SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN AND SPILL PREVENTION AND RESPONSE PLAN AT THE UNIVERSITY OF MINNESOTA MINNEAPOLIS CAMPUS

Transcription

1 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN AND SPILL PREVENTION AND RESPONSE PLAN AT THE UNIVERSITY OF MINNESOTA MINNEAPOLIS CAMPUS ST. PAUL CAMPUS COMO SERVICE AREA Prepared by Service Engineering Group August 14, 2001 Revised November 12, 2001 Revised March 20, 2005 Revised December, 2010

2 Table of Contents Section Page Section 1.0 General Information 1.1 Introduction Purpose and Scope Plan Revision and Amendment Certification by Professional Engineer Management Certification 3 Section 2.0 Spill and Discharge Reporting and Contact List 4 Section 3.0 Site Information Campus Description Oil Storage Overview 7 Section 4.0 Spill History 8 Section 5.0 Containment Measures Aboveground Tanks Hydraulic Elevators Transformers Drums Fats and Grease Dumpsters Tank Truck Unloading 11

3 5.7 Used Oil Transfer New Oil Transfer 12 Section 6.0 Spill Response and Emergency Procedures Discharge Drainage Controls Discharge Response and Cleanup Spill Recovery Material Disposal Options Spill Reporting Procedure Spill Response Procedure Notification Spill Response Equipment Media Contacts 16 Section 7.0 Potential Spill and Flow Predictions ASTs Hydraulic Elevators Areas Oil-filled Transformers Areas Drums Storage Areas Fat and Grease Storage Areas Proper Containment 19 Section 8.0 Inspections and Records ASTs 20

4 8.2 Hydraulic Elevators Oil-filled Transformers Drums Storage Fat and Grease Storage 21 Section 9.0 Personnel Training 22 Section 10.0 Security Fencing Master Flow Drain Valves Starter Controls Locked Unloading Connections Lighting 23 Section 11.0 Loading and Unloading Secondary Containment Unloading Spill Prevention Precaution 25 Section 12.0 Regulatory Conformance 27 Section 13.0 Facility Drainage 28 Section 14.0 Containment Area Drainage Tank Compatibility with its Contents, Containment Containment Area Drainage Buried Underground Tanks

5 14.4 Above Ground Tank Integrity Testing High Liquid Level Alarms Tank Container Visible Oil Leak Corrections Mobile Oil Storage Tanks 30 Section 15.0 Facility Transfer Operations Buried Pipe Insulation Cap Terminal Connection Pipe Support Design Valve and Piping Inspection 31

6 TABLES Table 1.0 Table 7.1 Table 7.2 Table 7.3 Table 7.4 Table 7.5 Table 10.1 Table 10.2 Table 10.3 Spills and Emergency Response Call List Aboveground Storage Tank Inventory Hydraulic Elevator Inventory Oil-Filled Transformer Inventory Drum Storage Inventory Fat and Grease Storage Inventory Spill Response Training: DEHS Department Fueling, Tank Inspection and Maintenance Training: Facilities Management Department Fueling, Tank Inspection and Maintenance Training: Other Departments

7 FIGURES Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 Figure 6 Figure 7 Figure 8 Figure 9 Figure 10 Figure 11 Figure 12 Figure 13 Figure 14 Figure 15 Figure 16 Figure 17 Site Location Map: Minneapolis Campus Site Location Map: St. Paul Campus Tank Location Map: Minneapolis Campus East Tank Location Map: Minneapolis Campus West Hydraulic Elevator Location Map: Minneapolis Campus East Hydraulic Elevator Location Map: Minneapolis Campus West Oil-Filled Transformer Location Map: Minneapolis Campus East Oil-Filled Transformer Location Map: Minneapolis Campus West Tank Location Map: St. Paul Campus Hydraulic Elevator/Oil-Filled Transformer Location Map: St. Paul Campus Facilities Management District Map: Minneapolis Campus Facilities Management District Map: St. Paul Campus Storm Sewer Map: Minneapolis Campus East Storm Sewer Map: Minneapolis Campus West Storm Sewer Map: St. Paul Campus (North Section) Storm Sewer Map: St. Paul Camp us (Other areas) Storm Sewer Map: Minneapolis Campus (Other areas)

