SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN

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1 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN Rose-Hulman Institute of Technology Main Campus, South Campus, South Campus West & Oxbridge

2 Table of Contents SECTION 1.0 Purpose 2.0 Regulatory Reference 3.0 Scope 4.0 Responsibility 5.0 Plan Review, Certification, & Evaluation 6.0 Worker Attendance 7.0 Informed Employees 8.0 Facility Layout 9.0 Drainage Pathways and Distance to Navigable Waters 10.0 Spill Response, Emergency Procedures, and Reporting 11.0 Routine Containment Drainage 12.0 Inspections and Records 13.0 Training 14.0 Security 15.0 Management Approval and Certification Appendices A. Emergency Contacts B. Facility Layout C. Emergency Generators D. Above Ground Storage Tanks E. Under Ground Storage Tanks F. Transformers G. Elevators

3 1.0 Purpose Office of Environmental Health & Safety Spill Prevention, Control, and Countermeasure Plan The Rose-Hulman Institute of Technology Spill Prevention, Control, and Countermeasure (SPCC) Plan is intended to provide Rose-Hulman employees a written plan which describes the equipment, manpower, procedures, and adequate countermeasures for preventing and controlling oil discharges. 2.0 Regulatory Reference EPA s 40 CFR Part Scope This plan is applicable to all operations where employees may be exposed to potential discharge situations under normal working conditions or during an emergency situation. 4.0 Responsibility The Manager of Environmental Health & Safety and Rose-Hulman Institute of Technology is responsible for this plan and for ensuring the plan is available to the EPA Regional Administrator for on-site review during normal working hours. Copies of the written plan are located at the Office of Environmental Health & Safety in the Department of Facilities. This plan is also available on the Office of Environmental Health & Safety website. The Manager of Environmental Health & Safety is responsible for developing and maintaining the plan. The facility owner name, address, and telephone is as follows: Rose-Hulman Institute of Technology 5500 Wabash Avenue Terre Haute, IN The facility contact related to this plan is: Jacob E. Campbell Manager, Environmental Health & Safety Additional contact related to this plan is: Office of Public Safety John Wolfe Director, Public Safety

4 5.0 Plan Review, Certification, and Evaluation The plan will be reviewed and self-certified as described in accordance with Section Rose-Hulman Institute of Technology will amend this SPCC Plan in accordance with Section and other applicable Section of Part 112, when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge. The amendment will be prepared within six months of the change. Examples of changes that may require amendment to the plan include, but are not limited to: Commissioning or decommissioning containers Replacement, reconstruction, or movement of containers Reconstruction, replacement, or installation of piping systems Construction or demolition that might alter secondary containment structures. Rose-Hulman Institute of Technology reviews this plan as required by the Regional Administrator of the EPA. Amendments are then prepared within six months of the review. Any technical amendments to our plan will be self-certified. Non-technical amendments such as changes to names and telephone numbers are not required. 6.0 Worker Attendance Rose-Hulman Institute of Technology is normally attended by workers at least four hours per day. 7.0 Informed Employees As a result of proper plan maintenance, our employees will be informed of the equipment, manpower, procedures, and steps to prevent and control a discharge. 8.0 Facility Layout and Important Emergency Contacts The physical layout of Rose-Hulman Institute of Technology can be found in Appendix B. Emergency contacts in case of a discharge can be found in Appendix A. The campus of Rose-Hulman Institute of Technology is located in Terre Haute, Indiana. There are two creeks which run through campus, which collect the majority of the runoff from campus. Oil and petroleum products are present on the campus of Rose-Hulman in above and below ground storage tanks, transformers, compressors, and multiple 55-gallon drums. The following oil and petroleum products are found on campus: gasoline, diesel fuel, #2 fuel oil, transformer oil, lubricating oil, cooking oil, compressor fluid, motor oil, and hydraulic oil. The products listed are used for emergency steam generation, electrical transformers, hydraulic elevators, trash compactors, cooking equipment, compressors, and motor vehicles. Rose-Hulman also owns a retail gas station located adjacent to main campus which utilizes underground storage tanks for gasoline.

