SPILL PREVENTION, CONTROL AND COUNTERMEASURE (SPCC) PLAN

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1 SPILL PREVENTION, CONTROL AND COUNTERMEASURE (SPCC) PLAN HUDSON VALLEY COMMUNITY COLLEGE 80 VANDENBURGH AVENUE TROY, NEW YORK March 2015 Page i

2 FIVE-YEAR SPCC PLAN REVIEW AND EVALUATION In accordance with 40 CFR Part 112.5(b), a review and evaluation of this SPCC Plan is to be conducted by at least once every five years. As a result of that review and evaluation, will amend the SPCC Plan within six months of the review to include more effective prevention and control technology if: (1) such technology will significantly reduce the likelihood of a discharge of oil in quantities that may be harmful, as described in 40 CFR Part 110, into or upon the navigable waters of the United States or adjoining shorelines; and if (2) such technology has been field proven at the time of review. Any major technical amendment(s) to the SPCC Plan will be reviewed and certified by a Licensed Professional Engineer within six months after a change in the facility design, construction, operation, or maintenance occurs which materially affects the facility s potential for the discharge of oil in quantities that may be harmful, as described in 40 CFR Part 10, into or upon navigable waters of the United States or adjoining shorelines. As such, has completed a review of this SPCC Plan, as herein described. The following result of the review is noted (check one): [ ] Major changes to the facility have occurred since the last review, therefore the SPCC Plan was appropriately updated and recertified by a Licensed Professional Engineer. [ ] The SPCC Plan for facility was reviewed on the date specified below and no amendment to the SPCC Plan is necessary per 40 CFR Part 112.5(b). [X] Minor changes to the facility have occurred since the last review and the SPCC Plan has been appropriately updated. Reviewed On: March 18, 2015 Reviewer s Signature: Reviewer s Name: Laurie Vivekanand, Director Environmental Health and Safety (Copies of this page should be made for subsequent reviews, and all completed pages must be signed and appended to the SPCC Plan. If the Plan is amended based on the above review, a copy of the previous version of this page should be made and the Licensed Professional Engineer s Certification of the amendment must be completed and maintained with the SPCC Plan.) Page ii

3 FACILITY MANAGEMENT APPROVAL is committed to the prevention of discharges of oil to navigable waters and the environment and maintains the highest standards for spill prevention, control and countermeasures through regular review, updating and implementation of this SPCC Plan. Full approval and implementation of this SPCC Plan as described herein, is extended by management of at a level of authority to commit the necessary resources. Authorized Facility Representative Name: James LaGatta Authorized Facility Representative Signature: Authorized Facility Representative Title: Date: Vice President, Administration Page iii

4 LICENSED PROFESSIONAL ENGINEER CERTIFICATION Certain information in this SPCC Plan has been provided by Hudson Valley Community College. It is understood that also certifies that the information provided is true and accurate. This certification does not relieve Hudson Valley Community College of its duty to implement this SPCC Plan in accordance with 40 CFR Part 112. I hereby attest and certify that (i) I am familiar with the requirements of 40 CFR Part 112; (ii) I, or my agent, have visited and examined the facility; (iii) this SPCC Plan for Hudson Valley Community College located in Troy, New York has been prepared in accordance with good engineering practices, including consideration of applicable industry standards, and with the requirements of 40 CFR Part 112; (iv) procedures for required inspections and testing have been established in this SPCC Plan, and (v) this SPCC Plan is adequate for the facility. (Seal) Printed Name of Licensed Professional Engineer Signature of Licensed Professional Engineer Date Registration Number Registration State Page iv

5 TABLE OF CONTENTS Inserts Following Cover Page: Five Year SPCC Plan Review and Evaluation Facility Management Approval Licensed Professional Engineer Certification 1.0 INTRODUCTION Applicability Plan Elements Management Approval/PE Certification Site Operational History Plan Amendments and Revisions FACILITY IDENTIFICATION Facility Owner and Operator Facility Contacts Facility Summary Description GENERAL FACILITY LAYOUT AND SITE PLAN DRAINAGE SYSTEMS OIL STORAGE INVENTORY Oil Storage Facilities POTENTIAL SPILL PREDICTIONS, VOLUMES, RATES, AND CONTROL CONTAINMENT AND/OR DIVERSIONARY STRUCTURES OR EQUIPMENT TO PREVENT DISCHARGE Secondary Containment Construction and Volume for Bulk Storage Tanks Containment and/or Diversionary Structures of Other Oil Storage Areas Tank and Container Installation Fail-Safe Engineered Integrity Testing and Inspection of Aboveground Containers Buried or Partially Buried Metallic Storage Tanks Brittle Fracture Control of Leakage through Internal Heating Coils Visible Oil Leak Correction from Tank Seam and Gasket Appropriate Position of Mobile or Portable Oil Storage Tanks FACILITY DRAINAGE Drainage from Diked Oil Storage Areas Drainage from Undiked Oil Storage Areas Drainage from Other Oil Storage Areas... 18

6 8.0 FACILITY OIL TRANSFER OPERATIONS Buried Piping Installation Protection and Examination Not-In-Service and Standby Service Terminal Connections Pipe Support Designs Aboveground Valve and Pipeline Examination Aboveground Piping Protection from Vehicular Traffic Filling of Facility Fleet Vehicles FACILITY TANK TRUCK UNLOADING Minimum Standard Operating Procedures Secondary Containment Provisions for the Tank Unloading Area INSPECTIONS, TESTS AND RECORDS Routine Visual Inspection Program and Facility Maintenance Records Historical Spills SECURITY PERSONNEL TRAINING SPILL RESPONSE PROCEDURES Spill Response Equipment Spill Response Procedures Methods of Disposal of Recovered Materials Spill Incident Reporting Follow-up Reporting SPCC Plan Amendment by the Regional Administrator Liability STATE RULES, REGULATIONS AND GUIDELINES FOR OIL DISCHARGE, PREVENTION AND CONTAINMENT New York State Registration of Petroleum Storage Facilities (6 NYCRR Part 612) New York State Handling and Storage of Petroleum (6 NYCRR Part 613) New York State Handling and Storage of Petroleum (6 NYCRR Part 613). 35

7 LIST OF FIGURES Figure # 1 Site Location Map 2 Site Plan LIST OF TABLES Table # 1 Petroleum Storage Inventory 2 Potential Oil Discharge Areas, Spill Prevention Systems, and Spill Prevention Techniques Appendix LIST OF APPENDICES A B C D E F G H I J SPCC Rule Cross Reference Certification of the Applicability of Substantial Harm Criteria Construction Projects Temporary Oil Storage Addendum Monthly Tank Inspection Form Drum and Transformer Storage Inspection Logs Oil Delivery/Pick-up Log SPCC Training Plan Outline Spill Response Procedures Emergency Spill Phone Number Initial Spill Information Form

8 1.0 INTRODUCTION This document presents the Spill, Prevention, Control and Countermeasure (SPCC) Plan for (HVCC), a two-year liberal arts and technical college, located at 80 Vandenburgh Avenue in Troy, New York (Figure 1). This SPCC Plan has been prepared and implemented in accordance with the oil pollution prevention regulations promulgated in Title 40 of the Code of Federal Regulations, Part 112 (40 CFR Part 112). The purpose of this SPCC Plan is to form a comprehensive spill prevention program that: Identifies and assesses areas where oil is handled, stored or managed. Prevents spills, leaks or other releases of oil that could result in the discharge of oil to navigable waters. Ensures appropriate control and countermeasure equipment or procedures are in place to adequately contain and control an inadvertent release of oil. 1.1 Applicability Under 40 CFR Part 112, facilities are required to prepare, maintain, and implement a Spill Prevention Control and Countermeasure (SPCC) Plan if oil could potentially be spilled into navigable waterways, and if any of the following storage thresholds are exceeded: 1. 42,000 gallons or more of oil is stored in underground tanks; or 2. 1,320 gallons or more of oil is stored above-ground. Since HVCC stores greater than 1,320 gallons of oil aboveground (see Table 1), and there is a potential for petroleum to be discharged to surface waters, HVCC is subject to 40 CFR Part 112. Provided in Sections 3.0 and 4.0 of this Plan are the procedures that will be followed by HVCC to prevent and contain the release of oil. 1.2 Plan Elements This SPCC Plan has been developed in accordance with 40 CFR Part 112, including Section Appendix A provides a cross reference for the requirements of 40 CFR Part 112 with the respective sections and page numbers of the SPCC Plan where the requirement has been addressed. For each requirement of 40 CFR Part 112 that is listed in Appendix A, the referenced SPCC Plan section provides a discussion of the facility s conformance with the listed requirement. A complete copy of this SPCC Plan will be maintained onsite and will be made available to the Regional Administrator for review during normal working hours. Page 1

