TULANE UNIVERSITY SPILL PREVENTION CONTROL & COUNTERMEASURE (SPCC) PLAN FOR OIL STORAGE AREAS Office of Environmental Health and Safety (504) 988-5486 FAX (504) 988-1693 Revised: Dec 7, 2011 S\BM\emresponseplans\SPCC2011
Tulane University Spill Prevention Control and Countermeasure Plan Table of Contents Section Page PE Certification.. 1 I. Purpose. 2 II. Scope 2 III. Definitions 2 IV. Emergency Contact Information.. 5 V. Tulane National Primate Research Center (TNPRC). 8 VI. Hebert Research Center 12 VII. Uptown Campus. 16 VIII.J. Bennett Johnston (JBJ) Building 20 Appendix A - Aboveground, Underground Storage Tank List and Oil-filled Equipment List Appendix B - Flow Predictions Appendix C - Containment Structures Appendix D - Material Safety Data Sheets (Gasoline, Diesel, Motor Oil) Appendix E - Past Spill History Sheets Appendix F - Inspection Record Form
P.E. CERTIFICATION This Plan shall be reviewed and re-certified by a professional engineer every three years. I,, P.E., a Registered Professional Engineer in the State of Louisiana, have examined the SPPC Plan for the Tulane National Primate Research Center, Hebert Research Center, the Uptown Campus Facilities and J. Bennett Johnston Building. In accordance with the requirements of 40 CFR Part 112 and that I approve the attached SPCC Plan after visiting the sites, inspecting the facilities, and collecting information provided by the university. I attest that this plan has been prepared in accordance with good engineering practices and is compliant with the regulations found in LA DEQ s LAC 33:IX.907 and EPA s 40 CFR 112. Professional Engineer Engineer Seal: Registration No. Date: MANAGEMENT ENDORSEMENT: In accordance with the requirements of 40 CFR Part 112, this SPCC Plan is fully approved by the management of Tulane University, which commits the manpower, equipment, and materials necessary to fully implement this plan. Signature: Date: Name: Title: 1
I. Purpose The purpose of this Oil Spill Prevention Control and Countermeasure (SPCC) Plan is to prevent oil spills from occurring, and to perform safe, efficient and timely response in the event of a spill or leak (both referred to as spills herein). This SPCC Plan will establish procedures and equipment required to prevent the discharge of oil in quantities that violate applicable water quality standards, cause sheen upon or discoloration of the surface of navigable waters or adjoining shorelines, or cause sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines. The Plan also establishes the activities required to mitigate such discharges (i.e., countermeasures) should they occur. The plan should be used in the following ways: As a reference for oil storage and containment system information. As a tool for informing new employees and refreshing existing employees on practices for preventing and responding to spills. As a guide to periodic training programs for employees. As a guide to facility inspections. As a resource during an emergency response. II. Scope This plan applies to all sites where oil is stored, processed, distributed, or consumed, and could be reasonably expected to discharge oil in harmful quantities, and when the aboveground storage capacity of the site exceeds 1,320 gallons and total underground storage capacity of 42,000 gallons. Employees at the site, who handle oil, work with oil-containing equipment or respond to spills shall become familiar with the contents of the Plan. The Emergency Response Coordinators shall be responsible for implementation of emergency spill response activities. III. Definitions Aboveground Storage Tank (AST): A tank that is wholly aboveground or with any portion of the tank visible at the surface. Partially buried, bunkered, or mounded tanks are all considered to be aboveground tanks as are tanks in subterranean vaults. Barrel: Forty-two United States gallons at sixty degrees Fahrenheit. Berm: Dirt, concrete, or other constructed embankment that is commonly employed for secondary containment of drainage diversion purposes at oil storage or related operations. Boom: A temporary floating barrier used to contain an oil spill. Bulk Storage Tank: Any container used to store oil. 2
Containment of Diversionary Structure: Structure or equipment that prevents oil discharges from reaching navigable water. Containment of diversionary structures include dikes, berms, retaining walls, curbing, culverting, weirs, booms, spill diversion ponds, retention ponds, sorbent materials, and sumps. Dike: An embankment or wall that contains drainage water or spilled oil inside the walled area. Discharge-the placing, releasing, spilling, percolating, draining, pumping, leaking, seeping, emitting, disposing, bypassing or other escaping of pollutants into the air, waters, subsurface water or ground as the result of a prior act or omission; or the placing of pollutants into barrels, or similar containers under conditions and circumstances that leaking, seeping, draining or escaping of the pollutants can be reasonably anticipated. Facility -any mobile or fixed, onshore building, structure, installation, equipment, pipe, or pipeline used