5 South Campus West houses the Advanced Transportation Systems (ATS) program. This program contains an automotive shop where motor oil, transmission fluid, and fuel is stored. The fuel storage is located on the northwest corner of the property. This fuel storage is diked and is drained by the Manager of EH&S. There is a wetland located adjacent to this property. Oil is typically stored in 5 quart or smaller containers. Used oil, used coolant, and used transmission fluid is stored in 30 gallon containers on secondary containment pallets inside the building. South Campus houses various groups. This property has a small pond which drains to a small creek which leads to Honey Creek. Cutting tool coolant and machine oil is used and stored on site. The used coolant and oil is stored in the building garage located on the southwest corner of the building. Emergency Generators There are 10 emergency generators on main campus and 1 emergency generator on South Campus (Ventures). Eight emergency generators are all supplied by natural gas lines and therefore not subject to this plan. Three emergency generators are supplied by diesel fuel and are subject to this plan. These three emergency generators are located behind Hatfield Hall (55 gallons), in the basement mechanical of Hulman Memorial Student Union (300 gallons), and the Sports and Recreation Center mechanical room (230 gallons). A complete list of all emergency generators on campus can be found in Appendix C. Above Ground Storage Tanks There are 3 above ground fuel tanks on campus with a total capacity of 1,250 gallons. There are two above ground storage tanks located next to the Facilities building on the northeast corner of the campus core. These tanks are located within a secondary containment concrete dike which provides 100% secondary containment. The drain port for this secondary containment is locked and any fluids are verified by the Office of Environmental Health and Safety prior to draining. One of these tanks is a 500 gallon tank containing automotive gasoline. The second tank is a 250 gallon containing diesel fuel. The third above ground storage tanks is located behind the garage at the baseball fields, which is at the southwest corner of campus. This tank is a 500 gallon propane tank used to heat the garage at that location. There is no secondary containment for this tank. A complete list of above ground storage tanks on campus can be found in Appendix D. Underground Storage Tanks As of July 1, 2010 there are no active underground storage tanks located on campus. A 20,000 gallon underground storage tank located behind the Hulman Memorial Student Union was closed in place. This tank was filled with sand. A 2,000 gallon underground storage tank located outside the Moench boiler room was removed in The gas station owned by Rose-Hulman utilizes one 12,000 gallon tank and one 8,000 gallon tank to store gasoline. The tenant is responsible for all compliance with federal and

6 state laws, regulations, and requirements pertaining to these tanks. These tanks are fiberglass coated plastic with overfill protection and leak detection. A complete list of underground storage tanks on campus can be found in Appendix E. Transformers There are currently 19 non-pcb oil transformers located on concrete pads throughout the main campus property. There are 3 non-pcb oil transformers located at our Oxbridge property, 1 non-pcb oil transformers located at our South Campus (Ventures) property, and 2 non-pcb transformers located at our South Campus West property. The estimated total volume of transformer oil on campus is approximately 13,865 gallons. As defined in 40 CFR (b), transformers are not considered bulk oil storage containers. Rather, they are considered equipment which contains oil for operational purposes. Subsequently, this equipment does not require secondary containment. A complete list of all transformers on campus can be found in Appendix F. Elevators There are currently 9 hydraulic elevators on main campus and 1 on the south campus. The estimated total volume of hydraulic elevator oil on campus is approximately 1,511 gallons. As with transformers hydraulic elevator reservoirs are not considered bulk oil storage containers because their contents are in use. Therefore, these hydraulic reservoirs are exempt from secondary containment requirements. There are currently no drains located within the elevator rooms on campus. A complete list of all elevators on campus can be found in Appendix G. Grease Dumpsters Dining Services utilizes a 1,000 gallon grease pit to temporarily store waste oil associated with cooking processes. This pit is located on the north side of Hulman Memorial Student Union and is connected to the Dining Services grease traps. There is also a 250 gallon double-walled grease dumpster located at the loading dock which routinely emptied by an outside vendor. Trash Compactors and Cardboard Balers There are 3 hydraulic cardboard balers and 1 hydraulic trash compactor on campus. The cardboard balers are located at the Hulman Memorial Student Union loading dock (1) and the Recycling Building (2). The one trash compactor is located at the Recycling Building as well. Drums There are various locations on campus where 55 gallon drums containing oil or petroleum products are stored. There are 8 drums sitting on secondary containment pallets in the Facilities buildings. These contain used oil, hydraulic fluid, and oil used in various