9 1.3 Management Approval/PE Certification Signature sheets for SPCC Plan Review and Evaluation, Management Approval and Licensed Professional Engineer certification are inserted following the Cover Sheet. 1.4 Site Operational History Certification by the facility, that the facility could not, because of its storage capacity, reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters of the United States or its adjoining shorelines is provided in Appendix B, in accordance with the provisions of 40 CFR Part (e). 1.5 Plan Amendments and Revisions This SPCC Plan will be appropriately amended by the facility when there is a change in the facility design, construction, operation or management that materially affects its potential for a discharge of oil in harmful quantities. Examples of changes that may require amendment of the SPCC Plan include, but are not limited to: commissioning or decommissioning of containers; replacement, reconstruction, or movement of containers; replacement, reconstruction or installation of piping systems; construction or demolition that might alter secondary containment structures; changes of product or service; or revision of standard operation or maintenance at the facility. Notwithstanding any amendments to the SPCC plan that are required as a result of changes at the facility, a complete review and evaluation of the SPCC plan will be completed at least once every five years. As a result of this review, the SPCC plan should be amended to include more effective prevention and control technology if the technology has been field-proven at the time of the review and will significantly reduce the likelihood of a discharge from the facility. During any time period, HVCC may have construction projects on-going at the campus. If, during these projects, storage tanks, containers or machinery are being used that have a capacity of 55 gallons or more, HVCC will describe these storage units in an Addendum included as Appendix C to this plan. Any required amendments to the SPCC Plan will be completed within six months and will be implemented as soon as possible, but not later than six months following preparation of the amendment. Each major SPCC Plan amendment will be the reviewed and certified by a Licensed Professional Engineer and approved by facility management. This SPCC Plan was updated from the September 2008 SPCC Plan as a result of minor changes made to the facility. This SPCC Plan supersedes all previous version of the facility s SPCC Plan. Page 2

10 2.0 FACILITY IDENTIFICATION 2.1 Facility Owner and Operator (HVCC) is located at 80 Vandenburgh Avenue in Troy, New York. 2.2 Facility Contacts The following primary facility contact is the designated person accountable for oil spill prevention: Name: Richard Edwards, Director of Physical Plant Contact Number: (518) The following backup facility contacts are the designated person accountable for oil spill prevention: Name: Joseph Leffler, Assistant to the Director of Physical Plant Contact Number: (518) Name: Laurie Vivekanand, Director of Environmental Health and Safety Contact Number: (518) Facility Summary Description (HVCC) consists of 175 acres and is improved by 22 buildings used for administrative, educational and maintenance purposes. Due to on-site operations, the college stores over 10,000 gallons of various petroleum products in bulk storage containers that are subject to SPCC regulations. These products are used as fuel for on-site emergency generators, stored in transformers, etc. On-site activities include administration, education and maintenance. Due to on-site activities, several petroleum products are used and/or stored at the facility including: Heating oil used to fire burners in the instruction of technical curricula; Diesel fuel to run emergency generators; Oil used within on-site transformers and generators; Used oil generated by maintenance and automotive classes; Gasoline and Diesel Fuel for vehicles Food grease from food service operations Food grease for biodiesel fuel production; and Hydraulic oil from elevators Table 1 lists the major storage areas, locations and product types in storage. Figure 2 depicts the location of each storage area. Page 3

11 3.0 GENERAL FACILITY LAYOUT AND SITE PLAN DRAINAGE SYSTEMS The college, consisting of 22 buildings situated on 175 acres, is located on two separate campuses that are referred to as the Hy Rosenblum Administration Center (Morrison Avenue) and the Main Campus (80 Vandenburgh Avenue). This plan addresses the Main Campus located at 80 Vandenburgh Avenue. Approximately 160 acres of the campus are developed as athletic fields, buildings that house administration and educational activities, parking lots, etc., while the remaining 15 acres is undeveloped. Figure 2 provides the facility s Site Plan, which includes the general facility layout and the location of the bulk storage tanks and other oil storage areas. In general, the areas surrounding the tank loading and unloading areas drain to various parking lots located throughout campus. Parking lots are pitched so that drainage is directed to a stormwater catch basin in most instances. These stormwater catch basins are protected during tank refueling operations. Stormwater outfalls flow into an unnamed tributary to the northeast of the college property or to the municipal stormwater drainage system on State Route 4 on the western boundary of the campus. Page 4

12 4.0 OIL STORAGE INVENTORY HVCC maintains several different petroleum products within aboveground storage tanks, underground storage tanks, 55-gallon drums and elevator hydraulic cylinders. Used oil is also maintained in a 385-gallon double-walled, aboveground storage tank and 55- gallon drums while waste food grease is maintained in grease traps, bins and 55-gallon drums. In addition, HVCC utilizes a total of 20 oil-filled transformers, which are located throughout the campus. Each of the oil storage locations are summarized on Table 1 and are shown on Figure 2. The following sections summarize the facility s oil storage inventory and associated handling operations. 4.1 Oil Storage Facilities Stationary Aboveground Storage Tanks (ASTs) HVCC stores fuel oil (#2), gasoline and diesel fuel within seven (7) aboveground storage tanks located throughout the site. HVCC utilizes a 385-gallon double-walled aboveground storage tank to collect used oil. Each of the aboveground tank locations is noted on Figure 2. A summary is provided below: Area (see Figure 2) Identification/ Storage Unit Product Quantity (gallons) Storage Container Type Williams Hall, room 158 Higbee, east side of building, housed in the generator WIL1 #2 Fuel oil 180 HG-2 Diesel Fuel Cogan Hall, room 153 COG-1 Used Oil 385 Double-walled, aboveground tank constructed of steel 300 Double-walled aboveground tank Double-walled, aboveground tank constructed of plastic Cogen Facility, engine room Lapan Services Building, east side of building Lapan Services Building, east side of building GEN-2 Diesel Fuel 400 LSB-1 Gasoline 2,000 LSB-2 Diesel Fuel 1,000 Aboveground tank constructed of steel located within a steel berm. Aboveground tank constructed of steel and enclosed by a 6 thick concrete vault Aboveground tank constructed of steel and enclosed by a 6 thick concrete vault Administration data center ADM-2 Diesel Fuel 300 Double-walled aboveground tank constructed of steel Each of the aboveground tanks is double-walled and/or is equipped with a concrete berm or steel dike to contain any material released from the tank or spilled during product transfer. Each tank is either located inside a building or equipped with an enclosure to Page 5