in oil well drilling operations (excluding offshore), oil production, oil refining, oil storage, or waste treatment. The boundaries of a facility may depend on several site-specific factors, such as the ownership or operation of buildings, structures, and equipment on the same site and the types of activity at the site. Oil - Section 311(a)(1) of the Clean Water Act defines "oil" as "oil of any kind or in any form including, but not limited to, petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes other than dredged soil." EPA interprets this definition to include crude oil, petroleum and petroleum-refined products, as well as non-petroleum oils such as vegetable and animal oils. Oil-filled Equipment - equipment that includes an oil storage container (or multiple containers and associated piping intrinsic to the operation of the equipment) in which the oil is present solely to support the function of the apparatus or the device. It is not considered a bulk storage container, and does not include oil-filled manufacturing equipment (flow-through process). Some examples include, but are not limited to: hydraulic systems, lubricating systems (e.g., those for pumps, compressors, and other rotating equipment including pump jack lubrication systems), gear boxes, machining coolant systems, heat transfer systems, transformers, circuit breakers, electrical switches, and other systems containing oil solely to enable the operation of the device. Operator- is the person or legal entity responsible for the operation and/or maintenance of a facility with a discharge covered by these regulations. Navigable Waters - include all waters that are used in interstate or foreign commerce, all interstate waters including wetlands, and all intrastate waters, such as lakes, rivers, streams, wetlands, sloughs, prairie potholes, wet meadows, lakes, or natural ponds. Essentially, the term navigable waters refer to any natural surface water in the U.S. Secondary Containment: Localized containment structure surrounding a potential source of oil discharge. Sheen - an iridescent appearance on the surface of water. 3
Sludge - an aggregate of oil or oil and other matter of any kind in any form other than dredged soil having a combined specific gravity equivalent to or greater than water. Sorbent: An aggregate of oil or oil plus other matter of any kind in any form other than dredged spoil having a combined specific gravity equivalent or greater to water. 4
IV. EMERGENCY CONTACT INFORMATION (Order in which telephone numbers are to be called) 1. If an oil spill is discovered at any oil storage facility, contact Tulane University Police. Tulane Police will contact the office of Environmental Health and Safety. If a spill incident is discovered after 5 p.m., contact Tulane University Police. Uptown Campus: Primary Contact: Karen Douglas Dept: Office of Environmental Health and Safety Office Phone: 504-865-5307 Cell Phone: 504-906-2417 Secondary Contact: Pam Fatland Dept: Office of Environmental Health and Safety Office Phone: 504-988-5486 Cell Phone: 504-234-6961 National Primate Research Center: Primary Contact: Kellie Mayer Dept: Office of Environmental Health and Safety Office Phone: 504-862-8040 ext. 6653 Cell Phone: 504-419-1391 Secondary Contact: Pam Fatland Dept: Office of Environmental Health and Safety Office Phone: 504-988-5486 Cell Phone: 504-234-6961 Hebert Center Primary Contact: Pam Fatland Dept: Office of Environmental Health and Safety Office Phone: 504-988-5486 Cell Phone: 504-234-6961 Secondary Contact: Name: James Putin Dept: TUHSC Facilities Services Office Phone: 504-394-9816 Cell Phone: 5
J. Bennett Johnston Building Primary Contact: Pam Fatland Dept: Office of Environmental Health and Safety Office Phone: 504-988-5486 Cell Phone: 504-234-6961 Secondary Contact: Name: Don Conners Dept: TUHSC Facilities Services Office Phone: 504-988-5424 Cell Phone: 504-234-6068 2. If an oil spill is discovered after normal working hours and weekends, the following must be contacted: a. Tulane Police: Uptown Campus: (504)865-5200 Medical School: (504)988-5555 Hebert Research Center: (504)988-5555 National Primate Research Center: (985)871-6411 b. OEHS will then call these agencies (in the following order if more than 42 gallons are spilled outside the containment area and are released into waterways) LA Department Single Point of Contact (225)219-3640 LA Department of Environmental Quality (504)838-5361 (24 hour emergency #) (225)342-1234 LA State Police (225)925-6595 New Orleans Sewerage and Water Board (504)942-3833 National Response Center 1-(800)424-8802 c. OEHS will direct Tulane University Police to contact the following Tulane departments: Risk Management The Office of Emergency Response Facilities Services Uptown TUHSC Tulane National Primate Center 6