7 equipment maintained by Facilities. South Campus West has various oil products stored in 55 and 30 gallon drums. 9.0 Drainage Pathways and Distance to Navigable Waters Lost Creek is the main water body which could be impacted by a spill on the campus of Rose-Hulman Institute of Technology. Lost Creek flows westerly through campus and continues through the city of Terre Haute, eventually flowing into the Wabash River. The gasoline and diesel fuel storage is located within 50 feet of Lost Creek. A release on campus also has the potential to reach this creek via the network of storm sewer catch basins. Honey Creek, in southern Vigo County, may be affected by a potential release at South Campus or South Campus West as may the wetlands located adjacent to these properties Spill Response, Emergency Procedures, and Reporting The goal of this plan is to eliminate the potential for oil spills to reach affected waterways, minimize human exposure, and environmental impacts in the unlikely event of a spill. Responsibility for spill cleanup depends upon whether a spill in incidental or non-incidental. Incidental and Non-incidental spills will be determined on a case-by-cases basis. Incidental spills are limited in quantity, exposure potential, and toxicity. Incidental spills present minor safety or health hazards to employees in the immediate work area or those assigned to respond. Responses to incidental spills of hazardous substances are to be performed when the substance can be absorbed, neutralized, or otherwise safely controlled at the time of release by the employee in the immediate area at the time of release. Incidental spill response does not require HAZWOPER training. Non-Incidental spills pose a significant safety or health hazard to employees working in the immediate vicinity or to the employee cleaning up the released hazardous substance. This type of release also has the potential to become an emergency in a short amount of time. Responders to non-incidental spills must be trained according to the OHSA 29 CFR Hazard Communication standard or the OSHA 29 CFR Lab Standard. Non-incidental spills require full HAZWOPER training. In the event of a spill on campus, the following procedures will be followed: 1. Remove all sources of ignition. If the ignition source cannot be removed, divert spilled substance away from the ignition source. 2. Identify the release substance and consult the appropriate Material Safety Data Sheet. 3. Report the spill immediately to the Office of Environmental Health & Safety. 4. If the amount of spilled substance is minimal, absorb and containerize. Contact EH&S for proper disposal methods.

8 5. If the amount of spilled substance is large, contain it as much as possible. Contact EH&S and monitor area until trained response personnel arrive. 6. The EH&S Manager will determine if a reportable spill occurred. If so, notification to the appropriate government agencies will be made followed by a written report. Indiana Department of Environmental Management requires all spills over 1,000 gallons be reported. 7. Spills in confined spaces must follow the procedures outlined in the Rose-Hulman Office of Environmental Health & Safety Confined Space procedure. 8. For more information regarding spill cleanup see Appendix G of the Rose-Hulman Institute of Technology Emergency Response Plan. In the event of a discharge of oil to navigable waters the following information will be provided to the National Response Center (NRC) immediately following identification of a discharge to navigable waters. The Discharge Notification Form can be found in Appendix H. The exact address or location and phone number of the facility Date and time of discharge Type of material discharged Estimate of the total quantity discharged Estimate of the quantity discharged to navigable waters Source of the discharge Description of all affected media Cause of the discharge Any damages or injuries caused by the discharge Actions being used to stop, remove, and mitigate the effects of the discharge Whether an evacuation may be needed Names of individuals and/or organizations who have been contacted Information regarding spills will be submitted to the EPA Region Administrator (Region V) and the Indiana Department of Environmental Management (IDEM)within sixty days of a single discharge more than 1,000 U.S. gallons of oil to navigable water or two discharges to navigable waters each more than 42 U.S. gallons of oil occurring within any twelve month period. The following information must be submitted to the EPA RA and IDEM: Name of the facility Your name Location of Facility Maximum storage or handling capacity of the facility and normal daily throughput Corrective action and countermeasures taken, including a description of equipment repairs and replacements An adequate description of the facility, including maps, flow diagrams, and topographical maps, as necessary. The cause of the reportable discharge, including a failure analysis of the system or subsystem in which the failure occurred