13 prevent the accumulation of precipitation with the secondary containment. Product is transferred from tanker trucks into the tanks via hoses. Underground Storage Tanks (USTs) HVCC stores diesel fuel within one (1) underground storage tank located just north of the Electric Generating Plant (Cogen Facility). The tank location is noted on Figure 2. A summary is provided below: Area (see Figure 2) Cogen Facility, north of building Identification/ Storage Unit Product Quantity (gallons) GEN-1 Diesel Fuel 8,000 Storage Container Type Underground, doublewalled fiberglass reinforced plastic tank The tank is constructed of fiberglass reinforced plastic and is double-walled. The tank is equipped with overfill protection with an audible alarm as well as a tank gauging system. GEN-1 supplies the day tank (GEN-2) located in the Cogen Facility with diesel fuel via partially buried, double-walled piping. Product is transferred from a tanker truck into the tank via a hose. Oil Storage in Containers with a Capacity of 55 Gallons or Greater (Other Than ASTs, USTs and Mobile Bulk Storage Containers) Drums of oil are stored in the Grounds Department (Lapan Services Building), Williams Hall and the Cogen Facility. Typically, up to two 55-gallon drums of used oil and one drum of virgin motor oil are stored within the Grounds Department. The drums are stored on 66-gallon capacity spill pallets to prevent a release from a drum. In addition, all used oil drums in use are equipped with a funnel with a lid to minimize spillage during additions. A 3,000-gallon vacuum truck is used to remove the oil from the drums periodically. One 55-gallon drum of used oil is stored within Williams Hall (Room 146). One 55- gallon drum of food grease for biodiesel fuel production is stored in Williams 155 for future biodiesel fuel storage. Two 55-gallon drums of food grease are stored at the Joseph L. Bruno Stadium. The drums at the Joseph L. Bruno Stadium are present from May to September only. Each drum is stored on a 66-gallon capacity spill pallet. A 3,000-gallon vacuum truck is used to remove the oil from the drums periodically. Up to fifteen (15) 55-gallon drums of virgin and used oil are stored in a storage shed located on the North side of the Cogen Facility. The storage shed is equipped with spill containment. 55-gallon drums of oil may be stored on spill pallets within the Cogen Page 6

14 Facility. A box truck is used to deliver the virgin oil and remove the used oil drums periodically. HVCC utilizes three grease traps at the facility that have the capacity to hold greater than 55 gallons of food grease. Two are is located at Joseph L. Bruno Stadium while the third is located in the Campus Center. A 3,000-gallon vacuum truck is used to remove grease from the grease traps at Joseph L. Bruno Stadium periodically. The Campus Center grease trap is inaccessible by vacuum truck. Oil-Filled Electrical, Operating and Manufacturing Equipment HVCC utilizes a total of 20 oil-filled transformers, which are located throughout the campus. Each of the transformers contains mineral oil and range in capacity from 135 to 750 gallons. The locations are shown on the Site Plan (Figure 2). HVCC utilizes five (5) oil/water separators. These units are located in the LaPan Grounds Shop, the Cogan Automotive Lab, the Cogen Facility, the Parking Garage and the Science Center. With the exception of the Science Center elevator separator, these units have the capacity to hold greater than 55 gallons of oil. The oil from these units is periodically removed and each unit is inspected at that time. The locations of the oil/water separators are provided on Figure 2. Oil is stored within six generator engines located within the Cogen Facility. Each generator engine has a 120 gallon capacity. Oil is added to the engines via drums and manual pumps. Hydraulic Oil is used in fifteen (15) elevators located in the Amstuz, Bulmer, Campus Center, Day Care Center, Guenther, Baseball Stadium, McDonough, Marvin, Administration, Parking garage and Science Center buildings. With the exception of the McDonough elevators, all hydraulic elevators hold greater than 55 gallons of oil. Dedicated (Onsite) Mobile Bulk Oil Storage Containers Food grease is stored in a 300-gallon, double-walled steel grease bin located at the Campus Center loading dock area. An outside contractor periodically removes food grease from the bin. Tank Truck Loading/Unloading Areas Tank truck unloading areas for filling each of the aboveground tanks are located throughout the campus adjacent to the tanks. Additional Oil Storage Areas or Oil Handling Activities During any time period, HVCC may have construction projects on-going at the campus. If, during these projects, storage tanks, containers or machinery are being used that have Page 7

15 a capacity of 55 gallons or more, HVCC will describe these storage units in an Addendum included as Appendix C to this plan. Page 8

16 5.0 POTENTIAL SPILL PREDICTIONS, VOLUMES, RATES, AND CONTROL Table 2 describes the potential type of failure(s), estimated amount of material which may be released, the probable flow direction of a spill, should one occur, and the existing secondary containment facility for each area of concern. Potential types of equipment failure include tank overflow, rupture or leakage of the AST or associated piping, and failure of unloading/loading equipment. Page 9

17 6.0 CONTAINMENT AND/OR DIVERSIONARY STRUCTURES OR EQUIPMENT TO PREVENT DISCHARGE The SPCC regulations require that the SPCC Plan describe the spill prevention techniques used to prevent discharged oil from reaching a navigable water course. One or more of the minimum spill prevention standards provided in the regulations must be employed at each potential oil discharge area. In addition to the minimum prevention standards, the regulations require that the SPCC Plan discuss the facility s conformance with applicable spill prevention guidelines listed under 40 CFR Part 112.7(j), other effective spill prevention and containment procedures, or, if more stringent, State rules, regulations and guidance. Appropriate containment and diversionary structures are provided for HVCC s bulk petroleum storage areas. All oil storage containers and associated piping at HVCC are steel, polyethylene plastic, or fiberglass reinforced plastic (FRP) and are compatible with their contents. Each container installation is engineered or updated in accordance with good engineering practices to avoid discharges. Fail-safe engineering devices associated with the on-site containers are listed in Table 1. Details of containment and/or diversionary structures are presented in the following sections. 6.1 Secondary Containment Construction and Volume for Bulk Storage Tanks All bulk storage tank installations provide a secondary means of containment for the entire capacity of the container as well as sufficient freeboard to contain precipitation (where applicable, see Section 7.0 for facility drainage details). Diked areas are sufficiently impervious to contain discharged oil. Table 1 provides detailed information regarding the facility s bulk storage tanks. The table includes construction information, piping information and operation and monitoring information regarding the tanks secondary containment systems. The tank materials and method of construction are compatible with the material stored in the tank and the conditions of storage such as pressure and temperature. The following table provides a summary of each tank s dike construction and/or secondary containment volume: Tank ID WIL1 #2 Fuel Oil HG-2 Diesel Fuel GEN-1 Diesel Fuel GEN-2 Diesel Fuel COG-1 Used Oil Tank Size Containment Construction 180 gals. Double-wall 300 gals. Double-wall Containment Volume >180 gals (>100%) >300 gals (>100%) 8,000 gals. Double-wall >8,000 gals (>100%) 400 gals. Steel containment berm 480 gals (120%) 385 gals. Double-wall >385 gals (>100%) Page 10

18 Tank ID LSB-1 Gasoline LSB-2 Diesel Fuel Admin data center Tank Size 2,000 gals. 1,000 gals. Containment Construction Steel tank encased in reinforced concrete vault Steel tank encased in reinforced concrete vault 300 gals Double-wall Containment Volume >2,000 gals (>100%) >1,000 gals (>100%) >300 gals (>100%) 6.2 Containment and/or Diversionary Structures of Other Oil Storage Areas Oil Storage in Containers with a Capacity of 55 Gallons or Greater (Other Than ASTs, USTs and Mobile Bulk Storage Containers) Drums of oil are stored in the Grounds Department (Lapan Services Building) and Williams Hall. All drums are stored on 66-gallon capacity spill pallets to prevent a release from a drum. In addition, all drums in use are equipped with a funnel with a lid to minimize spillage during filling. Up to fifteen (16) 55-gallon drums of virgin and used oil are stored in a detached storage shed on the North side of the Cogen Facility. The storage shed is equipped with secondary containment and a sump to contain spills. Up to two drums at a time are brought inside the Cogen Facility for staging prior to use and are stored on 4-drum secondary containment pallets. A pump is used to transfer oil from the drums. One drum of oily water is stored in the Cogen Facility. The drum is used to collect steam contaminated with oil from the Cogen engines. The drum is stored on a 66-gallon capacity spill pallet. Two 55-gallon drums of food grease are stored at the Joseph L. Bruno Stadium. The drums at the Joseph L. Bruno Stadium are present from May through September only. Each drum is stored on a 66-gallon capacity spill pallet. HVCC utilizes three grease traps at the facility that have the capacity to hold greater than 55 gallons of food grease. Two are located at Joseph L. Bruno Stadium while the third is located in the Campus Center. All units are located within buildings and any spills would be contained in the building structure. The following table provides a summary of the containment structures associated with other oil storage containers in use at the facility: Page 11