8 APPENDIXES Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Appendix G Appendix H Appendix I Appendix J Appendix K SPCC Checklist Site Information and UST Tank Testing and Inspection Hydraulic Elevator Checklist Site Information Oil- filled Transformer Checklist Site Information Drum Storage Checklist Site Information Fat and Grease Storage Checklist Site Information Delivery and Spill Prevention Response Plan by Lubrication Technologies, Inc., and Facilities Management Work Order Ticket Facilities Management Fueling Operations Checklist Facilities Management Generator Tank Monthly Inspection Checklist University of Minnesota Cart Inventory of Supplies Bay West, Inc. Equipment List West Central Environmental Equipment List

9 Section 1.0 General Information 1.1 Introduction This document is the Spill Prevention Control and Countermeasure (SPCC) Plan for the University of Minnesota (University) for three separate facilities: the Minneapolis Campus, St. Paul Campus, and Como Service Area. This document satisfies the Plan requirements of the Federal Oil Pollution Prevention Regulations (40 CFR, Part 112) and the Prevention and Response (P&R) Plan requirements of the Oil and Hazardous Substance Discharge Preparedness Regulations (Minnesota Statutes, Chapter 115 E), also known as the Minnesota Spill Bill Response Plan. This SPCC Plan develops a program that will minimize the potential for release(s) of oil or oil products from the University facilities into public waters. The University presents in this document their General Preparedness to satisfy the requirements of the P&R Plan (Minnesota Statutes, Chapter 115E.045, Subdivision 2). Since the SPCC and P&R Plans are similar in informational and planning requirements, the two plans are combined into this single document. Copies of this Plan are at the following locations: Available on line at Situated in Thompson Center for Environmental Management 1.2 Purpose and Scope The purpose of this SPCC plan is the establish procedures and guidelines to prevent oil discharge on the University of Minnesota campuses. This plan specifically establishes proper procedures and equipment needed to address any potential discharges of oils that could violate applicable water quality standards, cause sheen upon or discoloration of the surface of navigable waters, or cause sludge and emulsion to be deposited beneath the surface of any water body. The plan has been prepared pursuant to regulations set forth

10 in 40 CFR 112 which states that any facility having oil storage capacity of 1,320 gallons aboveground or greater, and could be reasonably expected to discharge oil in harmful quantities into navigable waters of the United States must prepare and implement an SPCC Plan. Oil is defined in 40 CFR 112.2(a) as oil of any kind or form, including, but not limited to petroleum, fuel oil, sludge oil, oil refuse and oil mixed with wastes other than dredged spoil. The University of Minnesota stores these types of oil in sufficient amounts to necessitate the generation of an SPCC Plan. 1.3 Plan Revision and Amendment As set forth in 40 CFR 112.5(a) and (b), this SPCC Plan shall be amended and recertified whenever required by the Regional Administrator of the United States Environmental Protection Agency (USEPA), whenever applications are revised, or whenever there is a change in facility design, construction, operation, or maintenance which materially affects the facility s potential for the discharge of oil into or upon the navigable waters of the United States. In addition, the Plan shall be reviewed and evaluated at least once every five years. No amendments shall be implemented to satisfy these requirements unless certified by a Registered Professional Engineer. 1.4 Certification by Professional Engineer I hereby certify that I have examined the facility and, being familiar with the provisions of 40 CFR, Part 112, and Minnesota Statutes, Chapter 115E, attest that these SPCC and P&R Plans have been prepared by me or under my direct supervision in accordance with good engineering practices, and that I am a duly Licensed Professional Engineer under the laws of the State of Minnesota. Name: Van-Anh Thai, P.E. Title: Environmental Compliance Specialist Signature: Date: License #: 24381

11 1.4 Management Certification This plan was reviewed by and has the approval of management at a level and authority to commit the necessary resources toward spill prevention. In addition, management supports and assists with the timely training of all employees that handle oil at our facility. This plan will be maintained on-site in a readily accessible location for use in emergencies and agency inspections. Name: Andrew Phelan Tile: Assistant Director, Department of Environmental Health and Safety Signature:

12 Section 2.0 Spill and Discharge Reporting and Contact List SPILLS AND EMERGENCY RESPONSE CALL LIST UNIVERSITY OF MINNESOTA rd Avenue SE Minneapolis, Minnesota Environmental Health and Safety Department Day work hours call: After work hours call: on campus, 911 off campus Contact Title Telephone Numbers Andrew Phelan Emergency Coordinator Home: Cell: Calvin Cole 1st Backup Emergency Coordinator Home: Cell: Greg Casura 2 nd Backup Emergency Coordinator Home: Cell: Neil Carlson 3rd Backup Emergency Coordinator Home: Cell: Craig Moody 4th Backup Emergency Coordinator Home: Cell:

13 Regulatory Contacts (answered 24 hours) US Coast Guard and US EPA National Response Center Minnesota Pollution Control Agency Spill Response Unit State of Minnesota Duty Officer Division of Emergency Management & Public Safety City of Minneapolis Emergency Communications City of St. Paul Public Works (sewers) Emergency Response Contractor (answered 24 hours) Bay West, Incorporated West Central Response

14 Section 3.0 Site Information 3.1 Campus Description This plan consolidates plans for the Minneapolis Campus, St. Paul Campus and the Como Service Area. Address of facilities: Minneapolis Campus: 100 Church Street, Minneapolis, MN St. Paul Campus: 1420 Eckles Avenue, St. Paul, MN Como Service Area: 2812 Fairmont Avenue SE, Minneapolis, MN See Figure 1, Minneapolis Campus, and Figure 2, St. Paul Campus, for a map of the areas that are covered by this plan. This plan does not include the three steam- generating facilities owned by the University, located on the Minneapolis and St. Paul campuses, and operated by Foster Wheeler since July 1, A separate plan is available for the steam- generating facilities. Owner of Facilities: Type of Facilities: Date of Initial Operation: University of Minnesota Public Education and Research University, and medical facilities Was founded as preparatory school in 1851, was closed for a period of time reopened in 1867 and reorganized in 1869 as an institution of higher learning with periodic renovations and expansions. Person in Charge of Facilities: Robert H. Bruininks, President Authorized Individuals Responsible for Implementation of the SPCC and P&R Plans: Mr. Andrew Phelan, Assistant Director of Environmental Health & Safety is responsible for implementation of these plans. The University Emergency Chemical Response Team (CRT) employees are authorized and trained to perform First Response actions, including evacuation of appropriate personnel and initial efforts for spill control and containment, and cleanup of small spills.

15 3.2 Oil Storage Overview The University provides education and research facilities and includes clinical medical facilities. The facility handles and stores significant volumes of petroleum products used for heating fuel, emergency generators, hydraulic elevators, transformers, fueling, and oil for vehicles. An inventory of the bulk oil storage containers and operating equipment containing oil on-site is presented in Tables 7.1, 7.2, 7.3, 7.4, and 7.5. The locations of the petroleum storage containers and equipment are shown in relation to the entire area of the Como Service area and the two campuses in Figures 3, 4, 5, 6, 7, 8, 9, and 10. Due to the large number of tanks and equipment located throughout the two campuses and the Como Service Area, details of each location are shown in the attachments of Appendix A, Appendix B, Appendix C, Appendix D, and Appendix E (SPCC Checklist for specific sites), and are referenced in Tables 7.1, 7.2, 7.3, 7.4, and 7.5 by Map Number.

16 Section 4.0 Oil Spill History This facility has experienced only one significant spill (in excess of five gallons) in the past 48 months. The following provides a description of the spill, corrective actions, and plans for preventing reoccurrence. A spill occurred as a result of overfilling a new tank at Gortner Avenue Ramp in the Generator Room on the St. Paul Campus in Facilities Management (FM) Zone 4, on March 6, The tank at the Gortner Avenue Ramp was at half- full after the generator installation and test by the contractor. FM was going to fill the tank to capacity for the first time. The tank operator was informed that the tank was 400 gallons, and was prepared to fill the tank with 230 gallons of diesel fuel. Someone had incorrectly read the plaque on the tank, which indicated that the tank had maximum capacity of 300 gallons. The fill proceeded and the operator indicated that he had heard foaming of the diesel in the pipe. The mechanic went to check on the tank and found diesel fuel flowing out the door of the generator room. The University Environmental Health and Safety Department (EHS) were called. This resulted in a spill of gallons of diesel fuel that pooled at two floor drains outside of the Generator Room that discharge to the sanitary sewer. Due to ice buildup in the area, the oil did not drain and was cleaned-up for disposal. This spill prevention plan includes procedures to have an FM representative to remain in view of the tank in order to communicate any issues, anticipated volume required and fuel gauge readings on the tank to the tanker driver; and to insure that the tanker driver follows his company s fueling procedures for all future refueling activities. (See Section 12.2 on unloading procedures for details)