9 Additional preventive measures you have taken or contemplated to minimize the possibility of recurrence Other information as the EPA Regional Administrator may reasonably require pertinent to the plan or discharge 11.0 Routine Containment Drainage The secondary containment dike containing the 500 gallon and 250 gallon fuel storage tanks can collect rainwater and must be routinely drained. The Office of Environmental Health &Safety is responsible for this task. Collected water must be inspected for oil sheens. If no sheens are present, rainwater may be drained. If any sheen is found, cleanup should be completed using the appropriate absorbents and booms. All cleanup materials must be disposed of properly. There is also a secondary containment dike for fuel drum storage at South Campus West. The same procedures stated above pertain to this containment dike as it sits adjacent to a wetland area Inspections and Records Visual inspections of the tanks and secondary containment will be conducted monthly by the Office of Environmental Health & Safety. All inspections are documented and the records maintained in the Office of Environmental Health & Safety. These inspections will include a visual check for signs of leaking and tank deterioration, the containment area, and any associated piping. External integrity testing is to be conducted on all above ground fuel tanks and emergency generator tanks every five years by a certified tank inspector. In addition, internal testing will be conducted every 20 years if the tank is not replaced at the end of their life expectancy as determined by the manufacuter. Inspections of the transformers on campus will be conducted biennially and copies of these inspections are kept in the Department of Buildings and Systems as well as the Office of Environmental Health & Safety. Elevators are serviced monthly by an outside contractor and inspected on an annual basis by the same outside contractor Training All employees involved with oil stores on campus are to be trained in the safe operation and maintenance of oil-related equipment to eliminate the potential for spills. All training records will be maintained in the Office of Environmental Health & Safety Security Rose-Hulman Institute of Technology maintains an Office of Public Safety which coordinates all activities related to the local emergency response agencies. Public Safety maintains regular security patrols and the campus is sufficiently lit to allow for the discovery of any spills during evening hours. The Office of Environmental Health & Safety can be contacted

10 after hours through the Office of Public Safety. The Department of Facilities has personnel on call in the event of any issues related to the operation of campus. The fuel storage tanks are padlocked when not in use and only Facilities staff have keys to these pumps.

11 Certification I hereby attest that I have completed my review and evaluation of the SPCC Plan for Rose- Hulman Institute of Technology: Name: Signature: Date: Review and evaluation will amend plan as a result? Management Approval We are committed to the prevention of discharges of oil to navigable waters and the environment. This plan has the full approval of management at a level of authority to commit the necessary resources to fully implement it. Title: Signature: Date:

12 Appendix A A list of emergency contacts that would be needed in the unlikely event of a major spill at Rose-Hulman Institute of Technology include the following: SPCC Facility Response Coordinator (Office of EH&S) Office of Public Safety (After hours & Weekends) Terre Haute Fire Department Hazardous Materials Response Team Indiana Department of Natural Resources: Spill Line

13 Appendix B

14 Appendix C Emergency Generators Location Fuel Type Tank Capacity(gal) Hatfield Hall Diesel 55 Hulman Memorial Student Union Diesel 300 Sports and Rec Center Diesel 230 Crapo Hall Natural Gas N/A Deming Hall Natural Gas N/A Facilities Natural Gas N/A Moench Hall Natural Gas N/A Olin Hall Natural Gas N/A Public Safety Natural Gas N/A Scharpenberg Hall Natural Gas N/A South Campus (Ventures) Natural Gas N/A

15 Appendix D Above Ground Storage Tanks Tank Location Contents 500 Gallon Steel Facilities Gasoline 250 Gallon Steel Facilities Diesel Fuel