19 Tank ID Drum Storage (Grounds Lapan Services Building) Drum Storage (Williams Hall Rm 155) Drum Storage (Williams Hall Rm 146) Drum Storage (Cogen Facility) Drum Storage Building (N side of Cogen Facility) Drum Storage (Stadium) Container Size 55 gallon drums 55 gallon drum Containment Construction Spill pallet; concrete floor drains to oil water separator Spill pallet, concrete floor; floor drain sealed Containment Volume 66 gals. (120%) 66 gals (120%) 55 gallon drum Spill pallet, concrete floor 66 gals (120%) 55 gallon drums 55 gallon drums Spill pallet; concrete floor drains to oil water separator Spill containment sump 66 gals. (120%) [per drum] 240 gals. (430%) [per drum] 55 gallon drums Spill pallet 66 gals. (120%) Grease trap (Stadium) > 55 gals Building Floor >100% Grease trap (Campus Center) > 55 gals Building Floor >100% Dedicated (Onsite) Mobile Bulk Oil Storage Containers Food grease is stored in a 300-gallon, double walled steel grease bin located at the Campus Center loading dock area. An outside contractor periodically removes food grease from the bin. The bin is located in parking lot area on concrete and any spills would be contained in interstitial space of the double-walled tank. The following table provides a summary of the containment structures associated with the mobile oil storage container in use at the facility: Tank ID Container Size Containment Construction Containment Volume Food Grease Bin 300 gals. Double-walled > 300 gals (>100%) Oil-Filled Electrical, Operating and Manufacturing Equipment HVCC utilizes a total of 20 transformers, which are located throughout the campus. 17 of the 20 transformers in use are located within a containment curb. The curbing is sufficient to contain the entire transformer oil volume. Transformers T1A, T14 and T17 are not located within a curbed area. A release from transformer T1A, T14 or T17 would discharge to the ground. Although two catch basins are located in the area of T1A, one is approximately 20 feet away and in the opposite drainage flow direction while the other is over 50 feet away. Transformer T14 is located in the service yard of Joe Bruno Stadium. A release from Transformer T14 would discharge to the stormwater sewer system via the storm drain located approximately 5 feet away. Transformer T17 is located in the areaway of the Science Center. A release from Transformer T17 would discharge to the stormwater sewer system via the areaway floor drain. Page 12

20 Transformers in use are inspected weekly by the electrician and a written inspection log is completed monthly by the Environmental Health & Safety department for all transformers in use and storage. HVCC personnel (Physical Plant Department electricians) will oversee all transformer loading/unloading procedures. Before loading/unloading, all drains within 50 feet of the substation are covered or otherwise protected to prevent the potential for mineral oil to enter the drain. HVCC utilizes five (5) oil/water separators located in the LaPan Grounds Shop, Cogan Hall Automotive Shop, Parking Garage, CoGeneration Facility and Science Center. With the exception of the Science Center Elevator Pit separator, each of these units has the capacity to hold greater than 55 gallons of oil. The units are all located within a building and any spills would be contained in the building structure. On-Site Machinery Oil is stored within six generator engines located within the Cogen Facility. The generators are located within the Cogen Facility on concrete floors. Any leakage or spillage from the generators would be contained by the facility s concrete floor. All drains in the Cogen Facility are equipped with removable plugs, except when in use. In the unlikely event a release reached a floor drain in the building, all floor drains are connected to an oil/water separator which has greater than a 55-gallon storage capacity. Oil is stored within the hydraulic cylinders of 15 elevators located in the Amstuz, Bulmer, Campus Center, Day Care, Guenther, Stadium, McDonough, Marvin, Administration, Parking Garage and Science Center buildings. Leakage of oil from the elevator cylinders would be discharged to the floor of the elevator pit. The pit would provide containment of the oil; however, oil could mix with any groundwater in the elevator pit and be pumped out to the sanitary drain system by the sump pump. The Science Center elevator pit is equipped with an oil water separator. Tank Truck Loading/Unloading Areas Tank truck loading/unloading areas for filling each of the aboveground tanks are located throughout the campus adjacent to the tanks. Secondary containment is provided by asphalt surfaces in the loading/unloading areas. Any storm drains present in the vicinity of the loading/unloading areas are covered, or spill pans are placed, beneath fittings during loading/unloading operations. Page 13

21 Additional Oil Storage Areas or Oil Handling Activities During any time period, HVCC may have construction projects on-going at the campus. If, during these projects, storage tanks, containers or machinery are being used that have a capacity of 55 gallons or more, HVCC will describe these storage units in an Addendum included as Appendix C to this plan. 6.3 Tank and Container Installation Fail-Safe Engineered Each container installation is engineered or updated in accordance with good engineering practices to avoid discharges. Table 1 summarizes the fail-safe engineering devices associated with the on-site containers. 6.4 Integrity Testing and Inspection of Aboveground Containers The facility conducts a comprehensive visual inspection of the oil storage areas at a minimum monthly frequency, as detailed in Section 10.1 below. In addition to the routine visual inspection, the facility will test each aboveground container to identify any potential integrity problems as detailed in Section 10.1 below. 6.5 Buried or Partially Buried Metallic Storage Tanks HVCC does not maintain any SPCC regulated, buried or partially buried metallic tanks on the site grounds. 6.6 Brittle Fracture SPCC requirements state that field constructed aboveground containers undergoing repair, alteration, reconstruction, or change in service that might affect the risk of discharge or failure due to fracture or other catastrophe must undergo a brittle fracture evaluation. HVCC does not utilize any field constructed storage tanks. API 653 states that the potential for brittle fracture is minimal for tanks with shell thickness less than 0.5 inches. All tanks utilized by HVCC have a thickness less than 0.5 inches. 6.7 Control of Leakage through Internal Heating Coils None of the storage containers at HVCC have internal heating coils. 6.8 Visible Oil Leak Correction from Tank Seam and Gasket Visible leaks are reported to the Physical Plant Department. The leaks are documented in the inspection log, fixed, and any spilled oil is cleaned up. Page 14

22 6.9 Appropriate Position of Mobile or Portable Oil Storage Tanks A mobile food grease bin is located outside of the Campus Center. No other mobile or portable oil storage tanks are utilized at the facility. Page 15

23 7.0 FACILITY DRAINAGE 7.1 Drainage from Diked Oil Storage Areas The secondary containment basins for each of the petroleum tanks are equipped with normally closed and locked manual gate valves, where applicable. It should be noted that Tanks HG-2, WIL-1, GEN-2, COG-1 are located inside buildings or mechanical structures. Tanks LSB-1 and LSB-2 are located within a concrete vault. No precipitation is expected to accumulate within these containment basins. Tanks with Covered Diked Areas Tanks HG-2, GEN-2, WIL-1, and COG-1 are located inside buildings or mechanical structures. Tanks LSB-1 and LSB-2 are located within a concrete vault. No precipitation is expected to accumulate within the interstitial spaces. The interstitial space, however, is monitored monthly. Curbed Transformers HVCC utilizes a total of twenty transformers. All transformers in use are located on concrete pads. Seventeen of the twenty pads are curbed with concrete and the area between the curb filled with rocks. The precipitation is collected within the rock area and allowed to drain slowly from the area. Any oil that would be released would be contained within the rock area until it could be cleaned up within a short time period. All transformers are inspected weekly by the electrician and a written inspection log (Appendix E) is completed monthly by the Environmental Health & Safety department. HVCC personnel (Physical Plant Department electricians) will oversee all transformer loading/unloading procedures. Before loading/unloading, all drains within 50 feet of the substations are covered or otherwise protected to prevent the potential for mineral oil to enter the drain. 7.2 Drainage from Undiked Oil Storage Areas Undiked Truck Unloading Areas Each of the facility s outdoor oil truck unloading areas is undiked. The potential for oil to accumulate or otherwise be present in this area will arise primarily from leakage or spillage during active truck unloading operations. As described in Section 9 below, the truck unloading activity is continuously monitored by facility personnel. All truck unloading areas are either paved with asphalt or concrete. For those locations where a stormwater drain is present in the immediate vicinity of an unloading area (HG-2, LSB-1, LSB-2, ADM-2), either a catch basin cover is in place or spill pans are placed beneath fittings during unloading. In addition, an Oil Delivery/Pick-Up Log (Appendix F) is filled out every time a delivery is made. Page 16