17 Section 5.0 Containment Measures 5.1 Aboveground Tanks The types of oil contained in each storage tank are indicated in Table 7.1. Active above ground storage tanks (ASTs) for emergency generators typically have double-wall tanks located immediately under the generators or are within basins capable of containing a volume of liquid of the tank capacity plus 10%. A number of the generators are located inside buildings that may have additional capacity to contain spills. Five of the inside ASTs are near floor drains that empty into the sanitary sewers. A significant leak associated with these ASTs could result in oil entering the sanitary sewer. These tanks will require some form of secondary containment to prevent the oil from accessing the floor drains. Emergency generators with underground storage tanks (USTs) are generally less than 1,100 gallons, with fiberglass construction and overflow protection. Day tanks are used for generators with USTs. Several of the day tanks that are listed in Table 7.1 and detailed in Appendix A have a volume of less than 55 gallons and are not subject to the SPCC rules. Periodically, the spill containment basins contain water from condensation and groundwater infiltration and need to be pumped off by an outside contractor and hauled off-site for disposal. Pumping maintenance records are maintained in the FM office. The presence of water can be seen in the access hatch and will show in the monitoring detector. 5.2 Hydraulic Elevators There are 111 active hydraulic elevators located in campus buildings. Each elevator consists of a storage container, a hydraulic pump, steel delivery lines, and an elevator pit that contains the hydraulic ram of the elevator. Each of the storage containers and pumps are located inside the elevator equipment storage rooms. Any leak of hydraulic oil from these containers or pumps would result in oil pooling on the floor of the room, the elevator pit or the adjacent hallways. Sixty-five of the elevators have floor drains that empty into the sanitary sewers located in the equipment room, in the elevator pit or

18 located just outside the equipment room. A significant leak associated with these elevators could result in oil entering the sanitary sewer. These elevators will require some form of diversionary structured are highlighted in Table 7.2. In the standard operations of the hydraulic elevators, there is a small amount of oil that gets past the seal located at the top of the hydraulic cylinder. This oil drains back into a five-gallon bucket or to a scavenger pump. If the bucket overflows or the scavenger pump fails this oil ends up on the pit floor and is cleaned up using floor oil dry or absorbent pads. The storage capacity and contents of these containers is shown on Table Transformers There are 186 oil-filled transformers on the Minneapolis campus, St. Paul campus and Como Service area in excess of 55 gallons. One hundred and twenty-three of the transformers are located inside buildings and sixty-three of the transformers are located outside. Fifteen of the inside transformers may, in the event of a leak, run into floor drains that are connected to the sanitary sewer. These transformers are highlighted in bold print in Table 7.3. There is no secondary containment associated with the outside transformers. Forty-four of the outdoor transformers are in areas where there is no access to the storm sewers or diversionary structures are in place to prevent oil from accessing the storm sewer system. Nineteen of these transformers will require some diversionary device to prevent a leak from entering the storm sewers. The transformers requiring diversionary devices are highlighted in bold print in Table 7.3. The storage capacity and contents of these containers is shown in Table Drums There are thirty-six drum storage areas located throughout the two campuses and the Como Service Area. Twenty-seven of the drum storage areas require additional secondary containment and are highlighted in bold print in Table 7.4. The storage capacity and contents of these drums are shown in Table 7.4.

