from occurring as well as how to handle spills if they occur. All Spill Response Trained Personnel will be trained to respond to any spill and should be notified immediately by anyone observing a spill whether large or small. This Plan satisfies requirements outlined in 40 CFR Part 403.8(f)(2)(v) and 40 CFR Part 112. This is a comprehensive plan for all areas of the Otterbein Campus that contain any significant quantity of oil. Stone Environmental 3 July 2014

7 3. PLAN AVAILABILITY A copy of this SPCC Plan will be kept in the Environmental Health & Safety Officer s (EH&S Officer) office located in the Business Affairs Office at Otterbein University. A copy was also provided to the Westerville Fire Division. The SPCC Plan is revised each time a significant change is made in the plan. Upon request, the SPCC Plan shall be immediately available to Ohio EPA, or any other agency that requests it. Stone Environmental 4 July 2014

8 4. PLAN ADMINISTRATION AND CERTIFICATION Otterbein University is committed to preventing discharges of contaminants to navigable waters and the environment, and to maintaining the highest standards for spill prevention, control, and countermeasures through the implementation and regular review and amendment of the Plan. It will be the responsibility of those named below to see that any changes to the Plan will be updated to all copies as outlined in Section 3. This Plan has the full approval of Otterbein University, who has committed the necessary resources to implement the measures described in this Plan. I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information therein. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information contained is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Signature: Date: Tara Grove Title: EH&S Officer, Otterbein University Professional Engineer Certification (40 CFR 112.3(d)) The undersigned Registered Professional Engineer is familiar with the requirements of Part 112 of Title 40 of the Code of Federal Regulations (40 CFR part 112) and has visited and examined the facility, or has supervised examination of the facility by appropriately qualified personnel. The undersigned Registered Professional Engineer attests that this Spill Prevention, Control, and Countermeasure Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards and the requirements of 40 CFR part 112; that procedures for required inspections and testing have been established; and that this Plan is adequate for the facility, (40 CFR 112.3(d)). This certification in no way relieves the owner or operator of this facility of his/her duty to prepare and fully implement this SPCC Plan in accordance with the requirements of 40 CFR Part 112. This Plan is valid only to the extent that the facility owner or operator maintains, tests, and inspects equipment, containment, and other devices as prescribed in this Plan. Signature: Date: Sharon J. Herman, P.E., Stone Environmental Stone Environmental 5 July 2014

9 Otterbein University 1 South Grove FACILITY INFORMATION A. Name & Address of Facility Otterbein University 1 South Grove B. Name & Address of Owner C. Designated Emergency Coordinators The Designated Emergency Coordinators shall implement this plan. The Designated Emergency Coordinators shall revise the plan, maintain control measures, perform inspections and assessments, and implement corrective actions as needed. This plan shall remain available, either paper copy or electronically, to Designated Emergency Coordinators. Primary Contact: Tara Grove Title: EH&S Officer Work Phone: Cell Phone: Secondary Contact: Otterbein Police Work Phone: Additional Contact: Westerville Fire Department Non-emergency: Emergency: 911 Additional Contact: Title: Work Phone: Cell Phone: This list will be updated whenever a change of personnel warrants it. At all times, there must be at least one employee either on the facility premises or on call (i.e., Stone Environmental 6 July 2014

10 available to respond to an emergency by reaching the facility within a short period of time) with the responsibility for coordinating all spill and emergency response measures. The Designated Emergency Coordinators must be thoroughly familiar with all aspects of the Plan, all operations and activities at the facility, the location and characteristics of any oil storage, the location of all records within the facility, and the facility layout. In addition, this person must have the authority to commit resources needed to carry out the emergency procedures stated in this Plan. D. Other Identifying Information EPA Hazardous Waste ID (RCRA ID No.): OHD TRI Facility ID: Ohio Storm Water NPDES Permit No: NA NA SIC Code: 8221 North American Industrial Classification System: The facility is an institution of higher learning. It consists of primarily classrooms and lecture halls. Oil is used to for emergency generators, heating, cooking and motive power. E. Description of Facility Location Otterbein University is located on the northeast side of Columbus, Ohio on 140 acres. The University s listed address is 1 South Grove,, Figure 1 shows the location of the university in relation to waterways. Figure 2 shows the location on campus of the buildings included in this Plan. The buildings and potential sources of oil contamination are listed in Table 1 located in Section 6. Description of Security Measures: 1. The campus is patrolled by its own police force. 2. Fencing There is no fencing on any portion of the property. 3. Lighting applicable outdoor lighting is located throughout campus. 4. Most sources of oil require a key for access. Each source is discussed individually in Section Otterbein utilizes a Cardinal Red Alert System. This emergency alert/notification system sends s, text messages and automated phone calls to the campus community in the event of an emergency. F. Internal Communication System Fixed phones, cell phones, and the Cardinal Red Alert System provide immediate campus communication options. Stone Environmental 7 July 2014