24 In the event that oil leakage or spillage occurs during the active transfer operation, facility personnel will immediately implement oil spill response procedures (Section 13 below). Oil spill booms and/or absorbent materials will be used to control the oil and/or drainage that may contact the oil. Secondary containment of the area will be provided by the placement of the oil spill booms or equivalent measures to divert oil away from local drainage courses and structures. Oil absorbent materials will be used to cleanup and remove the released oil. Final cleanup and housekeeping measures will be provided to the extent necessary to ensure that no residual oil remains that could adversely impact subsequent drainage from the area. These measures may include triple-flushing the area or other methods. Under no circumstances shall visibly contaminated rainwater (i.e. sheen on the water) be discharged. Undiked Truck Loading Areas Each of the facility s outdoor oil truck loading areas (vacuum truck and drum delivery) for removal of waste oil are undiked. The potential for oil to accumulate or otherwise be present in this area will arise primarily from leakage or spillage during active truck loading operations. As described in Section 9 below, the truck loading activity is continuously monitored by facility personnel. All truck loading areas are either paved with asphalt or concrete. For those locations outdoors where a stormwater drain is present in the immediate vicinity of a loading area, either a catch basin cover is in place during unloading or spill pans are placed beneath fittings. In addition, an Oil Delivery/Pick-Up Log (Appendix F) is filled out every time a pickup is made. In the event that oil leakage or spillage occurs during the active transfer operation, facility personnel will immediately implement oil spill response procedures (Section 13 below). Oil spill booms and/or absorbent materials will be used to control the oil and/or drainage that may contact the oil. Secondary containment of the area will be provided by the placement of the oil spill booms or equivalent measures to divert oil away from local drainage courses and structures. Oil absorbent materials will be used to cleanup and remove the released oil. Final cleanup and housekeeping measures will be provided to the extent necessary to ensure that no residual oil remains that could adversely impact subsequent drainage from the area, which may include triple-flushing the area or other methods. Under no circumstances shall visibly contaminated rainwater (i.e. sheen on the water) be discharged. All other loading areas are located inside or under cover. Any spills from the loading activities will be contained in the building s concrete walls and floor. In the unlikely event that a release reaches a floor drain in the building, all floor drains present in loading areas are either connected to an oil/water separator which has a capacity of greater than 55 gallons or the drain is plugged during loading activities. Uncurbed Transformer As noted above, HVCC has a total of twenty transformers, all but one are located on concrete pads. Although seventeen of the twenty pads are surrounded by gravel and are Page 17

25 bermed, three transformers are not located within a curbed area (T1A, T14 and T17). A release from transformer T1A would discharge to the ground. Although two catch basins are located in the area of T1A, one is approximately 20 feet away and in the opposite drainage flow directions while the other is over 50 feet away. Transformer T14 is located in the service yard of Joe Bruno Stadium. A release from Transformer T14 would discharge to the stormwater sewer system via the storm drain located approximately 5 feet away. Transformer T17 is located in the areaway of the Science Center. A release from Transformer T17 would discharge to the stormwater sewer system via the areaway floor drain. Transformers in use are inspected weekly by the electrician and a written inspection log is completed monthly by the Environmental Health & Safety department. HVCC personnel (Physical Plant Department electricians) will oversee all transformer loading/unloading procedures. Before loading/unloading, all drains within 50 feet of the substation are covered or otherwise protected to prevent the potential for mineral oil to enter the drain. Mobile Storage Container Food grease is stored in a 300 gallon, double walled steel grease bin located at the Campus Center loading dock area. An outside contractor periodically removes food grease from the bin. The potential for food grease to accumulate or otherwise be present in this area will arise primarily from leakage or spillage during active truck loading operations. The bin is located in a parking lot area on pavement and any spills would be to the pavement. Other Undiked Oil Management Areas Drainage from all other undiked areas, such as where piping is located outside containment walls or drum storage areas, would discharge to either interior building floors or pavement. For those locations which are inside or in protected areas of the facility, precipitation is not anticipated to accumulate. Depending on the location of indoor storage areas, an interior drain could discharge to the sanitary or storm sewer. However, drains within Cogan Hall, the Physical Plant and the Cogen Facility, where oil drums are stored, discharge to oil/water separators, which provide wastewater treatment prior to discharge to the sanitary or storm sewer. All floor drains near petroleum storage areas are equipped with removable plugs. Undiked areas which are not indoors or otherwise covered are inspected monthly. 7.3 Drainage from Other Oil Storage Areas Construction Projects During any time period HVCC may have construction projects on-going at the campus. It is possible that during these projects storage tanks, containers or machinery will be used that have a capacity of 55 gallons or more. Since these storage units are temporary, HVCC will describe these storage units, spill prediction Page 18

26 scenarios, and administrative and engineering controls (including drainage controls) in an Addendum included as Appendix C to this plan. Page 19

27 8.0 FACILITY OIL TRANSFER OPERATIONS 8.1 Buried Piping Installation Protection and Examination A portion of the piping that connects Tank GEN-1 to GEN-2 is located underground. The underground portion is double walled and sloped towards the underground storage tank. This piping system is checked weekly for physical evidence of failure. No other buried piping is associated with the petroleum bulk storage at HVCC. 8.2 Not-In-Service and Standby Service Terminal Connections Terminal connections are capped or blank-flanged at the transfer point and the origin marked when piping is not in service or is in standby service for an extended time. 8.3 Pipe Support Designs Pipe supports are designed to minimize abrasion and corrosion and allow for expansion and contraction. 8.4 Aboveground Valve and Pipeline Examination Aboveground valves, piping, and appurtenances associated with ASTs are inspected during routine monthly inspections. Records of these inspections are documented in an inspection log. During the inspections, the general condition of items, such as flange joints, expansion of joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces are documented in the inspection log and deficiencies are corrected in a timely manner. The inspection logs are located in Appendix E. 8.5 Aboveground Piping Protection from Vehicular Traffic Piping locations within the plant are in locations away from vehicular traffic. 8.6 Filling of Facility Fleet Vehicles Tanks LSB-1 and LSB-2 store gasoline and diesel fuel which is used to re-fuel HVCC fleet vehicles. As needed, vehicles are filled from these tanks using flow control valves which require the presence of the vehicle operator to make the transfer. The transfer lines are clearly marked. Page 20

28 9.0 FACILITY TANK TRUCK UNLOADING As needed, aboveground and underground storage tanks are filled from tanker trucks. The tank truck unloading operations comply with the SPCC prevention and controls listed under 40 CFR 112.8(h). It is noted that none of the unloading operations are considered to be occurring at loading/unloading racks. Consequently, the loading/unloading rack requirements specified in 40 CFR 112.7(h) do not apply. However, the minimum standard operating procedures described in the following sections are utilized for all unloading operations that occur at the facility. 9.1 Minimum Standard Operating Procedures Tank truck unloading activities meet the minimum requirements of the U.S. Department of Transportation and include, at a minimum, the following standard operating procedures: (a) Appropriate facility personnel are notified when a tank truck unloading event will take place, prior to initiation. (b) Obtain and fill out a Oil Delivery/Pick-Up Log (Appendix F) (c) No smoking is allowed during the active tank truck unloading event. Fire/hot work is kept away from the unloading area at all times. (d) Tank truck unloading operations are conducted only in the area specifically designated for that purpose and portable catch basin covers are placed over drains prior to initiation of oil transfer, where required. (e) All hoses are inspected for evidence of deterioration or cracks. (f) Each tank truck unloading event is directly attended and continuously monitored by the truck driver and by an appropriate facility employee. These personnel will take immediate actions to stop the flow of oil when the working capacity of the receiving tank (designated as approximately 90% of the tank capacity) has been reached or in the event that an equipment failure or emergency occurs. (g) The tank truck hand brake is set throughout the duration of the tank truck unloading event. The facility employee checks if active wheel blockage of the tank truck is necessary, prior to initiation of the active unloading event, to preclude motion of the tank truck during the unloading event. If required to preclude tank truck motion, the employee ensures that appropriate wheel blockage, such as wheel chocks, is first provided and firmly set. (h) The facility employee ensures that drip pans or buckets or oil absorbent pads are placed beneath all hose connections that may be prone to leakage, prior to initiation of the tank truck unloading event. (i) The tank truck unloading event does not begin until the level in the receiving tank is checked and confirmed to have sufficient available volume, based on the working capacity of the receiving tank (90% of design capacity) to receive the volume of oil intended to be unloaded. Page 21