3. If there are Fire and Police Emergencies, OEHS will contact: LA State Police (225)925-6595 St. Tammany Parish: Fire Department: (985)898-4727 or 911 Sheriff Department: (985)809-8200 or 911 Belle Chasse / Plaquemines Parish: Fire Department: (504)394-4070 or 911 Sheriff Department: (504)391-2004 or 911 New Orleans / Orleans Parish: Fire Department: (504)581-3473 or 911 Police Department: (504)821-2222 or 911 4. Hazardous Materials Emergency Response Companies Response companies may be called by Office of Environmental Health & Safety personnel upon additional evaluation of the oil spill, if it is determined that OEHS does not have personnel and equipment to contain and clean up an oil release from the storage area. The following emergency response companies shall be called in the following order: a. United States Emergency Services Group (USESG) 24 Hour Emergency Phone Number: 1-888-279-9930 b. Technical Environmental Services (TES) 24 Hour Emergency Phone Number: (504) 348-3098 c. Environmental Services and Consulting (ESC) 24 Hour Emergency Phone Number: (504)261-0206 V. Tulane National Primate Research Center (TNPRC) 7
A. GENERAL INFORMATION Name of facility: Tulane National Primate Research Center Name of the operator of the facility: Administrators of the Tulane Educational Fund Mailing Address: 18703 Three Rivers Road Covington, Louisiana 70433 Location of facility: River Road, Covington Date and year of initial facility operation: May 1966 Description of Facility: National Primate Research Center is a facility of Tulane University. It is located in Covington, Louisiana approximately 1.5 miles from I-12, off Hwy 190 in Covington, LA. It has many buildings where various types of research are done. Culverts that lead to the public waterways surround the center. The nearest potential receiver water is the Tchefuncte River. Hazardous Substances Stored: See Appendix A B. SPILL RESPONSE PROCEDURES AND COUNTERMEASURES 1. Discovery of a Release Any person discovering a release of oil from a container, tank, or operating equipment shall notify: Tulane University Police ( See Emergency Contact Information) and; Tulane University Police will contact OEHS. 2. Spill Response Procedures a. Identify the material released. Consult MSDS s in Appendix D. b. Attempt to stop the release at its source. i. Cease any product transfer operations. ii. Shut off any transfer valves or controls. iii. Plug or seal tank or flow line ruptures if possible. c. Contain the release as much as possible. d. Deploy spill prevention materials around the area where the spill has occurred outside of the containment wall. e. Place absorbent material in culverts, drains, or areas where spilled material can enter into public waterways. f. Remove all ignition sources from the area. g. Attend to any injured personnel. h. Follow the instructions on the Emergency Contact Information page of the Plan. i. Prepare and provide information for post incident reports and 8
notifications. j. Decontaminate tools and equipment used in cleanup. Even if dedicated to cleanup efforts, tools and equipment that have been used must be decontaminated before replacing them in the oil spill response kit. k. Dispose of any waste materials that are generated by the clean up through Hazardous Waste Supervisor. C. SPILL FLOW PREDICTION MODEL See Appendix B D. CONTAINMENT STRUCTURE AND EQUIPMENT See Appendix C Spill Equipment: Building #6 at the Tulane National Primate Research Center has the following equipment for the containment of the spill and for preventing material from entering into the storm drainage systems and state waterways. The oil spill response equipment is clearly labeled as Oil Spill Equipment : a. 2 Bales of Absorbent Pads b. Absorbent Boom and other materials c. Storage containers for absorbent materials E. CONFORMANCE OF SECONDARY CONTAINMENT The secondary containment, where necessary, is constructed in such a manner that it is impervious to diesel and oil with the necessary containment capacity. The drainage valves and pipes are in accordance with LAC 33:IX.907, subpart F. F. SECURITY ACTIONS Security of the area is accomplished in several ways: 1. The area of the storage tanks is secured allowing only those involved with the daily operation of the facility, campus police and representatives of the Office of Environmental Health and Safety to access the area. 2. Adequate warning signs are posted according to all applicable regulations for the storage of hazardous substances. 3. Drainage valves have locks which are tagged and sealed in the closed position when unattended. 4. The discharge starter control for the pumps is locked in the "off" position and accessible only to authorized personnel. 5. Adequate lighting is provided in case of a spill or vandalism during hours of darkness. 9