19 5.5 Fat and Grease Dumpsters There are five fat and grease storage areas located throughout the two campuses and the Como Service Area. Fat and grease is collected from campus food service kitchens and stored in specially constructed grease collection dumpsters. The grease collection company provides these containers. These containers are double walled. The storage capacity and contents of these containers are shown in Table Tank Truck Unloading Fuel is transferred from tanker trucks to the storage tanks. During filling, the tanker truck is staged in the driveway or street near the tank (see tank locations in Appendix A). The UST fill pipe is located directly above the tank in the fill access hatch (as shown for each tank in Appendix A). The ASTs are filled through a fill pipe located normally at the top of the tank, or on the wall of the building, if the AST is located inside a building (as shown in Appendix A). Fuel pumps from the tanker are used for fuel transfer. Fuel pumps located inside the buildings are normally used for transfer of fuel from the underground storage tank (UST) to the day tank. Overhead streetlights or building lights sufficient to allow visual inspection of tanks, piping and fueling procedures light the fuel storage and transfer area. Fueling is normally done only during daylight hours. Fueling is managed by the FM Department, which is divided into district as shown in Figures 5 and 6. The Central Building Systems Automation Center (BSAC) monitors and provides a central contact for operational issues 24 hours a day, 7 days a week. FM operates a computer work order ticket system called COMPAS, for requesting and tracking maintenance inspection and repair of systems including storage tanks. An FM representative is present during fueling and signs-off on the manifest. An example of the fueling contract s operational procedures (including their Spill Prevention and Response Plan) and of FM s related Work Order Ticket are shown in Appendix F. Contacts for Other Facilities; including Agriculture Services, Fleet Services, and Golf Course and Turf Management Center are shown in Appendix F, and are not managed by the FM Department.

20 5.7 Used Oil Transfer Used oil is collected in small drain pans and poured directly into 55-gallon drums. These drums are picked up by a contractor, when full, for off-site disposal. When full drums are being loaded onto the trucks, area floor drains are covered to prevent access to the sanitary sewer in the event a drum is dropped, ruptures, or leaks. 5.8 New Oil Transfer Motor oil is delivered to the Food Services Building #113 in 55-gallon drums. This oil is transferred to the overhead rectangular drums with a small transfer pump. A line failure may cause a leak that could get into the sanitary sewer floor drain trench. This drain is covered, or a temporary dike system is used, during the transfer process. Whenever material is being transferred from drum to drum, floor drains are covered to prevent a spill from entering the sewer system.

21 Section 6.0 Spill Response and Emergency Procedures 6.1 Discharge of Drainage Controls Containment and diversionary structures for each facility transfer station or equipment are summarized in Tables 7.1, 7.2, 7.3, 7.4, and Discharge Response and Cleanup Discharge response will follow the same procedures outlined in the spill response section, Section Spill Recovery Material Disposal Options Recovered spill material will be managed in accordance with local environmental rules and regulations. Absorbent materials will be barreled on site and managed by the University EHS department. Depending on the size of the spill, recovered liquids will be stored in portable tanks or barrels. Petroleum-impacted soils will be stockpiled on site in accordance with MPCA guidance documents. Stockpiled soil will be place on an impermeable surface. Once soil stockpiling is complete, or overnight if stockpiling extends for more than one day, the stockpile will be covered with plastic to minimize potential runoff. 6.4 Spill Reporting Procedures If an uncontrollable petroleum spill creates an unsafe condition for University Personnel, evacuate the area immediately and call University Police Dispatch at or 911. In the event of uncontrollable spill, site personnel will follow procedures outlined in Section 6.5. Other information to be reported about the facility is available in the Tables, Figures, and Appendices of this plan. Spill response phone numbers are available in Section 2.0. Once the spill has been stabilized, the University representative will complete the Petroleum Spill Report.

22 6.5 Spill Response Procedures In the event of a spill, the individual discovering the spill will assess the situation as described below to determine if an unsafe condition exists if they are incapable of controlling, containing, or cleaning up the spill. The discoverer will report the spill to EHS at or to the Emergency Coordinator through 911 operators. Report all injuries, fires, explosions and potentially life threatening situations first to 911, and then to EHS Department. The individual discovering the spill will assess the situation to determine their ability to control or contain the spill, dependent on the following criteria, and will respond appropriately: 1. Protection of personnel, equipment and the local community. 2. If safe to do so, stop the source of spill (i.e., close valve, shut off pump, etc.). If in a fueling situation, and oil flows toward a storm sewer drain, deploy or check the drain cover over the drain and place a sand bag or other heavy weight as necessary to seal out any discharge to the sewer. If in the street, secure the area from traffic and pedestrians. 3. Notify EHS Emergency Coordinator during work hours or call 911 to allow the University Police to access the emergency response pager to contact EHS responders and any outside response organizations such as the fire department, Haz Mat teams and spill contractors. 4. Stop the flow of spilled material toward any pond, waterway, storm sewer or sanitary sewer with the use of spill response equipment stored in the TCEM building in carts for easy loading at the enclosed dock (see Figure 3). See Appendix E for a list of supplies available. 5. Remove spilled oil or oil product.