29 (j) Throughout the active transfer process, each person (truck driver and employee) remains alert and retains an unobstructed view of the truck, delivery hoses and storage tank, to the maximum extent practicable. Unless the truck engine is used for operation of the transfer pump, no flammable oil material is unloaded while the engine is running. No traffic or unauthorized personnel are permitted to enter the shipment area during fueling. (k) The drain/transfer valve on the truck is closed and the transfer line is fully drained back to the tank truck prior to disconnecting the transfer line. The tank manway is closed and locked. (l) Any leakage or spillage arising from the completed unloading event is fully cleaned up with oil absorbent material and properly disposed of. 9.2 Secondary Containment Provisions for the Tank Unloading Area The potential for oil to accumulate or otherwise be present in the unloading area will arise primarily from leakage or spillage occurring during the active truck unloading operation. As described in Section 9.1 above, the truck unloading activity is continuously monitored by facility personnel. Drip pans or buckets or oil absorbent pads are placed beneath all hose connections that may be prone to leakage, prior to initiation of the tank truck unloading event. Where necessary, a portable catch basin cover is moved in place prior to initiation of oil transfer in areas where catch basins are in close proximity. In the event that oil leakage or spillage occurs during the active transfer operation, facility personnel will immediately implement its spill response procedures (Section 13 below). Oil spill booms and/or absorbent materials will be used to control the oil and/or drainage that may contact the oil. Additional secondary containment of the immediate area will be provided by prompt placement of oil spill booms or by implementation of equivalent measures. Oil spill booms or equivalent measures will be used to either directly contain the oil and/or to divert the oil away from drainage courses and structures. Oil absorbent materials will be used to clean up and remove the released oil. Final cleanup and housekeeping measures will be used to the extent necessary to ensure that no residual oil remains that could contact and adversely impact subsequent drainage from the area. These measures may include triple-flushing the area or other methods. Under no circumstances shall visibly contaminated rainwater (i.e. sheen on the water) be discharged. Information regarding the type and quantity of oil spill booms, oil absorbent materials and other spill response materials and equipment maintained onsite by the facility, as well as the onsite storage areas for these materials, is provided in Section 13. Page 22

30 10.0 INSPECTIONS, TESTS AND RECORDS 10.1 Routine Visual Inspection Program and Facility Maintenance The facility s oil storage and oil handling areas are visually inspected at a minimum frequency of once per month by the facility s SPCC Coordinator or his designee. A typical inspection log sheet which is used for this purpose is provided in Appendix E. In general, all oil storage and oil handling areas are visually inspected for signs of equipment deterioration and leaks which might cause a spill and/or discharge. The more detailed inspection components applicable to the facility s oil storage and handling are indicated on the inspection form. Any deficiencies identified during the visual inspection program are promptly repaired; deficient equipment is drained of oil and taken offline if necessary to accommodate the required repairs. Documentation of adequate response measures for all deficiencies identified during the visual inspection is maintained together with the completed inspection logs. In addition to response measures provided as a result of the monthly inspection program, at all times, discharges which are observed to result in a loss of oil from any container, including, but not limited to seams, gaskets, piping, pumps, valves, rivets, and bolts are promptly corrected. The facility s routine preventative maintenance program for oil equipment includes performing regularly scheduled equipment maintenance, conducting routine inspections, maintaining appropriate types and quantities of spill response equipment and materials and maintaining good housekeeping conditions. Each aboveground container is inspected on a regular schedule for potential integrity problems and whenever repairs are made. A regular schedule for periodic tank inspections is provided below. Visual inspections are combined with another testing technique (i.e. interstitial monitoring, hydrostatic testing). Tank ID Testing Frequency Testing Method Interstitial Monitoring WIL-1 Monthly (see tank directions) #2 Fuel Oil Visual HG-2 Interstitial monitoring Monthly Diesel Fuel Visual GEN-1 Diesel Fuel Monthly Leak Detection System Testing GEN-2 Diesel Fuel Monthly Visual COG-1 Monthly Visual (interstitial space Used Oil LSB-1 Gasoline ADM-2 Monthly Monthly translucent) Interstitial monitoring Visual Interstitial Monitoring Visual Page 23

31 Tank ID Testing Frequency Testing Method LSB-2 Interstitial monitoring Monthly Diesel Fuel Visual Drum Storage (Grounds) Monthly Visual Drum Storage (Cogan & Willams) Monthly Visual Drum Storage (Cogen Building) Monthly Visual Drum Storage (CoGen Storage Shed) Monthly Visual Drum Storage (Stadium) Monthly Visual In addition, frequent inspections must be conducted of the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas. Records of inspections and tests must be maintained on-site (see Appendices D and E for example monthly inspection logs). Although not specifically required, oil/water separators are visually inspected annually at the time of cleanout. In addition, transformers are visually inspected monthly Records The following records are maintained for a minimum period of three years as part of this SPCC plan: (a) Completed inspection sheets for the monthly visual inspection program (Section 10.1 above). (b) Documentation of major repairs and/or upgrades made to the tanks or secondary containment structure, as provided in response to deficiencies identified by the monthly visual inspection program. (c) Documentation of employee training in the SPCC plan (Section 12 below) Historical Spills Seven oil spills have been reported to the NYS DEC since the date of the previous SPCC Plan update. A brief description of each spill follows. On September 12, 2011 approximately 10 gallons of food grease spilled from the trash compactor outside of the Campus Center due to grease being improperly disposed of in the compactor. The source of the grease was not identified but Cafeteria and Valley Cats staff were reminded of the need to dispose of grease in grease collection tanks or drums. On July 5, 2012 food grease was discovered in the stormwater catchbasins located outside of the Joe Bruno Stadium. The grease was presumed to have originated from the Valley Cats concession operations. Approximately 300 gallons of grease and discolored Page 24

32 water was pumped out of the catch basins. Stormwater and food waste disposal procedures. Valley Cats staff were retrained on On July 19, 2012 a failure of the Bulmer Technology Center elevator s hydraulic cylinder led to a spill of approximately 110 gallons of hydraulic oil. Most of this oil was contained within a PVC liner within the cylinder casing and later recovered for treatment and disposal. On December 14, 2012, a failure of a hydraulic lift operated by a contractor spilled approximately gallons of hydraulic oil over an area of approximately 500 square feet. The oil was spilled entirely on the asphalt parking lot surface and was not observed to have reached any soils, storm drains or unpaved surfaces. The oil was cleaned up with absorbant and the area scrubbed with simple green. Recovered oil and clean-up materials were sent for treatment and disposal. On January 23, 2014 a spill of frozen oily water was discovered outside of the Cogeneration Plant Building. At the time of the spill, PVC piping extended from the cogeneration engines to a 55 gallon drum outside of the building. Steam containing an oily mist residue was transported through the piping to a collection drum outside of the building. Due to low temperatures, the water in the drum froze and pushed a portion of the contents out. A frozen oil/water mix was observed at the PVC piping, on top of the drum and on the ground. It is estimated that less than ½ gallon of frozen water reached the ground. The frozen oil/water mix was cleaned up and the piping and drum has since been rerouted within the Cogeneration Plant building and the drum placed on a secondary containment pallet. On January 31, 2014 a spill of hydraulic fluid occurred on the paved parking lot outside of the LaPan Physical Plant Building. A hydraulic line on a backhoe ruptured, spilling hydraulic fluid onto the parking lot. The spill was less than 5 gallons, was cleaned up immediately with Speedi Dry and no fluid reached the storm drain system. Spills or releases above the reportable quantity will be reported and properly documented as outlined in Section 13 of this Plan. Page 25