11 G. Spill Reporting Phone Numbers Spill Type Agency Day Number Spills that impact soil, surface water or ground water Ohio EPA Central District Office Div. of Surface Water City of Westerville Water Division After Hours Number Fish Kills Hazardous Materials Ohio EPA US Fish & Wildlife Franklin County Emergency Mgmt. and Homeland Security Ohio EPA Storage Tank Spills Ohio EPA Spills that may be discharged to the sanitary sewer Reportable Quantity spills (per Federal Law) Spills that threaten health and safety or are not contained City of Columbus POTW National Response Center On-line Reporting Ohio EPA (Emergency Response Team) City of Columbus Health Department /nrchp.html Stone Environmental 8 July 2014

12 H. Other Emergency Telephone Numbers Fire Department- Emergency 911 Non- Emergency, City of Westerville Ambulance Service City of Westerville 911 Police Department Emergency 911 Non-Emergency, Westerville Division of Police Franklin County Sheriff Ohio State Highway Patrol I. When an Emergency Occurs Whenever there is an imminent or actual emergency situation, the Designated Emergency Coordinator must immediately: Activate facility alarms or communication systems to notify personnel Notify local emergency response agencies Whenever an emission, discharge, spill, fire or explosion occurs, the Designated Emergency Coordinator must immediately: Identify the character, exact source, amount and extent of the affected area J. Policies for Notification of Correct Agency 1. In emergencies where there is danger of fire, explosions, or toxic materials being discharged onto land, into the air or water that would Stone Environmental 9 July 2014

13 threaten human life, call the City of Westerville Fire Department first at Call the Ohio EPA Emergency Response Team at , the Local Emergency Planning Commission (LEPC) and the City of Westerville Fire Department for a spill or release which meets any of the criteria listed below and leaves the facility property line. ( leaves the facility property line may be as a direct result of the spill, carried by wind or storm water runoff, or uncontained as a result of clean up operations). The LEPC for this facility is the Franklin County Emergency Management and Homeland Security. The spill shall be reported within 30 minutes of knowledge of the release. Follow up with written report (see Section 5.L of this plan). Extremely Hazardous Substances as defined by 40 CFR 355 Hazardous Substances listed in 40 CFR 117, Table 117.3, reproduced in Appendix B of this document. Reportable quantities may be between 1 lb. and 5000 lbs see table in Appendix B. Any oil (which includes gasoline, petroleum, fuel oil, sludge, transformer oil and machining oil) released to navigable waterways that produces a visible sheen or film. For the release of oil or fuel onto land, the reportable quantity is 25 gallons. 3. If the spill threatens to enter a waterway, report the spill to the National Response Center at , or report the spill online at if any of the reportable quantities below exist: The reportable quantity for oil, gasoline, diesel or any petroleum product is that which produces a sheen, film or discoloration of the water, leaves a sludge or emulsion, or violates applicable water quality standards. For all other substances, review 40 CFR 117, Table 117.3, reproduced in Appendix B of this document. If a substance is not a petroleum or oil product, and not listed in Table 117.3, it is not subject to reporting to the National Response Center. Stone Environmental 10 July 2014

14 4. For emergencies that consist of liquid material spilled outside a contained area and that have the potential to enter the sanitary sewer system, call the City of Columbus POTW at K. List of Required Information When Making an Emergency Call When reporting a discharge incident over the telephone (initial reporting requirement), be prepared to relay as much of the information listed below as is known or can be estimated at the time of reporting: Name and telephone number of person making the report Name and location of the facility Date and time of discharge incident Brief description of the incident and any possible hazards to human health and or the environment Chemical name or identity of any substance(s) involved in the release or discharge Estimated quantity of material or waste involved Extent of contamination and precautions taken L. Post-Emergency Reporting Requirements After a release or discharge of a substance that leaves the facility property line, written follow-up emergency notice must be submitted within 30 days to the Ohio EPA Emergency Response Section, the LEPC (the Franklin County Information & Emergency Coordinator), and the Westerville Fire Division. Use the Written Follow-up to Emergency Release Notification criteria in Appendix C when preparing the report and submit to the following addresses: Ohio EPA, DERR-ER Franklin County Emergency Lazarus Government Center Management and Homeland Security 50 West Town, Suite Strawberry Farms P.O. Box 1049 Columbus, OH Columbus, OH Attn: ER Records Mgmt. SERC Report Westerville Fire Division 400 West Main Westerville, OH Stone Environmental 11 July 2014

15 Should a chemical spill to the sanitary sewer occur, file a written report with the City of Columbus POTW within five (5) calendar days of the incident. The report shall contain the following information: 1. A description of the discharge, the cause of the upset, and the upset s impact upon the user s compliance status. 2. The period of noncompliance, including the exact dates and times of noncompliance, and if the noncompliance continues, the time by which the noncompliance is expected to be corrected. 3. All steps taken to reduce, eliminate, and prevent recurrence of the noncompliance. This written report is to be sent to: City of Columbus Industrial Wastewater Pretreatment Group 1250 Fairwood Avenue, Room 186 Columbus, Ohio Attention: Pretreatment Program Manager Stone Environmental 12 July 2014

16 6. SPILL PREVENTION, CONTROL AND COUNTERMEASURE A. Conformance The facility currently conforms to the SPCC requirements of 40 CFR 112, with the exception of those noted in Recommendations in this Section. B. Discharge Sources and Prevention Measures The sources of potential oil discharge are listed in this Section. Stone Environmental 13 July 2014