23 Emergency Response Contractors: Bay West, Inc. and West Central Environmental have been retained by the University to respond to spills on a 24-hour basis. These companies are supplied with all necessary containment and recovery equipment to handle any catastrophic spill at the University. Listings of response equipment are shown for Bay West in Appendix J, and for West Central Environmental in Appendix K. 6.6 Notification If fuel in excess of 5 gallons or quantity sufficient to have oil sheen in the receiving surface water is released to the environment, the University EHS representative shall notify by telephone the individuals listed on the spill and emergency call listed in Section 2.0. If coordination is required to repair or ventilate buildings, during the day call the Central Call Center at or after hours contact BSAC at If a major incident with injuries or that could disrupt University functions occur, call Emergency Management at Department Contacts for other facilities: Agriculture Services: Tom Warnke, Senior Administrator Office: After Hours Emergency: Steve Ziertman, Mechanic: After Hours Emergency: (home); (cel) Fleet Services (Como Area): Tony Bittner, Service Manager:

24 Office: After Hours Pager: Golf Course, Turf Management Center: Brent Belanger, Superintendent: Office: After Hours Emergency: Spill Response Equipment University-owned spill response equipment is stored in buildings where oil transfers occur. To access spill response equipment, contact the University EHS department. The spill response equipment available from the emergency response contractors is listed in Appendices J and K. 6.8 Media Contacts If news media involvement exists, contact: -Craig Moody: (Office) (Cell) (Pager) -U Relations: (Pager)

25 Section 7.0 Potential Spill and Flow Predictions Surface drainage from areas located outside, where tanker trucks are staged during unloading, typically drains to the storm sewer. Storm sewers discharge to the Mississippi River for the Minneapolis campus, and to Sarita Wetland in the southeast part of St. Paul campus. If a spill occurred during product transfer, fuel could potentially reach storm sewers and surface water. Specific storm sewers and collection points for each tank are shown on Appendix A. System-wide storm sewers outfalls for the Minneapolis campus are shown in Figures 13, 14, and 17 and for the St. Paul campus in Figures 15 and 16. To prevent potential spills during fueling from reaching the Mississippi River, additional spill prevention procedures, inspection and spill containment procedures are included in this plan under Section 7.1. The outlet structure at the Sarita Wetland will be used to control spills from this area and prevent discharge to an overflow storm sewer to the Mississippi River. 7.1 ASTs As indicated in Table 7.1 and Section 5, the ASTs are in various locations. None of the indoor ASTs will drain to the storm sewer. In the event of a catastrophic failure, several of these tanks could result in petroleum being released to the sanitary sewer regulated by the cities of Minneapolis and St. Paul, and the Metropolitan Council Environmental Services. Tank-specific sanitary sewer drains are shown in Appendix A. All of the outdoor ASTs are double-walled or have other secondary containment, therefore, in the event of catastrophic failure of any of these ASTs, petroleum would not be released unless both walls are breached. As discussed in Section 5.6, the fuel transfer areas are in various locations. In areas where a failure could cause oil flow to storm sewers, containment measures consist of absorbent materials stored on or near the fueling truck, and containment materials (SPCC kit) placed by the FM representative from the service vehicle. In addition, secondary containment for fill connections is installed on many ASTs and USTs to collect spillage during hook-up and removal. The storm sewers located near a tank or fuel transfer are shown for each site in Appendix A. The route of a