33 11.0 SECURITY Current regulations pertaining to security measures required by a facility subject to SPCC regulations are set forth in 40 CFR 112.7(e)(9). Specifically, these regulations state: (i) (ii) (iii) (iv) (v) All plants handling, processing, and storing oil should maintain locked entrance gates and/or be guarded when the plant is not in production or is unattended; The master flow and drain valves and any other valves that will permit direct outward flow of the tank's content to the surface should be securely locked in the closed position when in non-operating or non-standby status. The starter control on all oil pumps should be locked in the "off" position or located at a site accessible only to authorized personnel when the pumps are in a non-operating or non-standby status. The loading/unloading connections of oil pipelines should be securely capped or blank-flanged when not in service or standby service for an extended time. This security practice should also apply to pipelines that are emptied of liquid content either by draining or by inert gas pressure. Facility lighting should be commensurate with the type and location of the facility. Considerations should be given to: (A) discovery of spills occurring during hours of darkness, both by operating personnel, if present, and by non-operating personnel (the general public, local police, etc.) and (B) prevention of spills occurring through acts of vandalism. Prevention of unknown entry and access to HVCC is accomplished by several methods such as: All Buildings are locked after normal college hours; The Cogen Facility is locked at all times and accessible by only designated personnel; The diesel generator housing Tank HG-2 is locked at all times and only accessible by designated personnel; All loading/unloading connections are locked when not in service; Campus has sufficient lighting to promote adequate security; and Department of Public Safety of HVCC patrols the campus 24 hours a day 7 days a week. Page 26

34 12.0 PERSONNEL TRAINING All facility personnel involved in the handling of oil are properly trained in general facility operations, applicable oil pollution control laws, rules and regulations, operation and management of equipment to prevent discharges, discharge (spill) response procedures and protocols, and the contents and requirements of this SPCC Plan. The training highlights past spill or discharge incidents at the facility, past equipment failures, component malfunctions, and any recently developed precautionary measures. Training is coordinated by the Director of Environmental Health and Safety. New employees involved with the handling of oil receive training initially upon job assignment. Refresher training is provided on an annual basis for all employees involved with the handling of oil to ensure that on-site personnel have an adequate understanding of the SPCC Plan for the facility. Appendix G provides a typical outline of the training provided to facility employees. All training sessions are documented and the documentation is retained as part of this SPCC Plan for a minimum of three years. HVCC is responsible for properly training, at a minimum, their oil handling personnel on the following subjects: The operation and maintenance of equipment to prevent the discharge of oil; Oil discharge procedure protocols; Applicable pollution control laws, rules, and regulations; and The contents of this plan. This training shall be conducted initially upon job assignment. In addition, HVCC will schedule and conduct spill prevention briefing on at least an annual basis to ensure that on-site personnel have an adequate understanding of the SPCC Plan for the facility. Such briefings will highlight and describe known spill events and failures, malfunctioning components, and recently developed precautionary measures. The Director of Environmental Health and Safety will be responsible for coordinating these activities. Page 27

35 13.0 SPILL RESPONSE PROCEDURES 13.1 Spill Response Equipment The following general spill control equipment is maintained at the facility, in close proximity to each storage tank, for responding to spill incidents: Oil absorbent pads/booms Granular absorbent material Hand tools (shovel, broom, etc.) Gloves Caution Tape A list of HVCC s specific spill abatement equipment and materials is provided in the following table: Spill Equipment Use Location Spill mats to cover storm drains Empty drum To seal storm drains Storage of used spill response materials Grounds, Higbee Hall Grounds, Cogen Facility, Cogan Hall Curb Oil Grate Guard Spill Pans To cover curb storm drain To place beneath connections during unloading operations Higbee Hall Lapan Services Building Spill socks, pads To place around storm drain Admin mechanical room 13.2 Spill Response Procedures In the event of a spill or release, the emergency procedures outlined in Appendix H will be implemented. A copy of the emergency procedures should be in or near the Emergency Coordinator's and the Emergency Coordinator's alternates office and the Office of Public Safety. Any HVCC employee or student who discovers a spill or release should contact the Office of Public Safety immediately. The emergency spill phone number is clearly posted near all oil storage tanks/areas (Appendix I).The procedures include a listing of emergency contact numbers. The Office of Public Safety shall contact the Emergency Coordinator or alternate immediately. If the Emergency Coordinator believes the spill or release cannot be handled by on-site personnel and may be a threat to either human health or the environment, a professional spill response company listed in Section 4.1(3)f should be contacted. The HVCC Physical Plant staff Page 28

36 shall be responsible to carry out the procedures outlined herein under the direction of the Emergency Coordinator, Richard Edwards (Director, Physical Plant) Methods of Disposal of Recovered Materials As indicated in the facility s spill response procedures (Appendix H), all materials recovered from oil spill response measures will be appropriately containerized and labeled as to contents, date and nature of organization, etc. The facility will make a hazardous waste evaluation of the containerized waste in accordance with the requirements of state and federal regulations as applicable. In the event that the material is determined to be a regulated hazardous waste, it will be managed and disposed of in accordance with the appropriate requirements of 6 NYCRR Part 374 and 376 and other applicable regulations (if required), including manifesting of the hazardous waste. In the event that the recovered material is determined to be non-hazardous, it will be managed as part of the facility s routine non-hazardous waste stream Spill Incident Reporting It is the Director of EHS or designee s responsibility to determine if the spill is reportable and to report the spill, if required. If the Director of EHS determines that the spill is reportable, the following notifications must be made: 1. NYSDEC Petroleum spills must be reported to the New York State Department of Environmental Conservation (NYSDEC) Spill Hotline at unless they meet the following criteria: The spill is known to be less than 5 gallons; and The spill is contained and under control; and The spill has not and will not reach the State s waterways or any land; and The spill is cleaned up within 2 hours of discovery. If the spill is reportable, it must be reported within 2 hours to the New York State Department of Environmental Conservation Spill Hotline (518) The following information must be provided to the DEC: Name and telephone number of reporter; Name and address of facility; Time and type of incident (e.g., spill, tank failure, etc.); The location of the release or threat of release; Name and quantity of material(s) involved, to the extent known; Page 29

37 The possible hazards to human health or the environment outside the facility; The extent of injuries, if any; and A description of actions taken or proposed to be taken in response to the release or threat of release. The following will occur when a spill is reported to the NYS DEC: A 24-hour dispatcher will answer and ask a series of questions as outlined above. The dispatcher will provide a spill number. The dispatcher will not offer any guidance on response or clean up. After you hang up, the dispatcher will contact a NYS DEC Spill Engineer to report the information. Depending on the severity or extent of the incident, the NYS DEC Spill Engineer will call back to discuss the incident and response. A spill that goes off-site or a large spill will likely trigger an immediate visit from the NYS DEC Spill Engineer and other state spill response personnel. Record details of all calls made or received. 2. National Response Center In addition to reporting the spill to the NYS DEC, you must report to the National Response Center (NRC) if the spill meets one of these criteria: a) a discharge of oil into, or upon the navigable waters* of the United States or adjoining shoreline in harmful quantities has occurred. Harmful quantities are defined as a discharge that violates applicable water quality standards or causes a sheen upon, or discoloration of, the surface water or adjoining shoreline; or b) a discharge in a quantity over 1,000 gallons has occurred, whether it is contained or not contained. *A navigable waterway is defined in 40 CFR Part 112.2(k) as an interstate waterway or intrastate waterway including lakes, rivers, and streams, which may be utilized by interstate travelers for recreational purposes. Navigable waters may also be defined as lakes, rivers, or streams from which fish or shellfish are taken. In the event that such a discharge of oil upon navigable waters occurs, the facility s designated employee accountable for oil spill prevention (Section 2.2 above), or his designee, is to be notified immediately. The designated employee, or his designee, will then immediately notify the National Response Center (NRC) at CFR part will be further consulted for Page 30

38 appropriate notification procedures in the event that direct reporting to the NRC is not practicable. The following will occur when a spill is reported to the NRC: A call to the NRC will be very similar to NYS DEC. Depending on the extent or severity of the incident, an EPA representative may call you back. Inform the NRC that you have already contacted NYSDEC and that clean up is underway or completed. 3. Local and Campus Authority In the event the Emergency Coordinator determines that the release of materials threatens human health outside the facility, Campus Public Safety and local authorities must be notified if evacuation of local areas is advised: 13.5 Follow-up Reporting Campus Public Safety Phone: (from campus phone) Troy Local Police Emergency: 911 Phone: State Police Phone: Troy Fire Department Emergency: 911 Phone: Hospital Emergency: 911 Ambulance Emergency: NYSDEC If a spill is reported to the NYSDEC, it is important that HVCC provide documentation to the NYSDEC Spill Engineer so that the Spill File can be closed. Prior to submitting information, HVCC should contact the NYSDEC Spill Engineer to determine what information must be submitted. Typically, to close a spill file, the following information must be submitted to the Spill Engineer: Spill Number and facility where spill occurred; Date of Spill; Type of material and amount spilled; Page 31

