OREGON DEPARTMENT OF TRANSPORTATION SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN

Transcription

1 OREGON DEPARTMENT OF TRANSPORTATION SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN for the MADRAS MAINTENANCE YARD 201 NW Cherry Lane Madras, OR Region: 4 District: 10 Property EA: F41602 prepared on: April 30, 2015 prepared by: ODOT Maintenance and Operations Branch

2 INTRODUCTION The Oregon Department of Transportation (ODOT) is responsible for the maintenance and operation of over 8,000 center lane miles of Oregon roads. ODOT Maintenance yards act as hubs for activities required for the upkeep of this system. Personnel at these facilities are responsible for the day-to-day maintenance operations of ODOT roadways. The agency recognizes that materials and activities at its yards have the potential to impact Oregon s environment. Maintenance yards are used to store equipment and products (including oil, fuel, and asphalt) required to perform road maintenance activities. In addition to material and equipment storage, some of the facilities provide permanent and temporary employee housing to meet the needs of the agency. ODOT considers heating oil and other fuel stored in association with employee housing to be part of the facility s Spill Prevention Control and Countermeasure (SPCC) Plan. ODOT Maintenance yards are considered on a site-by-site basis to determine if the facility met the criteria specified in 40 CFR Part 112 Oil Pollution Prevention. Facilities that met the oil volume criteria are assessed to determine if an oil discharge could impact navigable water. Conditions considered when determining whether a spill could reach navigable water include, but are not limited to, nearness of the facility to water or intervening natural drainage, onsite conduits (e.g. storm drains and ditches) that could ease transport of oil, volume of oil/fuel likely to be spilled, past discharges, and geological and geographical features. SPCC regulations specify the volume of secondary containment required for oil storage containers. Secondary containment requirements for oil-related activities and oil-filled equipment are goal-oriented. ODOT assessed typical oil transfer activities (such as fuel dispensing and used oil collection) and determine the appropriate volume of secondary containment. Secondary containment assessments (located in Appendix B) define the maximum volume of the most likely spill from oil transfer activities, oil-filled pipelines, and oilfilled operational equipment, should a release occur. The assessments consider possible causes of failure, discharge rates, durations, and reaction/detection time. SPCC Plans specifically outline structural and non-structural best management practices (BMPs) for oil storage at ODOT Maintenance yards that meet the SPCC criteria. Additional BMPs are listed in the ODOT Maintenance Environmental Management System (EMS). The EMS provides consistent guidance for all ODOT Maintenance yards. The ODOT Maintenance Yards EMS Policy and Procedures Manual (EMS Manual) contains procedures and directives on the storage, use and handling, and disposal of materials commonly used in the operation and maintenance of the state highway system, including oil. The intent of the EMS procedures is to translate regulatory requirements and agency expectations into straightforward BMPs and guidance. EMS and SPCC requirements have been combined where possible. One of the elements of the EMS program is the Maintenance EMS Monthly Field Audit (EMS Monthly Audit). The EMS Monthly Audit is completed by local Maintenance forces and evaluates storage areas, work areas, facility drainage, and facility security. Actions taken to resolve issues identified in the EMS Monthly Audit are recorded on the Maintenance EMS Monthly Audit Corrective Action Sheet (EMS Corrective Action Sheet). A blank copy of the EMS Monthly Audit is located in Appendix B of this document. Madras Maintenance Yard Page 1 of 34