17 TABLE 1 - Storage Tanks, Materials, Reportable Quantities (ID number refer to location maps on Figures 1, 2 and 3) ID # Location Address Source Label ID Total Capacity (gal) Contents Generator T Diesel Sec. Contain -ment Yes Fuel Tank T Diesel Yes 1 2 Equine Center Collegeview Center 600 N. Spring Rd. 60 Collegeview Rd. Shed Maintenance Shed NA NA Approx gal containers Approx gal pails, 2 1- gal cans Gasoline Used oil, gasoline Yes Generator T Diesel Yes No Fuel Tank T Diesel No Aboveground Heating Tank TBD TBD Heating Oil TBD Elevator Reservoir NA gal. pails Hydraulic Oil No 3 Service Building 195 W. Park DTE Hydraulic Fluid Underground Storage Tank NA 5-gal. pails Hydraulic Oil No TBD 1,000 Gasoline NA Used Oil in Maintenance Area NA Approx gal. drums Used Oil No Bulk Motor Oil NA 275 Motor Oil No Stone Environmental 15 July 2014

18 Fuel stored in flammable cabinet NA 5-gal. containers Gasoline Yes Diesel Tank T Diesel Yes 4 Roush Hall 27 S. Grove Generator C Diesel Yes 5 Towers Hall 1 S. Grove Elevator Reservoir NA 75 Hydraulic Oil Yes Transformer NA Transformer Oil * 6 Science Center 155 W. Main Generator C Diesel No Elevator Reservoir NA 134 Hydraulic Oil Yes 7 Clements Rec Center 85 W. Home Elevator Reservoir NA 80 Hydraulic Oil Yes Generator T Diesel Yes 8 Rike Physical Education Building 180 Center Transformer NA Transformer Oil * Elevator Reservoir NA 44 Hydraulic Oil Yes 9 Generator T Diesel Yes DeVore Hall 96 W. Home Transformer NA 400 Transformer Oil * Elevator Reservoir NA 95 Hydraulic Oil Yes Stone Environmental 16 July 2014

19 10 Courtright Memorial Library 138 W. Main Transformer NA Transformer Oil Yes Elevator Reservoir NA 75 Hydraulic Oil No 11 Batelle Fine Arts Center 170 W. Park Elevator Reservoir NA 16.2 Hydraulic Oil Yes 12 Business Office/HR 25 W. Home Generator C Diesel No W. Home 25 W. Home Elevator Reservoir Elevator Reservoir NA 99 Hydraulic Oil Yes NA 54 Hydraulic Oil Yes 14 Home Commons W. Home Transformer NA 300 Transformer Oil * Transformer NA 300 Transformer Oil * 15 Campus Center 100 W. Home Elevator NA 75 Hydraulic Oil Yes Used Cooking Oil NA 2 55-gal drums Cooking Oil No Oil/Water Separator NA Fats, oil and grease ** The transformers at Otterbein University are considered oil-filled operational equipment and meet the Qualification Criteria of 112.7(k): Qualified Oil-filled Operational Equipment. The owner or operator of a facility with oil-filled operational equipment that meets the qualification criteria in paragraph (k)(1) of this sub-section may choose to implement for this qualified oil-filled operational equipment the alternate requirements as described in paragraph (k)(2) of this sub-section in lieu of general secondary containment required in paragraph (c) of this section. Stone Environmental 17 July 2014

20 (1) Qualification Criteria Reportable Discharge History: The owner or operator of a facility that has had no single discharge as described in 112.1(b) from any oil-filled operational equipment exceeding 1,000 U.S. gallons or no two discharges as described in 112.1(b) from any oil-filled operational equipment each exceeding 42 U.S. gallons within any twelve month period in the three years prior to the SPCC Plan certification date, or since becoming subject to this part if the facility has been in operation for less than three years (other than oil discharges as described in 112.1(b) that are the result of natural disasters, acts of war or terrorism) (2) Alternative Requirements to General Secondary Containment. If secondary containment is not provided for qualified oil-filled operational equipment pursuant to paragraph (c) of this section, the owner or operator of a facility with qualified oil-filled operational equipment must: (i) Establish and document the facility procedures for inspections or a monitoring program to detect equipment failure and/or a discharge; and (ii) Unless you have submitted a response plan under , provide in your Plan the following: (A) An oil spill contingency plan following the provisions of part 109 of this chapter. See Section 7 of this document. (B) A written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful. See Section 4 of this document. ** Exempt per 40 CFR 112.1(d)(6). Transformers Owned by the City of Westerville The following table shows transformers located on Otterbein s property and owned by the City of Westerville, Electric Division. Although maintenance of these transformers is the responsibility of the City of Westerville, Otterbein University will inspect these annually and notify the Electric Division of any damage, leakage, corrosion or other circumstances they feel they should be aware of. Some of the smaller units listed may be pole-mounted transformers. For those, noting whether there is any signs of transformer oil on the ground or pole will be adequate. Note that the transformer at 60 Collegeview Road is a City of Westerville owned transformer, but has been included in the quarterly inspection checklist in Appendix A due to its close proximity to Otterbein Lake. If any deterioration is observed during annual inspection or at any other time, contact the City of Westerville Electric Division at (614) If any leakage is observed, contact the City of Westerville immediately as well as the Designated Emergency Coordinators listed on page 6. Stone Environmental 18 July 2014