16 Appendix E Underground Storage Tanks Office of Environmental Health & Safety Tank Location Contents 12,000 Gallon Fiberglass Gas Station Gasoline 8,000 Gallon Fiberglass Gas Station Gasoline

17 Appendix F Transformers Location Capacity (gal) kva Mount Owner Crapo Hall Concrete Pad Rose-Hulman Deming Hall Concrete Pad Rose-Hulman Facilities Concrete Pad Rose-Hulman Hatfield Hall Concrete Pad Rose-Hulman Hatfield Hall Concrete Pad Rose-Hulman Hulman Memorial Student Union Concrete Pad Rose-Hulman Intramural Fields Concrete Pad Rose-Hulman Logan Library Concrete Pad Rose-Hulman Lower Dorms Concrete Pad Rose-Hulman Moench Hall Concrete Pad Rose-Hulman Myers Hall Concrete Pad Rose-Hulman Myers Hall Concrete Pad Rose-Hulman New Apartment Res Hall Concrete Pad Rose-Hulman Olin Hall Concrete Pad Rose-Hulman Oxbridge Concrete Pad Duke Energy Oxbridge Concrete Pad Duke Energy Oxbridge Concrete Pad Duke Energy Recycle Building Concrete Pad Rose-Hulman Rotz Lab Concrete Pad Rose-Hulman South Campus (Ventures) Concrete Pad Duke Energy South Campus West Concrete Pad Duke Energy South Campus West Concrete Pad Duke Energy Speed Hall Concrete Pad Rose-Hulman Sports and Rec Center Concrete Pad Rose-Hulman Stadium Concrete Pad Rose-Hulman

18 Appendix G Elevators Building Capacity (gal) Hatfield Hall 90 Hulman Memorial Student Union (Freight) 70 Hulman Memorial Student Union (Passenger) 170 Logan Library 90 Moench Hall (B-Section) 90 Moench Hall (E-Section) 120 Myers Hall 150 New Apartment Res Hall (East) 150 New Apartment Res Hall (West) 150 New Olin 16 Old Olin 75 Percopo Hall 150 South Campus (Ventures) 80 Sports and Rec Center 110

19 APPENDIX H

20 Area Type of Failure (discharge scenario) Potential Discharge Volume (Gal) Direction of Flow for Uncontained Discharge Secondary Containment Method Secondary Containment Capacity (Gal) Bulk Storage Containers and Mobile/Portable Containers Hatfield Hall Emergency Generator Fuel tank rupture, SC failure 47 Hulman Student Union Emergency Generator Fuel tank rupture, SC failure 250 Sports and Rec Center Emergency Generator Fuel tank rupture, SC failure 195 Facilities Operations Fueling Station Fuel tank rupture, SC failure 750 Facilites Shop Oil Storage, 55-gallon drums Drum Failure, puncture 330 West, downhill to storm drain Double Walled Fuel tank 54 Maintained inside building Double Walled Fuel tank 280 Southwest, downhill to Lost Creek Double Walled Fuel tank 220 North, downhill, to Lost Creek Potential to flow outside overhead door to storm drain Concrete Dike 1,408 Pallet Containment 165 Hulman Student Union Grease Dumpster Failure, Puncture, Overfill 250 North, downhill, to storm drain Double Walled tank 275 Oil-Filled Operational Equipment - Transformers Crapo Hall Bushing or seal failure 190 Sorbent Materials as needed N/A Deming Hall Bushing or seal failure 135 North, downhill Sorbent Materials as needed N/A Facilities Bushing or seal failure 319 North, to Lost Creek Sorbent Materials as needed N/A Hatfield Hall Bushing or seal failure 251 South, to storm drain Sorbent Materials as needed N/A Hatfield Hall Bushing or seal failure 299 South, to storm drain Sorbent Materials as needed N/A Hulman Memorial Student Union Bushing or seal failure 705 North, downhill Sorbent Materials as needed N/A Intramural Fields Bushing or seal failure 131 West, to storm basin Sorbent Materials as needed N/A Logan Library Bushing or seal failure 336 Northeast, to strom drains Sorbent Materials as needed N/A Lower Dorms Bushing or seal failure 135 North, to storm drains Sorbent Materials as needed N/A Moench Hall Bushing or seal failure 336 East, to storm drain Sorbent Materials as needed N/A Myers Hall Bushing or seal failure 392 North, to parking lot Sorbent Materials as needed N/A Myers Hall Bushing or seal failure 448 North, to parking lot Sorbent Materials as needed N/A New Apartment Res Hall Bushing or seal failure 423 Pooling in general Sorbent Materials as needed N/A Olin Hall Bushing or seal failure 484 West, to storm drain Sorbent Materials as needed N/A