G. PERSONNEL TRAINING AND EMERGENCY RESPONSE COORDINATORS 1. OEHS personnel and emergency response coordinators are trained adequately to prevent, contain, control and clean up spilled material, and also to use spill equipment properly. Awareness training is done for the operators of the oilstorage units on an annual basis. 2. Emergency Response Coordinators: a. Name: Kellie Mayer Dept: Office of Environmental Health and Safety Office Phone: (504)862-8040 ext 6653 Work Cell Phone: (504)419-1391 b. Name: Pam Fatland Dept: Office of Environmental Health and Safety Dept: Office of Environmental Health and Safety Office Phone: 504-988-5486 Work Cell Phone: 504-234-6961 Functions / Activities during a Release: Ensure that Tulane University Police has been notified. Coordinate with Tulane Police to notify all affected facility personnel and implement facility evacuation if required. Notify state and local authorities. See Emergency Contact Information Identify the exact source, character and amount of any release, spill or leak. Assess possible threats to human health and determine the need for personal protective equipment. Coordinate and assist in the containment, control and countermeasure of any released hazardous materials according to this Plan. H. DRAINAGE OF CONTAINMENT AREAS The containment areas are fitted with manually operated bypass gate valves, which are normally closed. Drainage of the rainwater from within the containment area is performed with adherence to the following provisions: 1. Prior to discharge, the contained rain water is inspected to ensure compliance with any water discharge permit and/or applicable water quality standards. 2. The opening and closing of the bypass valve to drain the contained water is supervised by the facility manager or another appointed competent person. 3. Details of each discharge event (to include time, date, and estimated volume of discharge and name of person supervising) are recorded on the Monthly Inspection and Discharge Event form, which is maintained on site. 10
J. CHECK LIST The following items marked YES do apply to this facility s storage units: (All blank or NO items have explanations on back of this sheet or in an attachment) 1. Yes Secondary containment for each storage unit equals the contents of the tank plus enough freeboard for precipitation 2. _Yes Bermed containment area(s) are sufficiently impervious to contain spills. 3. Yes Drainage valves on secondary containment structures are locked until someone determines that the area can be drained appropriately. 4. _ Yes Contaminated storm water accumulated within secondary containment structures will be treated before release, or disposed of according to applicable regulations. 5. Yes Means are provided to prevent overfilling of storage units. 6. Yes All maintenance needs will be taken care of promptly. 7. Yes Warning lights or signs shall be provided in loading/unloading areas to prevent vehicle departure before complete disconnection of transfer lines. 8. Yes During filling or dispensing activities, operator will examine transfer hose and all connections for leaks. 9. Yes Means are provided to prevent unauthorized access (vandalism) to storage units when facility is unattended. 10. _ Yes Filling and/or dispensing valves on storage units shall be locked shut except during material transfers performed by authorized personnel. 11. Yes_ Facility lighting will be provided for the discovery of spills at night and to prevent potential spills due to vandalism. 12. Yes_ Facility Operator will train appropriate personnel and/or contractors and keep written SOPs and training records about a. how to use and maintain spill prevention and/or containment equipment and b. this plan, highlighting known spill events and what precautionary measures to take. 13. Yes In the event of a spill, Facility Operator will review and amend this plan as appropriate. 11
VI. Hebert Research Center A. GENERAL INFORMATION Name of facility: Tulane University Hebert Research Center Name of the operator of the facility: Administrators of the Tulane Educational Fund Mailing Address: 3705 Main Street Belle Chasse, Louisiana 70037 Location of facility: Behind Facilities Services Barn Building 156, Widgeon Road Date and year of initial facility operation: May 1966 Description of Facility: The storage facility is located behind building 156. In this facility there are three 500 gallon above-storage tanks. The tanks are located in a concrete containment dike surrounded by a chained linked fence. The nearest potential receiver is a drainage ditch along Widgeon Road that leads to Planters Canal. The canal empty into the parish drainage system then into the Intercostals Canal waterway. Hazardous Substances Stored: See Appendix A B. SPILL RESPONSE PROCEDURES AND COUNTERMEASURES 1. Discovery of a Release Any person discovering a release of oil from a container, tank, or operating equipment shall notify: Tulane University Police (See Emergency Contact Information) and; Tulane University Police will contact OEHS. 2. Spill Response Procedures a. Identify the material released. Consult MSDS s in Appendix D. b. Attempt to stop the release at its source. i. Cease any product transfer operations. ii. Shut off any transfer valves or controls. iii. Plug or seal tank or flow line ruptures if possible. c. Contain the release as much as possible. d. Deploy spill prevention materials around the area where the spill has occurred outside of the containment wall. e. Place absorbent material in culverts, drains or areas where spilled material can enter into public waterways. f. Remove all ignition sources from the area. g. Attend to any injured personnel. 12