21 Location Voltage Transformer size or Oil Capacity Westerville Electric Information 194 W HOME 120/ Gallons 188 W MAIN 120/ Gallons BAKER HOUSE 120/240 Unable to find an address CLEMENTS HOUSE 120/ Gallons 111 N. West 46 W HOME 120/ Gallons 166 W MAIN 120/ Gallons Same transformer as 172 W. Main 121 W HOME 120/ Gallons 64 W HOME 120/ Gallons 146 W HOME 120/ Gallons Same transformer as 154 W. Home 181 N W 120/ Gallons 177 W PARK 120/ Gallons 94 W PARK 120/ Gallons Same transformer as 94 W. Park 131 W PARK 120/ Gallons 82 W MAIN 120/ Gallons Same transformer as 82 W Main 25 W HOME 120/ Gallons, 225 kva 120/208 V MAYNE HALL 65 N. Grove - Primary Metered 55 N GROVE 120/240 "Can't find meter address" 180&190 W PARK 120/ Gallons, 1500KVA SCOTT HALL 120/ kva 120/240 V 1Ø "94 W. Home St. - Unable to find address" ENGLE HALL 120/240 Fed from Scott "92 W. Home St. - Unable to find address" ROUSH HALL 120/ Gallons, 500 kva 120/208 V 27 S. Grove St. DAVIS HALL 120/ Gallons, 50 kva 120/240 V 1Ø 170 Martin Drive, same transformer as Davis Annex N. Center St. 33 COLLEGEVIEW 120/ Gallons, 300kva120/ COLLEGEVIEW 480/ Gallons, 500KVA480/277 COWAN HALL 120/ Gallons, 150 kva 120/208 V 30 S. Grove EQUINE STABLES 277/ Gallons, 150 kva 120/208 V 600 N. Spring Road CLIPPINGER HALL 120/ Gallons, 225 kva 120/208 V 102 W. College Ave. FRANK MUSEUM 120/ Gallons, 75 kva 120/208 V 39 S. Vine Stone Environmental 19 July 2014

22 Equine Center The diesel generator here appears to be double-walled. It is not clear if the interstitial space is alarmed. A box surrounding the fill pipe provides containment for any drips and a small amount of overflow. A 550-gallon diesel tank is used to fuel farm equipment. A sticker indicates that this tank is double-walled. The tank is equipped with a gauge mounted at the bottom that allows one to determine if there is any liquid in the interstitial space. However, the gauge is cracked and unreadable. Recommendation: Replace gauge on interstitial space so that it can be read during quarterly inspection to determine if there is any liquid in the interstitial space. A spill kit is located inside the door of the garage. The shed contains two flammable cabinets. At the time of the walk-through, these two cabinets were holding approximately seven 5-gallon gas cans. The flammable cabinet would provide containment should one of these cans rupture. Equipment is repaired or maintained in the maintenance shed. At the time of the walk through, there were four 5-gallon pails of used oil and at least two 1-gallon gas cans. Recommendation: These pails and cans should be stored on catch pans as much as possible. A transformer is located near the barn, close to the generator. Both a catch basin and a trench drain are located in close proximity to the transformer. The transformer is located on a concrete pad. Bollards provide some protection from vehicular traffic, but do not cover the front side of the transformer. If someone were to back a horse trailer or other equipment into the transformer, the contents would be released to the storm sewer. Recommendation: Bollard(s) should be installed in front of the transformer. Collegeview Center This building is used for dry-goods storage. Loading docks with trench drains are located on the north side of the building. Since only items like furniture are stored in the building, this does not represent a spill risk. However, if Otterbein starts storing any chemicals or oil products in the building, they will need to implement methods of protecting these trench drains. A transformer, owned by the City of Westerville, is located behind the building on a concrete pad. Although it is not exposed to vehicular traffic in that location, its proximity to Otterbein Lake (approximately 120 feet), quarterly inspection is imperative. Stone Environmental 20 July 2014

23 A diesel generator sits on top of tank T-005. This is an older generator. It could not be determined if it is double-walled. It is well protected from vehicular traffic. Recommendation: Otterbein should review records to determine if this tank is double walled. Service Building The Service Building includes the heat plant and is located on two levels approached from either the east or the west. On the western lower level, at the time this SPCC Plan was written, underground storage tanks previously referred to as T-008, T-009 and T-010 storing heating fuel were being removed. One aboveground tank will take its place. This Plan will need to be revised when that occurs. At a minimum, the replacement aboveground storage tank should be double-walled with interstitial monitoring. Aboveground tank T-007 is an older tank, does not appear to be double-walled, and is mounted on cinderblocks. There is currently little protection from vehicular traffic. This tank currently supplies a generator. Recommendation: If this tank cannot be eliminated, it should be replaced with a double-walled tank, securely mounted and protected from vehicular traffic. Inside the service building, an elevator provides service to the second floor. The reservoir is 20 gallons and several 5-gallon drums of hydraulic fluid are nearby to top it off as needed. On the day of the walk through, there were adsorbents near the reservoir indicating there may be some leakage. This elevator is maintained by an outside contractor. The sump of the elevator collects with water that may be groundwater. This water is pumped outside the building into a blue 55-gallon plastic drum. It was difficult to determine if any hydraulic fluid was in the water that was being removed from the sump. Recommendation: This elevator system, including its reservoir, needs a more aggressive maintenance schedule. The water pumped from the elevator shaft needs to be inspected daily to make sure the collection barrel is not overflowing and to determine the presence of any hydraulic fluid. Any drums of hydraulic fluid should be kept on a spill pallet. 5-gallon drums of DTE hydraulic fluid were located throughout the room. Recommendation: These drums should also be stored on spill pallets. On the eastern upper level, a 1,000 gallon underground storage tank supplies gasoline to a dispensing system. The dispending system is protected from vehicular traffic by bollards. The underground storage tanks are regulated under 40 CFR 280 (in Ohio by the Bureau of Underground Storage Tank Regulation BUSTR), and as such, are exempt from SPCC. The procedures governing their inspection and maintenance are not included in this Plan. Quarterly inspection should include the dispensing station. A spill kit is located inside the garage door. It is expected that any spill from this Stone Environmental 21 July 2014