39 Amount of spilled material recovered; Location and nature of spill (i.e. tank overfill, leaking tank, etc.); Actions taken to contain spilled material, recover material, and remove contaminated media (i.e. soil, groundwater, etc.); and Additional actions required. 2. USEPA If the spill exceeded 1,000 gallons or impacted a navigable waterway, the Director of EHS must report the event(s) to the following agency within 60 days: The Regional Administrator U.S. Environmental Protection Agency 290 Broadway New York, New York The EPA report must include: a. Name of the facility; b. Name(s) of the owner or operator of the facility; c. Location of the facility; d. Date and year of initial facility operation; e. Maximum storage or handling capacity of the facility and normal daily throughput; f. Description of the facility, including maps, flow diagrams, and topographical maps; g. A complete copy of the SPCC Plan with any amendments; h. The cause(s) of such spill, including a failure analysis of system or sub-system in which the failure occurred; i. The corrective actions and/or countermeasures taken, including an adequate description of equipment repairs and/or replacements; j. Additional preventive measures taken or contemplated to minimize the possibility of recurrence; and k. Such other information as the Regional Administrator may reasonably require pertinent to the Plan or spill event SPCC Plan Amendment by the Regional Administrator In the event that the facility has discharged more than 1,000 gallons of oil in a single discharge in harmful quantities into or upon the navigable waters of the U.S. or adjoining shorelines, or discharged more than 42 gallons of oil in each of two discharges in harmful quantities into or upon the navigable waters of the U.S. or adjoining shorelines within any twelve month period, the facility must submit the following information to the Regional Administrator within 60 days from the time that the facility exceeds these discharge thresholds: Page 32

40 (1) name of facility (2) name of personnel providing this information (3) location of facility (4) maximum storage or handling capacity of the facility and normal daily throughput (5) corrective action and countermeasures that have been taken by the facility, including a description of equipment repairs and replacements (6) an adequate description of the facility, including maps, flow diagrams and topographical maps, as necessary (7) the cause of such discharge(s), including a failure analysis of the system or subsystem in which the failure(s) occurred (8) additional preventative measures that the facility has taken or contemplated to minimize the possibility of recurrence (9) such other information as the Regional Administrator may reasonably require pertinent to this SPCC Plan or discharge The facility will also submit this specific information to the New York State Department of Environmental Conservation (DEC). Following submittal of this information, the facility will appropriately amend this SPCC Plan as may be specified by the Regional Administrator and/or the DEC, in accordance with the requirements and procedures of 112.4(f) Liability Spills of oil or designated hazardous substances from on-shore facilities and vessels must be reported immediately. Under the Clean Water Act (CWA), unless the spill is shown to have resulted from an act of God, negligence of the Federal Government, or act of omission of a third party, an on-shore discharger may be assessed a Class I penalty of up to $10,000 per violation (up to a maximum assessment of $25,000) or a Class II penalty of up to $10,000 per day of violation (up to a maximum assessment of $125,000). Failure to report a spill immediately to the National Response Center is punishable by a criminal fine of up to $10,000 and imprisonment of up to one year. An owner or operator of any on-shore or off-shore facility from which petroleum products or a hazardous substance is discharged in harmful quantities is liable for the actual costs incurred by the United States Government (not to exceed $50,000,000) unless the discharge was caused solely by: an act of God; an act of war; negligence on part of the United States Government; or an act or omission of a third party. Page 33

41 14.0 STATE RULES, REGULATIONS AND GUIDELINES FOR OIL DISCHARGE, PREVENTION AND CONTAINMENT This plan is designed to comply with federal SPCC requirements found in 40 CFR Part 112. There are currently no general SPCC requirements promulgated by the State of New York. Petroleum storage facilities are regulated in New York State under the regulations listed below New York State Registration of Petroleum Storage Facilities (6 NYCRR Part 612) 612.1(b) states that Part 612 applies to all petroleum storage facilities with a combined storage capacity over eleven hundred (1,100) gallons. The facility has a petroleum storage capacity of greater than 1,100 gallons and therefore, Part 612 is applicable to the facility (c) specifies that the owner must register any new facility with the department before it is placed in service (e) states that, within 30 days prior to substantially modifying a facility, the owner must notify the department of such modification on forms supplied by the department (a) states that the owner must submit with each application for registration or registration renewal, a five-year fee. Based on the storage capacity, the fee for the facility is $500 per five-year period (b) states that any new facility or modification to an existing facility registered under this Part must comply with requirements of Part 614, Standards for New and Substantially Modified Petroleum Storage Facilities New York State Handling and Storage of Petroleum (6 NYCRR Part 613) 613.3(c)(3)(ii) requires the design capacity, working capacity and PBS identification number to be clearly marked on the tank and at the gauge (c)(4) requires all fill pipes leading to a pump-filled petroleum tank to be equipped with a properly functioning check valve (or equivalent device) which provides automatic protection against backflow, if the piping arrangement of the fill pipe is such that backflow from the receiving tank is possible 613.3(c)(5) requires that each tank connection through which oil can normally flow to be equipped with an appropriate operating valve to control the flow (c)(6)(i) and (ii) specifies location and tank capacity thresholds over which an aboveground tank must be equipped with a secondary containment system. Minimum design standards for such secondary containment systems are also specified by these sections (c)(6)(iii) outlines minimum requirements for management of stormwater accumulated within a tank secondary containment system. These Page 34

42 requirements are incorporated into the facility s procedures for management of stormwater accumulated within diked storage areas (Section 7 above) (c)(6)(iv) details water quality thresholds for the possible discharge of stormwater accumulated in a tank secondary containment system. These requirements are incorporated into the facility s procedures for management of stormwater accumulated within diked storage areas (d) specifies that the facility must maintain all gauges, valves and other equipment for spill prevention in good working order outlines inventory monitoring requirements for USTs outlines testing and monitoring requirements for USTs (a) specifies that aboveground storage tanks must be inspected at least monthly for specified items. These requirements are incorporated into the facility s AST inspection program (Section 10 above) (b) outlines requirements for ten-year inspections of specified ASTs. All ASTs at the facility are exempt because they are entirely aboveground (c) outlines requirements for maintenance of inspection records including minimum inspection information that must be recorded. These requirements are incorporated into the facility s AST inspection program (Section 10 above) (d) specifies minimum response measures that must be promptly taken in the event that inspections of ASTs reveal deficiencies. These requirements are incorporated into the facility s AST inspection program (Section 10 above) (e) specifies that if any portion of a facility is not inspected, then the un-inspected portion of the facility must be taken out of service details requirements for closure of out of service tanks New York State Handling and Storage of Petroleum (6 NYCRR Part 613) details the requirements for new USTs including label requirements, wear plates, pressure testing of new tanks, and tank construction. The UST in use at the facility meets all the requirements of this section requires minimum standards for secondary containment of USTs. The UST in use at the facility meets all the requirements of this section outlines monitoring requirements for new USTs. These requirements are incorporated into the facility s UST inspection program (Section 10 above) describes the requirements for reconditioning of a steel UST. The UST in use at the site is constructed of fiberglass-reinforced plastic; as such, this section does not apply outlines the guidelines for the installation of underground facilities. The UST in use at the facility meets all the requirements of this section details minimum design standards for new ASTs details minimum requirements for impermeable barriers under tank bottoms. Page 35

43 specifies requirements for monitoring systems for new ASTs specifies requirements for repairing and reconditioning ASTs details requirements for installation of new ASTs specifies requirements for new underground piping systems. Page 36

44 FIGURES

45 80 Vandenburgh Avenue Troy, NY

46

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