h. Follow the instructions on the Emergency Contact Information page of the Plan. i. Prepare and provide information for post incident reports and notifications. j. Decontaminate tools and equipment used in cleanup. Even if dedicated to cleanup efforts, tools and equipment that have been used must be decontaminated before replacing them in the oil spill response kit. k. Dispose of any waste materials that are generated by the clean up through Hazardous Waste Supervisor. C. SPILL FLOW PREDICTION MODEL See Appendix B D. CONTAINMENT STRUCTURE AND EQUIPMENT See Appendix C Spill Equipment: Maintenance Building #156 at the Hebert Research Center has the following equipment for the containment of the spill and for preventing material from entering the storm drainage systems and state waterways. The oil spill response equipment is clearly labeled as Oil Spill Equipment : a. 2 Bales of Absorbent Pads b. Absorbent Boom and other materials c. Storage containers for absorbent materials E. CONFORMANCE OF SECONDARY CONTAINMENT The secondary containment, where necessary, is constructed in such a manner that it is impervious to diesel and oil with the necessary containment capacity. The drainage valves and pipes are in accordance with LAC 33:IX.907, subpart F. F. SECURITY ACTIONS Security of the area is accomplished in several ways: 1. The area of the storage tanks is secured allowing only those involved with the daily operation of the facility, campus police and representatives of the Office of Environmental Health and Safety to access the area. 2. Adequate warning signs are posted according to all applicable regulations for the storage of hazardous substances. 3. Drainage valves have locks which are tagged and sealed in the closed position when unattended. 4. The discharge starter control for the pumps is locked in the "off" position and accessible only to authorized personnel. 5. Adequate lighting is provided in case of a spill or vandalism during hours of darkness. 13
G. PERSONNEL TRAINING AND EMERGENCY RESPONSE COORDINATORS 1. OEHS Personnel and Emergency Response Coordinators are trained adequately to prevent, contain, control and clean up spilled material, and also to use spill equipment properly. Awareness training is done for the operators of the oilstorage units on an annual basis. 2. Emergency Response Coordinators a. Name: Pam Fatland Dept: Office of Environmental Health and Safety Office Phone: (504)988-5486 Cell Phone: (504)234-6961 b. Name: James Putin Dept: TUHSC Facilities Services Office Phone: 504-394-9816 Functions / Activities during a Release Ensure that Tulane University Police has been notified. Coordinate with Tulane Police to notify all affected facility personnel and implement facility evacuation if required. Notify state and local authorities. See Emergency Contact Information Identify the exact source, character and amount of any release, spill or leak. Assess possible threats to human health and determine the need for personal protective equipment. Coordinate and assist in the containment, control and countermeasure of any released hazardous materials according to this plan. H. DRAINAGE OF CONTAINMENT AREAS The containment areas are fitted with manually operated bypass gate valves, which are normally closed. Drainage of the rainwater from within the containment area is performed with adherence to the following provisions: 1. Prior to discharge, the contained rain water is inspected to ensure compliance with any water discharge permit and/or applicable water quality standards. 2. The opening and closing of the bypass valve to drain the contained water is supervised by the facility manager or another appointed competent person. 3. Details of each discharge event (to include time, date, and estimated volume of discharge and name of person supervising) are recorded on the Monthly Inspection and Discharge Event form, which is maintained on site. J. CHECK LIST 14
The following items marked YES do apply to this facility s storage units: (All blank or NO items have explanations on back of this sheet or in an attachment) 1. Secondary containment for each storage unit equals the contents of the tank plus enough freeboard for precipitation 2. Bermed containment area(s) are sufficiently impervious to contain spills. 3. Drainage valves on secondary containment structures are locked until someone determines that the area can be drained appropriately. 4. Contaminated storm water accumulated within secondary containment structures will be treated before release, or disposed of according to applicable regulations. 5. Means are provided to prevent overfilling of storage units. 6. All maintenance needs will be taken care of promptly. 7. Warning lights or signs shall be provided in loading/unloading areas to prevent vehicle departure before complete disconnection of transfer lines. 8. During filling or dispensing activities, operator will examine transfer hose and all connections for leaks. 9. Means are provided to prevent unauthorized access (vandalism) to storage units when facility is unattended. 10. Filling and/or dispensing valves on storage units shall be locked shut except during material transfers performed by authorized personnel. 11. Facility lighting will be provided for the discovery of spills at night and to prevent potential spills due to vandalism. 12. Facility Operator will train appropriate personnel and/or contractors and keep written SOPs and training records about a. how to use and maintain spill prevention and/or containment equipment and b. this plan, highlighting known spill events and what precautionary measures to take. 13. In the event of a spill, Facility Operator will review and amend this plan as appropriate (see addendums). 15