21 Area Type of Failure (discharge scenario) Potential Discharge Volume (Gal) Direction of Flow for Uncontained Discharge Secondary Containment Method Secondary Containment Capacity (Gal) Oxbridge Bushing or seal failure 17 Oxbridge Bushing or seal failure 17 Oxbridge Bushing or seal failure 17 Pole Mount, drain to parking lot Pole Mount, drain to parking lot Pole Mount, drain to parking lot Sorbent Materials as needed Sorbent Materials as needed Sorbent Materials as needed N/A N/A N/A Recycle Building Bushing or seal failure North, to Lost Creek Sorbent Materials as needed N/A Rotz Lab Bushing or seal failure 215 North, to storm drains Sorbent Materials as needed N/A South Campus (Ventures) Bushing or seal failure 143 South, to lawn Sorbent Materials as needed N/A South Campus West Bushing or seal failure 180 South, to parking lot Sorbent Materials as needed N/A South Campus West Bushing or seal failure 143 South, to parking lot Sorbent Materials as needed N/A Speed Hall Bushing or seal failure 255 West, to parking lot Sorbent Materials as needed N/A Sports and Rec Center Bushing or seal failure 525 South, to Lost Creek Sorbent Materials as needed N/A Stadium Bushing or seal failure 266 South, to storm drain Sorbent Materials as needed N/A Oil-Filled Operational Equipment - Elevators Hatfield Hall Bushing, seal failure, or hose burst 90 Sorbent Materials as needed N/A Hulman Memorial Student Union (Freight) Bushing, seal failure, or hose burst 70 Sorbent Materials as needed N/A Hulman Memorial Student Union (Passenger) Bushing, seal failure, or hose burst 170 Sorbent Materials as needed N/A Logan Library Bushing, seal failure, or hose burst 90 Sorbent Materials as needed N/A Moench Hall (B-Section) Bushing, seal failure, or hose burst 90 Sorbent Materials as needed N/A Moench Hall (E-Section) Bushing, seal failure, or hose burst 120 Sorbent Materials as needed N/A Myers Hall Bushing, seal failure, or hose burst 150 Sorbent Materials as needed N/A New Apartment Res Hall (East) Bushing, seal failure, or hose burst 150 Sorbent Materials as needed N/A New Apartment Res Hall (West) Bushing, seal failure, or hose burst 150 Sorbent Materials as needed N/A New Olin Bushing, seal failure, or hose burst 16 Sorbent Materials as needed N/A

22 Area Type of Failure (discharge scenario) Potential Discharge Volume (Gal) Direction of Flow for Uncontained Discharge Secondary Containment Method Secondary Containment Capacity (Gal) Old Olin Bushing, seal failure, or hose burst 75 Sorbent Materials as needed N/A Percopo Hall Bushing, seal failure, or hose burst 150 Sorbent Materials as needed N/A South Campus (Ventures) Bushing, seal failure, or hose burst 80 Sorbent Materials as needed N/A Sports and Rec Center Bushing, seal failure, or hose burst 110 Sorbent Materials as needed N/A

23 Dike Drainage Log Date Bypass valve sealed closed Rainwater inspected to be sure no oil (or sheen) is visible Open bypass valve and reseal it following drainage Dike Drainage Log Drainage activity supervised Observations Signature of Inspector

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