26 release to a storm sewer may be predicted from storm sewer maps shown in Figures 13, 14, 15, 16 and Hydraulic Elevator Areas As indicated in Table 7.2, the hydraulic elevators are located in many of the campus buildings. In the event of a catastrophic failure of the storage tank or a break in the pump delivery line, several of the elevators could result in petroleum being released into the storm or sanitary sewer. Sanitary sewer drains of hydraulic elevators are shown in Appendix B. The location of floor drains and direction of flow are shown in Table 7.2 and Appendix B. 7.3 Oil Filled Transformer Areas As indicated in Table 7.3, the oil-filled transformers are in various locations. None of the indoor transformers will drain to the storm sewers. In the event of catastrophic failure, several of these transformers could result in petroleum released to the sanitary sewer. Transformer specific sanitary sewer drains are shown in Appendix C. Most of these outdoors transformers have no secondary containment. If a leak were to occur, a spill kit containing absorbent pads would have to be picked up from FM. The storm sewers located near each transformer are shown in Appendix C and in the storm sewer map shown in Figures 13, 14,15, 16, and Drum Storage Areas As indicated in Table 7.4, the drum storage areas are in various locations in several campus buildings. None of the drum storage areas will drain to the storm sewer. In the event of a drum rupture, 27 of the drum storage areas could result in a petroleum release into the sanitary sewer. Drums in these areas will be provided with secondary containment adequate to hold the volume of the largest drum. The sanitary floor drains will be covered during transport of these drums. These drains are shown in Table 7.4 and Appendix D.

27 7.5 Fat and Grease Storage Areas As indicated in Table 7.5, the fat and grease storage areas are in various locations. The grease collection dumpsters are double-walled containers, therefore, in the event of a wall rupture a release of grease would not occur unless both walls were ruptured. If a catastrophic failure were to occur, it is possible that grease would be released into the storm sewers. The most probable way for a spill to occur would be for the dumpster to be rolled off the loading docks or accidentally tipped over. The fat and grease dumpsters will be secured in such a fashion as to prevent them from being inadvertently moved and tipped over. These drains are shown in Appendix E and the storm sewers are shown in Figures 13, 14, 15, 16, and Proper Containment Containment structures are summarized in Tables 7.1, 7.2, 7.3, 7.4, and 7.5. Items within adequate secondary containment or diversionary structures are marked in bold lettering in Table 7.1, 7.2, 7.3, 7.4, and 7.5.

28 Section 8.0 Inspections and Records 8.1 ASTs The system of tanks, pumps, lines, dikes and equipment are visually inspected on a monthly basis, during the scheduled maintenance check. The standby generators are run as part of this check. Generators are also inspected after they operated due to power failure incident. This affirms continued safe utility for spill prevention and control. Inspection report forms have been developed for tanks, associated piping and pumps, the dike and containment area. These forms are located in FM office. The forms are integrated to meet the needs of operations, maintenance, safety, loss control and spill prevention (example checklist in Appendix H). Other departments listed in Appendix F also use this checklist. External inspection of the ASTs, associated piping and containment areas are performed by FM District Maintenance personnel and recorded on Work Order. The site specific testing and maintenance is shown in Appendix A. If any evidence of tank or piping failure or fuel leakage are observed during inspection, the leak or failure is immediately corrected and reported to FM or other departments shown in Appendix F to arrange corrective action. If the leakage or failure cannot be immediately corrected, the tank will be taken out of service until the leakage or failure is corrected. Complete inspection and test records will be kept on file for a period of at least three years. 8.2 Hydraulic Elevators The University Elevator Shop personnel or a designated elevator repair contractor visually inspects the hydraulic elevator system of tanks, pumps, lines and equipment on a monthly basis. The monthly maintenance of the elevators includes cleaning of the elevator equipment rooms and elevator pits. Any oil that has been collected in the fivegallon buckets from seal leakage is returned to the tanks. Any oil that has overflowed onto the floor is cleaned up using oil dry absorbent pads. A visual inspection for leaks is conducted any time non-routine maintenance is performed. The monthly inspections

29 must be performed and documented. Completed inspection and test controls are kept on file for a period of at least three years. 8.3 Oil Filled Transformers The high voltage transformers are cleaned and inspected on an annual basis by University high voltage electricians. Leak is usually discovered when a transformer heats up and fails. Complete inspection and test records are kept on file for a period of a least three years. 8.4 Drum Storage There is no current policy for the regular inspection of the drums in the drum storage areas. All drums are stored in areas where a large lead would be easily detected. A routine inspection plan for storage drums by FM District Maintenance personnel will be written, implemented, and documented. Completed inspection and test records will be kept on file for a period of at least three years. 8.5 Fat and Grease Storage There is no current policy for the regular inspection of the fat and grease storage containers. All storage dumpsters are in areas where a large leak would be easily detected. A routine inspection plan of fat and grease storage dumpsters by FM District Maintenance personnel will be written, implemented, and documented. Completed inspection and test records will be kept on file for a period of at least three years.