VII. Uptown Campus A. GENERAL INFORMATION Name of facility: Tulane University Uptown Campus Name of the operator of the facility: Administrators of the Tulane Educational Fund Mailing Address: 6823 St. Charles Ave. New Orleans, Louisiana 70118 Location of facility: 1300 Audubon Place Date and year of initial facility operation: May 1966 Description of Facility: The storage facility where the tanks are located is the Tulane University Uptown Campus Physical Plant yard where university vehicles are parked. The facility has a pumping station, garage and storage area where trucks are fueled and regular maintenance is done. A storm drain is located inside the facility property 50 feet from Audubon Place. The nearest receiving waterway from storm drain is Lake Pontchartrain. Hazardous Substances Stored: See Appendix A B. SPILL RESPONSE PROCEDURES AND COUNTERMEASURES 1. Discovery of a Release Any person discovering a release of oil from a container, tank, or operating equipment shall notify: Tulane University Police (See Emergency Contact Information) and; Tulane University Police will contact OEHS. 2. Spill Response Procedures a. Identify the material released. Consult MSDS s in Appendix D. b. Attempt to stop the release at its source. i. Cease any product transfer operations. ii. Shut off any transfer valves or controls. iii. Plug or seal tank or flow line ruptures if possible. c. Contain the release as much as possible. d. Deploy spill prevention materials around the area where the spill has occurred outside of the containment wall. e. Place absorbent material in culverts, drains or areas where spilled material 16
can enter into public waterways. f. Remove all ignition sources from the area. g. Attend to any injured personnel. h. Follow the instructions on the Emergency Contact Information page of the Plan. i. Prepare and provide information for post incident reports and notifications. j. Decontaminate tools and equipment used in cleanup. Even if dedicated to cleanup efforts, tools and equipment that have been used must be decontaminated before replacing them in the oil spill response kit. k. Dispose any waste materials that are generated by the clean up through Hazardous Waste Supervisor. C. SPILL FLOW PREDICTION MODEL See Appendix B D. CONTAINMENT STRUCTURE AND EQUIPMENT See Appendix C Spill Equipment: Maintenance Building at the Uptown Campus Facilities Services Yard has the following equipment for the containment of the spill and for preventing material from entering the storm drainage systems and state waterways. The oil spill response equipment is clearly labeled as Oil Spill Equipment : a. 2 Bales of Absorbent Pads b. Absorbent Boom and other materials c. Storage containers for absorbent materials E. CONFORMANCE OF SECONDARY CONTAINMENT The secondary containment, where necessary, is constructed in such a manner that it is impervious to diesel and oil with the necessary containment capacity. The drainage valves and pipes are in accordance with LAC 33:IX.907, subpart F. F. SECURITY ACTIONS Security of the area is accomplished in several ways: 1. The area of the storage tanks is secured allowing only those involved with the daily operation of the facility, campus police and representatives of the Office of Environmental Health and Safety to access the area. 2. Adequate warning signs are posted according to all applicable regulations for the storage of hazardous substances. 3. Drainage valves have locks which are tagged and sealed in the closed position when unattended. 4. The discharge starter control for the pumps is locked in the "off" position and accessible only to authorized personnel. 17
5. Adequate lighting is provided in case of a spill or vandalism during hours of darkness. G. PERSONNEL TRAINING AND EMERGENCY RESPONSE COORDINATORS 1. OEHS Personnel and Emergency Response Coordinators are trained adequately to prevent, contain, control and clean up spilled material, and also to use spill equipment properly. Awareness training is done for the operators of the oilstorage units on an annual basis. 