24 station would be small and would be cleaned from the asphalt using spill kit materials. A 550-gallon aboveground diesel tank T-006 and dispensing system is also located in this area. The tank is protected by bollards and is double-walled with a leak gauge. Vehicles are maintained in the garage portion of this building. Used oil is stored in 55-gallon drums on a spill pallet. Bulk new motor oil is stored in a 275-gallon dispensing station. This appeared to be single-walled and had notable rust along the bottom of the walls. There were no floor drains in the area and a spill would likely not travel outside the building. Recommendation: Otterbein should verify that the rust observed was superficial, and replace this system if necessary. A flammable cabinet held at least one 5-gallon container of gasoline. If one of these were to rupture, the cabinet would provide containment. Roush Hall A transformer is located outside Roush Hall. This will be included in quarterly inspections. A generator, with tank C-003 of diesel fuel, is located in a concrete pit. Besides being double-walled, containment is provided by concrete containment, approximately 2 feet high. Storm water could collect in this containment structure. Because the tank is double-walled, the concrete containment is redundant and therefore a determination during the quarterly inspection as to whether storm water needs to be removed from the containment area is deemed adequate. Towers Hall Towers Hall has a piston elevator. The room surrounding the reservoir serves as adequate containment for the 75 gallons of hydraulic oil it contains. Otterbein owns a transformer located in a shed near Towers Hall. The concrete floor and walls provide containment. There did not appear to be any floor drains in the shed, although a great deal of sediment had washed into the shed. Recommendation: Remove any sediment and debris that has washed into the building. Ensure that there are no floor drains in this shed where a leak of transformer oil would be directly introduced into the storm sewer system. Consider ways of diverting storm water from entering this shed. Science Center A generator in the basement of this building is located in close proximity to three floor drains. A spill during filling operations would be introduced into the sanitary sewer. Recommendation: Purchase drain covers and store in an easily accessible Stone Environmental 22 July 2014

25 location. Require that all three drains be covered during filling operations. At the time of the walk through, some absorbent mats were at the base of the generator. Recommendation: Determine if these mats were to clean up a spill or drips, such as during filling, or due to a slow leak on any portion of the generator. If the later is true, drain covers should be put in place and the generator or tank repaired immediately. There is an elevator reservoir for the building. The room surrounding the elevator reservoir would serve as containment if there were a release of hydraulic fluid. Clements Rec Center The room surrounding the elevator reservoir would serve as containment if there were a release of hydraulic fluid. Rike Physical Education Building The room surrounding the elevator reservoir would serve as containment if there were a release of hydraulic fluid. Recommendation: Cracks between the floor and the walls should be sealed, such as with caulk, to provide better containment. A generator and adjacent tank T-004 are outside the building. The tank is doublewalled. Construction is currently underway to replace the generator with a larger one. While this construction takes place, the generator/tank is on a wood foundation. This is not considered ideal, but in light of the temporary nature of this arrangement, no recommendation is made at this time. A transformer is located outside the building, within a couple feet of a catch basin. It was not clear if this transformer contains oil. Recommendation: Determine if this is an oil-containing transformer or a dry transformer. If this transformer contains oil, a course of action will be determined to protect the catch basin from a release of transformer oil. DeVore Hall A generator and diesel tank T-003 sit outside the east side of the building. The tank is double-walled and has a high level alarm on it. A transformer is located outside the building. This contains 400 gallons of transformer oil. The transformer is protected from vehicular traffic and will be part of the quarterly inspection. The elevator reservoir is located in a room that provides containment except for the door that could allow a release to flow into the adjacent room. About ten feet from the door are a sewage lift pump and a sump pump to remove any groundwater or flooding from the basement. Recommendation: A spill kit should be added to this area. In Stone Environmental 23 July 2014