30 Section 9.0 Personnel Training Awareness and training is an integral part of the University Emergency Response Plan. Training activities for spill prevention and spill control are conducted under the leadership of EHS department. Training components include Spill prevention and spill response Inspection and maintenance of tanks, pumps, lines, dikes and signs Proper procedures for filling and pumping (flow control) Lines of reporting and authority Safe exit routes Individual assignments during spill response Hazard identification Energy/fire control Drainage control during spill response Proper use of spill response tools Procedures for recovering spilled material. Training is provided for new hires, with a refresher course for all employees conducted every two years, or whenever the SPCC plan changes, whichever is most frequent. New employees also learn procedures via on-the-job training as an apprentice or intern prior to taking on full responsibility for their assignment. Spill response-training personnel for the EHS department are shown in Table A training program for discharge prevention is set up for the FM departments for refueling, tank inspections, and maintenance. Trained personnel responsible for discharge prevention from the FM District are shown in Table Training is also set up for Agriculture Services, Fleet Services, and Golf Course Turf Management Center personnel listed in Table 10.3.

31 Section 10 Security Primary security for the oil-containing equipment in the three areas is provided by individual building locks, equipment locks, fill cap locks, and University Police patrol. Grounds/Transportation also has barricades and related equipment to secure any site requiring additional security Fencing When practical, all tanks and operating equipment are located inside buildings or in securely fenced areas. For some of the outside transformers, fencing is not practical. To meet SPCC requirements, regular University Police patrols will be used for security Master Flow Drain Valves All master flow drain valves and other valves permitting direct outward flow of the content of AST to the ground are place in a closed position and locked, or secured in a locked structure, when in use Starter Controls Locked The starter controls for each oil transfer pump are locked, or secured in a locked structure, when not in use Unloading Connections Pipelines are securely capped or blank-flanged when not in service, or in standby service for an extended period of time Lighting All tanks located inside buildings have adequate lighting to detect spills resulting from tank or piping failure. All of the oil-filled transformers that are located outside lack lights

32 or have inadequate lighting. Therefore, regular University Police patrols will be used to detect spills. Transformer failure caused by loss of oil will require a response from the electricians.

33 Section 11.0 Loading and Unloading 11.1 Secondary Containment The University does not operate any loading racks, and secondary containment is not required for delivery vehicles. Portable dike material and sewer covers are use in placed or secondary containment Unloading Spill Prevention Precaution All tanker truck unloading procedures are performed under the direction and supervision of FM Department authorized representative, or the equivalent owner s representative for non-facility locations. Upon arrival, tank truck operators are informed by the FM representative which tank to fill and how much capacity the selected tank has available, and follows the delivery procedures in Appendix F. Site tanks are never filled to 100% capacity in order to allow for expansion space. Inventories are measured in each tank, according to a monthly schedule. A visual gauge is used to monitor the liquid level in the tank before and during fuel transfer. The tank truck operator also has a whistle gauge to monitor the distance between the fill hose and tank level. Before each filling operation, the FM representative will lay down a portable dike from the SPCC kit, between the fuel tanker hose connection and the storm sewer, and cover the drains of the primary storm sewers. The representative will then complete the checklist for fueling operations (example checklist in Appendix G). After conferring with the FM representative, the tank truck operator pumps (or gravity flows) the material into the designated tank. After the tank is filled to the designated level, the operator disconnects the transfer hose. If incidental spilling occurs during hose disconnection, the operator absorbs the spilled material with absorbent pads. The absorbent material will be disposed of properly. The tank truck operator is responsible to ensure all drains, valves and outlets on the truck are tightly closed with no leakage.

34 The FM representative verifies that the proper fuel capacity was transferred to the proper tank and that no significant spillage occurred during the transfer.

35 Section Regulatory Conformance The MPCA requires secondary containment and/or diversionary structures for all aboveground tanks, operating equipment and loading areas. Underground storage tanks meet requirements of MPCA UST regulations, including cathodic protection, double-walled constructions and monitoring systems.

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