2. Emergency Response Coordinators: a. Name: Karen Douglas Dept.: Office of Environmental Health and Safety Office Phone: (504)865-5307 Cell Phone: (504)906-2417 b. Name: Pam Fatland Dept: Office of Environmental Health and Safety Office Phone: (504) 988-5486 Cell Phone: (504) 234-6961 Functions / Activities during a Release: Ensure that Tulane University Police has been notified. Coordinate with Tulane Police to notify all affected facility personnel and implement facility evacuation if required. Notify state and local authorities. See Emergency Contact Information Identify the exact source, character and amount of any release, spill or leak. Assess possible threats to human health and determine the need for personal protective equipment. Coordinate and assist in the containment, control and countermeasure of any released hazardous materials according to this plan. H. DRAINAGE OF CONTAINMENT AREAS The containment areas are fitted with manually operated bypass gate valves, which are normally closed. Drainage of the rainwater from within the containment area is performed with adherence to the following provisions: 1. Prior to discharge, the contained rain water is inspected to ensure compliance with any water discharge permit and/or applicable water quality standards. 2. The opening and closing of the bypass valve to drain the contained water is supervised by the facility manager or another appointed competent person. 3. Details of each discharge event (to include time, date, and estimated volume of discharge and name of person supervising) are recorded on the Monthly 18
Inspection and Discharge Event form, which is maintained on site. J. CHECK LIST The following items marked YES do apply to this facility s storage units: (All blank or NO items have explanations on back of this sheet or in an attachment) 1. Secondary containment for each storage unit equals the contents of the tank plus enough freeboard for precipitation 2. Bermed containment area(s) are sufficiently impervious to contain spills. 3. Drainage valves on secondary containment structures are locked until someone determines that the area can be drained appropriately. 4. Contaminated storm water accumulated within secondary containment structures will be treated before release, or disposed of according to applicable regulations. 5. Means are provided to prevent overfilling of storage units. 6. All maintenance needs will be taken care of promptly. 7. Warning lights or signs shall be provided in loading/unloading areas to prevent vehicle departure before complete disconnection of transfer lines. 8. During filling or dispensing activities, operator will examine transfer hose and all connections for leaks. 9. Means are provided to prevent unauthorized access (vandalism) to storage units when facility is unattended. 10. Filling and/or dispensing valves on storage units shall be locked shut except during material transfers performed by authorized personnel. 11. Facility lighting will be provided for the discovery of spills at night and to prevent potential spills due to vandalism. 12. Facility Operator will train appropriate personnel and/or contractors and keep written SOPs and training records about a. how to use and maintain spill prevention and/or containment equipment and b. this plan, highlighting known spill events and what precautionary measures to take. 13. In the event of a spill, Facility Operator will review and amend this plan as appropriate (see addendums). 19
VIII. J. Bennett Johnston Building A. GENERAL INFORMATION Name of facility: Tulane University J. Bennett Johnston Building Name of the operator of the facility: Administrators of the Tulane Educational Fund Mailing Address: 1430 Tulane Ave. New Orleans, Louisiana 70112 Location of facility: 1324 Tulane Ave. Date and year of initial facility operation: May 1991 Description of Facility: The building has a loading/receiving dock located on South Liberty Street. A storm drain is located greater than 50 ft. outside the facility property on South Liberty Street. The nearest receiving waterway from storm drain is Lake Pontchartrain. Hazardous Substances Stored: See Appendix A B. SPILL RESPONSE PROCEDURES AND COUNTERMEASURES 1. Discovery of a Release Any person discovering a release of oil from a container, tank, or operating equipment shall notify: Tulane University Police (See Emergency Contact Information) and; Tulane University Police will contact OEHS. 2. Spill Response Procedures a. Identify the material released. Consult MSDS s in Appendix D. b. Attempt to stop the release at its source. i. Cease any product transfer operations. ii. Shut off any transfer valves or controls. iii. Plug or seal tank or flow line ruptures if possible. c. Contain the release as much as possible. d. Deploy spill prevention materials around the area where the spill has occurred outside of the containment wall. e. Place absorbent material in culverts, drains, or areas where spilled material can enter into public waterways. f. Remove all ignition sources from the area. g. Attend to any injured personnel. 20