26 the event that any leakage is detected from the elevator reservoir, adsorbents such as socks must be used to divert flow from the two sump pumps in this area. During any maintenance operations on the elevator involving its hydraulic system, these two sump pumps should be protected as well. Courtright Memorial Library The elevator reservoir is located in the basement of this building. While the room itself would provide some containment in the event of a release, a portion of the room is sheetrock, with a crack between the wall and the floor. Outside the closet that houses the reservoir, a floor drain is located approximately ten feet away. A second floor drain is located approximately twenty feet away. Recommendation: Vinyl or rubber base molding, four inches or more high, with radiused bottom edge, typically sold in rolls, would create much better containment in the closet housing the reservoir if it were applied to the areas where the wall is made of sheetrock and caulked to create a seal between the trim and the floor. A spill kit, containing socks and mats, should be added to this area and training will create an awareness that in the event of a release from the reservoir, socks must be used to divert any flow from the floor drains. These drains should also be protected during any maintenance operations on the elevator hydraulic system. The transformer is located in a concrete pit, under roof. This pit provides containment in the event of a release from the transformer. Battele Fine Arts Center The elevator reservoir contains 16.2 gallons of hydraulic oil. This volume of oil is considered adequately contained. Business Office/HR A generator and diesel tank C-002 are located in the basement of this building. The tank did not appear to be double-walled. A sump pump was in close proximity and a floor drain is located approximately ten feet away. To fill the tank, a hose is run down the stairs. Recommendations: Otterbein indicated that they are considering replacing this generator and tank with the one that will be removed soon from the Rike Physical Education Building. This is recommended. If this replacement does not occur in the immediate future, then a means of preventing a release from reaching the sump pump and floor drain needs to be determined. At a minimum, a spill kit should be added to this area with materials to divert flow, in the event of a release, from entering the sump pump and floor drain. During filling operations, procedure should include providing protection for these two sanitary connections such as a drain cover or socks that are picked up after filling is complete. Stone Environmental 24 July 2014

27 25 W. Home There are two different elevator reservoirs at this address which is a residence adjacent to the Business Office. One is located down the stairs on the exterior of the Business Office. For this one, the concrete floor and cinderblock walls create containment should there be a release from the reservoir. The other is located in a closet. The concrete floor and portion of the walls made of cinderblock provide containment. However, the walls made of sheetrock would allow hydraulic oil to seep through the crack between the sheetrock and the concrete and the sheetrock would begin to break down. A floor drain is located approximately fifteen feet outside this closet. Recommendation: As recommended earlier, vinyl or rubber base molding, four inches or more high, with radiused bottom edge, typically sold in rolls, would create much better containment in the closet housing the reservoir if it were applied to the areas where the wall is made of sheetrock and caulked to create a seal between the trim and the floor. Since the floor drain was not a condensation drain or did not seem to have a current use, consider sealing the drain. Home Commons A transformer holding 300 gallons of transformer oil is located outside this building. This will be included on the quarterly inspection checklist. Campus Center A transformer is located outside the Campus Center. It is protected from vehicular traffic by a sidewalk, a tree, and curbing. It is in a highly visible location so that a leak would be expected to be detected promptly and cleaned up. An elevator reservoir in this building holds 75 gallons of hydraulic oil. The closet around this reservoir provides containment. Just outside the closet is a sump pump, which has a guard wall around it approximately 1-1/2 feet high. The guard wall would prevent any release of hydraulic oil that was not contained by the room from entering the sump to be pumped to the sanitary. Cooking oil used by an outside vendor for food preparation is pumped out of fry vats with a portable unit and transferred to one of two 55-gallons drums on the loading dock. The drums, on dollies, are rolled to the end of the loading dock to be pumped out every couple of weeks. A catch basin is in close proximity to the loading dock. Recommendation: Although space is limited where these drums are stored, investigate some type of containment for these drums. A spill kit should be added to the loading dock. This should include a drain cover for the catch basin by the loading dock. Signage should indicate the requirement to cover the catch basin if there is a release of new or used cooking oil. Stone Environmental 25 July 2014

28 An oil/water separator removes fats, oils and grease from wastewater from the food preparation areas. Recommendation: This needs to be on a regular Preventive Maintenance (PM) schedule to be pumped out frequently enough that grease is not introduced to the sanitary sewer. C. Countermeasures One of the Designated Emergency Coordinators listed in Section 5.C shall be notified of any spill of oil. They will initiate the actions detailed in the next chapter of this plan along with the reporting requirements previously mentioned. D. Tank Integrity Testing AST Inspection Standard SP-001 was used to determine the level of inspection required for all bulk storage tanks. This has been shown in the table below. The level of inspection required is defined here. P Periodic AST inspections conducted by owner s inspector. The checklists for these have been included in Appendix F. The personnel performing these inspections shall be knowledgeable of storage facility operations, the type of storage tank and its associated components, and characteristics of the liquid stored. E Formal External inspection by certified inspector. Formal external inspections are to be performed by certified inspectors. A certified inspector is certified by one or more of the following: American Petroleum Institute (API) Standard 653 Authorized Inspector Certification with STI SP001 Adjunct Certification. Steel Tank Institute (STI) Certified SP001 AST Tank System Inspector The certified inspector should refer to section 7 of SP001 for requirements of the inspection. L Leak Test by owner or owner s designee. Consult the Steel Tank Institute Recommended Practice R912, Installation Instructions for Shop Fabricated Stationary Aboveground Storage Tanks for Flammable, Combustible Liquids. Air should not be used for a pressure test and an inert gas should be used instead. The introduction of a gas containing oxygen (such as air) to a tank that has previously held petroleum liquid can pose an explosion hazard. Vacuum testing of the interstice of double-wall or double-bottom tanks is an option. Refer to the Steel Tank Institute Recommended Practice R912, Installation Instructions for Shop Fabricated Stationary Aboveground Storage Tanks for Flammable, Combustible Liquids. Stone Environmental 26 July 2014