h. Follow the instructions on the Emergency Contact Information page of the Plan. i. Prepare and provide information for post incident reports and notifications. j. Decontaminate tools and equipment used in cleanup. Even if dedicated to cleanup efforts, tools and equipment that have been used must be decontaminated before replacing them in the oil spill response kit. k. Dispose any waste materials that are generated by the clean up through Hazardous Waste Supervisor. C. SPILL FLOW PREDICTION MODEL See Appendix B D. CONTAINMENT STRUCTURE AND EQUIPMENT See Appendix C Spill Equipment: J. Bennett Johnston storage room located within the Liberty street loading dock has the following equipment for the containment of the spill and for preventing material from entering into the storm drainage systems and state waterways. The oil spill response equipment is clearly labeled as Oil Spill Equipment : a. 2 Bales of Absorbent Pads b. Absorbent Boom and other materials c. Storage containers for absorbent materials E. CONFORMANCE OF SECONDARY CONTAINMENT The secondary containment, where necessary, is constructed in such a manner that it is impervious to diesel and oil with the necessary containment capacity. The drainage valves and pipes are in accordance with LAC 33:IX.907, subpart F. F. SECURITY ACTIONS Security of the area is accomplished in several ways: 1. The area of the storage tanks is secured allowing only those involved with the daily operation of the facility, campus police and representatives of the Office of Environmental Health and Safety to access the area. 2. Adequate warning signs are posted according to all applicable regulations for the storage of hazardous substances. 3. Drainage valves have locks which are tagged and sealed in the closed position when unattended. 4. The discharge starter control for the pumps is locked in the "off" position and accessible only to authorized personnel. 5. Adequate lighting is provided in case of a spill or vandalism during hours of darkness. 21
G. PERSONNEL TRAINING AND EMERGENCY RESPONSE COORDINATORS 1. OEHS Personnel and Emergency Response Coordinators are trained adequately to prevent, contain, control and clean up spilled material, and also to use spill equipment properly. Awareness training is done for the operators of the oilstorage units on an annual basis. 2. Emergency Response Coordinators: a. Name: Pam Fatland Dept: Office of Environmental Health and Safety Office Phone: (504) 988-5486 Cell Phone: (504) 234-6961 b. Name: Don Conners Dept: TUHSC Facilities Services Office Phone: (504)988-5424 Cell Phone: (504)234-6068 Functions / Activities during a Release Ensure that Tulane University Police has been notified. Coordinate with Tulane Police to notify all affected facility personnel and implement facility evacuation if required. Notify state and local authorities. See Emergency Contact Information Identify the exact source, character and amount of any release, spill or leak. Assess possible threats to human health and determine the need for personal protective equipment. Coordinate and assist in the containment, control and countermeasure of any released hazardous materials according to this plan. H. DRAINAGE OF CONTAINMENT AREAS The containment areas are fitted with manually operated bypass gate valves, which are normally closed. Drainage of the rainwater from within the containment area is performed with adherence to the following provisions: 1. Prior to discharge, the contained rain water is inspected to ensure compliance with any water discharge permit and/or applicable water quality standards. 2. The opening and closing of the bypass valve to drain the contained water is supervised by the facility manager or another appointed competent person. 3. Details of each discharge event (to include time, date, and estimated volume of discharge and name of person supervising) are recorded on the Monthly Inspection and Discharge Event form, which is maintained on site. 22
J. CHECK LIST The following items marked YES do apply to this facility s storage units: (All blank or NO items have explanations on back of this sheet or in an attachment) 1. Secondary containment for each storage unit equals the contents of the tank plus enough freeboard for precipitation 2. Bermed containment area(s) are sufficiently impervious to contain spills. 3. Drainage valves on secondary containment structures are locked until someone determines that the area can be drained appropriately. 4. Contaminated storm water accumulated within secondary containment structures will be treated before release, or disposed of according to applicable regulations. 5. Means are provided to prevent overfilling of storage units. 6. All maintenance needs will be taken care of promptly. 7. Warning lights or signs shall be provided in loading/unloading areas to prevent vehicle departure before complete disconnection of transfer lines. 8. During filling or dispensing activities, operator will examine transfer hose and all connections for leaks. 9. Means are provided to prevent unauthorized access (vandalism) to storage units when facility is unattended. 10. Filling and/or dispensing valves on storage units shall be locked shut except during material transfers performed by authorized personnel. 11. Facility lighting will be provided for the discovery of spills at night and to prevent potential spills due to vandalism. 12. Facility Operator will train appropriate personnel and/or contractors and keep written SOPs and training records about a. how to use and maintain spill prevention and/or containment equipment and b. this plan, highlighting known spill events and what precautionary measures to take. 13. In the event of a spill, Facility Operator will review and amend this plan as appropriate (see addendums). 23