29 Leak Testing Methods can include the following technologies: Gas pressure decay (including vacuum decay) Gas pressure soap bubble testing Gas tracers (e.g. helium tracer) Soil tracers (chemical marker) Mass Measurement Level measurement Hydrostatic test (10) Formal External Inspection and Leak Test every 10 years. Stone Environmental 27 July 2014

30 Tank Integrity Testing Summary ID # 1 Location Address Source Label ID Equine Center 2 Collegeview Center 3 Service Building 4 Roush Hall 6 8 Science Center Rike Physical Education Building 9 DeVore Hall 600 N. Spring Rd. 60 Collegeview Rd. 195 W. Park 27 S. Grove 155 W. Main 180 Center Total Capacity (gal) Contents Generator T Diesel Sec. Containment Yes SP-001 Inspection Required Fuel Tank T Diesel Yes P Generator T Diesel Yes Fuel Tank T Diesel No Aboveground Heating Tank TBD TBD Heating Oil TBD Bulk Motor Oil NA 275 Motor Oil No P P P,E&L(10) Diesel Tank T Diesel Yes P Generator C Diesel Yes Generator C Diesel No Generator T Diesel Yes 96 W. Home Generator T Diesel Yes TBD P P P,E&L(10) P P 12 Business Office/HR 25 W. Home Generator C Diesel No P,E&L(10) Stone Environmental 20 July 2014

31 7. SPILL RESPONSE In all cases: Contact a Designated Emergency Coordinator Don protective gear as needed If appropriate, attempt to shut off flow of material Cover any drains in area to keep liquid from going to sanitary sewer or to the catch basins outside the plant Direct all foot and truck traffic away from spill area Initiate containment procedures Contain leak using absorbents (pillows, socks, pigs, mats, etc.) Dispose of used absorbents accordingly If the spilled material is hazardous or of uncertain nature (solvents, acids, etc.): Review Safety Data Sheet (SDS, formerly known as Material Safety Data Sheets or MSDS) to determine whether material is hazardous, Personal Protective Equipment (PPE) required, and disposal procedures. If the spilled material is flammable or suspected of being flammable: Review Safety Data Sheet (SDS) to determine whether material is flammable, Personal Protective Equipment (PPE) required, and disposal procedures. Extinguish all flames and sources of ignition Initiate evacuation of immediate area as deemed necessary Don protective gear Bring fire extinguishers to the spill site Using non-sparking equipment, transfer the absorbed material to an appropriate drum Equipment for Spill Prevention and Emergency Response Spill clean-up equipment and supplies will be stored where they are most accessible and close to the greatest spill potential. Equipment and supplies may include the following, as deemed appropriate: Fire extinguishers Mops Dust masks Socks Sleeves Rubber apron Oil-Dri adsorbent Hard hat Broom Pails Chemical resistant gloves Protective eyeglasses/face shield 55-gallon drum over pack Shop vac Power washer Stone Environmental 20 July 2014

32 Satellite kits with socks, absorbent pads, gloves, and any other equipment deemed necessary for that area, should be added when appropriate. Disposal If the material is non-hazardous and non-flammable, and the spill was small enough to be contained with pigs, socks, mats or rags, those items may be disposed of in the trash provided they are not dripping. For large quantities, hazardous or flammable materials, the Designated Emergency Coordinator shall determine the appropriate disposal procedures and containers. The Designated Emergency Coordinator shall also decide when an environmental contractor will be used for more extensive cleanup. Stone Environmental 21 July 2014

33 8. EMPLOYEE TRAINING PROGRAM In order to have a successful SPCC, employees who handle any form of oil should have training and awareness of the importance of proper spill prevention and clean up techniques. A. Designated Emergency Coordinators Members of this team will receive detail training on all aspects of the SPCC, as well as annual refresher training. All training will be documented using the form in Appendix D and retained by the Chemical Hygiene Officer for a period of five years. Training will include the following topics: 1. Describe components of the SPCC. 2. Describe any incidents which have occurred and procedures for proper response to situations. 3. Spill prevention and response procedures, good housekeeping, and materials handling practices. 4. Review potential sources of oil contamination. 5. Location and use of spill kits. Designated Emergency Coordinators will have annual refresher training that includes a review of housekeeping procedures and materials handling practices, spill prevention and response, a review of spill episodes that occurred in the prior year (if any), and follow up on any corrective actions that may have been indicated. B. Training for New Employees All newly-hired employees who are expected to handle any form of oil will be given general spill awareness training as part of their orientation before being placed on the job. The training will consist of a discussion of the topics listed below. All training will be documented using form in Appendix D and retained by the Environmental Health & Safety Officer for a period of five years. Good Housekeeping 1. Demonstrate clean up of trash, leakage, and spills in equipment areas. 2. Indicate proper disposal locations for all wastes. 3. Identify potential sources of storm water contamination. Spill Prevention and Response 1. Introduce Designated Emergency Coordinators, instruct employees on notification of them upon the identification of a leak or spill. 2. Identify and describe potential spill areas and run-off patterns. Stone Environmental 22 July 2014

34 3. Inform employees of the location and use of spill kits. Describe use of adsorbent materials to contain and clean up spills of liquids. Stone Environmental 23 July 2014

35 FIGURES

36

37 APPENDIX A QUARTERLY INSPECTION FORM ANNUAL CITY TRANSFORMER INSPECTION FORM

38 QUARTERLY INSPECTION FORM Additional sheets can be used, as necessary, to provide all of the information required. ID # Location Address Source Label ID Total Capacity (gal) Contents Any signs of leakage, damage, corrosion, etc? Generator T Diesel 1 2 Equine Center Collegeview Center 600 N. Spring Rd. 60 Collegeview Rd. Fuel Tank T Diesel Shed Maintenance Shed NA NA Approx gal containers Approx gal pails, 2 1- gal cans Gasoline Used oil, gasoline Generator T Diesel Fuel Tank T Diesel Aboveground Heating Tank TBD TBD Heating Oil Elevator Reservoir NA gal. pails Hydraulic Oil 3 Service Building 195 W. Park DTE Hydraulic Fluid Underground Storage Tank NA 5-gal. pails Hydraulic Oil TBD 1,000 Gasoline Used Oil in Maintenance Area NA Approx gal. drums Used Oil Bulk Motor Oil NA 275 Motor Oil

39 Fuel stored in flammable cabinet NA 5-gal. containers Gasoline Diesel Tank T Diesel 4 Roush Hall 27 S. Grove Generator C Diesel 5 Towers Hall 1 S. Grove Elevator Reservoir Transformer NA 75 NA Hydraulic Oil Transformer Oil 6 Science Center 155 W. Main Generator C Diesel Elevator Reservoir NA 134 Hydraulic Oil 7 Clements Rec Center 85 W. Home Elevator Reservoir NA 80 Hydraulic Oil 8 Rike Physical Education Building 180 Center Generator T Diesel Transformer Elevator Reservoir NA NA 44 Transformer Oil Hydraulic Oil 9 Generator T Diesel DeVore Hall 96 W. Home Transformer NA 400 Transformer Oil Elevator Reservoir NA 95 Hydraulic Oil

40 10 Courtright Memorial Library 138 W. Main Transformer Elevator Reservoir NA NA 75 Transformer Oil Hydraulic Oil 11 Batelle Fine Arts Center Business Office/HR 25 W. Home Home Commons 15 Campus Center 170 W. Park 25 W. Home 25 W. Home W. Home 100 W. Home Elevator Reservoir NA 16.2 Hydraulic Oil Generator C Diesel Elevator Reservoir Elevator Reservoir NA 99 NA 54 Transformer NA 300 Transformer NA 300 Elevator NA 75 Used Cooking Oil Oil/Water Separator NA NA 2 55-gal drums Hydraulic Oil Hydraulic Oil Transformer Oil Transformer Oil Hydraulic Oil Cooking Oil Fats, oil and grease Date: Time: Inspected by (printed): Signature:

41 ANNUAL INSPECTION OF CITY-OWNED TRANSFORMERS Location Voltage Transformer size or Oil Capacity 194 W HOME 120/ Gallons 188 W MAIN 120/ Gallons BAKER HOUSE 120/240 CLEMENTS HOUSE 111 N. West 120/ Gallons 46 W HOME 120/ Gallons 166/172 W MAIN 120/ Gallons 121 W HOME 120/ Gallons 64 W HOME 120/ Gallons 146/154 W HOME 120/ Gallons 181 N W 120/ Gallons 177 W PARK 120/ Gallons 94 W PARK 120/ Gallons 131 W PARK 120/ Gallons 82 W MAIN 120/ Gallons 25 W HOME 120/208 MAYNE HALL 65 N. Grove 161 Gallons, 225 kva 120/208 V 55 N GROVE 120/ &190 W PARK 120/ Gallons, 1500KVA SCOTT HALL 94 W. Home St. 120/ kva 120/240 V 1Ø ENGLE HALL 92 W. Home St. 120/240 Fed from Scott ROUSH HALL 27 S. Grove St. 120/ Gallons, 500 kva 120/208 V DAVIS HALL 170 Martin Dr. 120/ Gallons, 50 kva 120/240 V 1Ø 33 COLLEGEVIEW 120/ Gallons, 300kva120/ COLLEGEVIEW 480/ Gallons, 500KVA480/277 COWAN HALL 30 S. Grove St. 120/ Gallons, 150 kva 120/208 V EQUINE STABLES 600 N. Spring Rd. 277/ Gallons, 150 kva 120/208 V CLIPPINGER HALL 102 W. College Ave. 120/ Gallons, 225 kva 120/208 V FRANK MUSEUM 39 W. Vine St. 120/ Gallons, 75 kva 120/208 V Initial /Date when Inspected Note any damage, corrosion, deterioration, or conditions that should be addressed.

42 APPENDIX B REPORTABLE QUANTITIES OF HAZARDOUS SUBSTANCES

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44

45

46

47

48

49

50