3 Implementation of BMPs in both the SPCC Plan and the EMS Manual provide reasonable assurance that oil, in quantities that may be harmful, will not be discharged into or upon the navigable waters of the United States or adjoining shorelines from these locations. Harmful quantities are outlined in 40 CFR Part 110 Discharges of Oil and include quantities that cause a sheen on the water, a sludge deposit under the water, or that violate a water quality standard. ODOT Maintenance yards do not have the potential to cause substantial harm as described in 40 CFR (f) and therefore are not required to prepare a Facility Response Plan. Certification of no substantial harm is located in the Applicability of the Substantial Harm Criteria section of this document. This Plan has been prepared in the sequence specified in 40 CFR SPCC regulations and references are printed in italics. In some cases the SPCC regulation has been summarized, these occurrences will be identified by the word summary prior to the regulatory code number. Citations are followed by discussion on how the facility meets the regulation. BACKGROUND SPCC Plans are required for owners or operators of non-transportation related 1 onshore and offshore facilities engaged in gathering, storing, transferring, distributing, or consuming oil and oil products which: a) Due to their location, could reasonably be expected to discharge oil in quantities that may be harmful into or upon the navigable waters of the United States or adjoining shorelines. and b) Have more than 1,320 gallons of oil stored in containers with a capacity of 55 gallons or greater or have at least 42,000 gallons of oil stored in underground tanks or are required to have an SPCC Plan by the EPA Regional Administrator in order meet the purpose of the Clean Water Act (CWA). (Summary of 40 CFR 112.1(2)) Once a yard is determined to meet the SPCC criteria, all aboveground oil containers and all underground oil tanks (not already regulated by other state and federal law) are subject to the SPCC regulation. Containers with a storage capacity of less than 55 gallons are exempted from secondary containment requirements. (Summary of 40 CFR 112.1(1)) Some sections of the SPCC regulations provide specific requirements (e.g. warn vehicles entering the facility of aboveground piping). However, SPCC regulations are performancebased, with an overall goal of preventing oil spills that may impact navigable water, so flexibility is allowed. The implementation of environmentally equivalent measures demonstrate compliance with the regulation even when a specific requirement is not being met. Alternatives are considered environmentally equivalent when equal environmental protection is provided. For example, protecting piping from possible collision may be considered environmentally equivalent to warning drivers. The selection of alternative measures may be based on various considerations including safety, cost, geographic constraints, and appropriateness of a particular requirement. Alternative measures cannot rely solely on actions and procedures that are already required by other parts of the rule. The reason for nonconformance with the regulation must be stated within the Plan and the alternative method must be certified by a Professional Engineer (PE). (Summary of Section 3.1 Environmental Equivalence of the SPCC Guidance for Regional Inspectors, dated 11/28/05) 1 See the definition section of this document for an explanation of non-transportation related facility. Madras Maintenance Yard Page 2 of 34

4 Equivalent environmental protection is not allowed for secondary containment. However, secondary containment may be determined impractical when installation is not possible by any reasonable method. Impracticality may be based on considerations such as space and geographic limitations, local zoning ordinances, fire codes, or safety. Economic cost may be considered a factor of impracticality, but may not be used as the sole justification. Alternative methods of protection must be implemented when secondary containment is deemed impractical. SPCC regulations contain both general and specific secondary containment provisions. General provisions address the most likely oil discharge and specific provisions address major container failures. (Summary of Section 4.1 Secondary Containment and Impracticability Determinations of the SPCC Guidance for Regional Inspectors, dated 11/28/05) A complete copy of the SPCC Plan must be maintained at the facility, if the facility is normally attended at least four hours per day or at the nearest field office if the facility is not so attended. The SPCC Plan must be available to the Environmental Protection Agency (EPA) Regional Administrator for onsite review during normal working hours. (Summary of 40 CFR (e)) REVISIONS, AMENDMENTS, AND PERIODIC EVALUATIONS Summary of 40 CFR Amendment of Spill Prevention, Control, and Countermeasure Plan by Regional Administrator. If the facility discharges more than 1,000 gallons of oil in a single incident or discharges more than 42 gallons of oil in each of two incidents into navigable water, within any twelve-month period, additional information regarding the spill(s) must be submitted to the EPA Regional Administrator. The EPA Regional Administrator may require that the SPCC Plan be amended after such occurrences. Summary of 40 CFR 112.5(a) - Amendment of Spill Prevention, Control, and Countermeasure Plan by owners and operators. The SPCC Plan must be amended whenever there is a change in facility design, construction, operation or maintenance that materially affects the facility's potential for the discharge of oil into or upon the navigable waters. Such amendments must be prepared within six months, and implemented as soon as possible, but not later than six months after preparation. Summary of 40 CFR 112.5(b) - A review and evaluation of the SPCC Plan must be completed at least once every five years. The SPCC Plan must be amended within six months of the review to include more effective prevention and control technology if: 1. Such technology will significantly reduce the likelihood of a spill event from the facility, and 2. Such technology has been field-proven at the time of the review. The review and evaluation must be documented. The documentation must include a signed statement as to whether the SPCC Plan will be amended. Summary of 40 CFR 112.5(c) - A Professional Engineer must certify any technical amendments. This SPCC Plan for the Madras Maintenance yard has been prepared in accordance with regulations and amendments effective November 10, Amendments to this SPCC Plan resulting from periodic reviews and/or spill events will follow the timelines outlined in 40 CFR and The reason for amendment will be noted in Section 1 - Conformance with Requirement. The original text and regulatory citations will be left in place. Substantive changes will be bolded and will include the date of the amendment. The SPCC Plan History section of this document provides an ongoing record of revisions, periodic evaluations, and amendments to the SPCC Plan for this facility. Madras Maintenance Yard Page 3 of 34

5 PROFESSIONAL ENGINEERS CERTIFICATION 40 CFR 112.3(d) A licensed Professional Engineer must review and certify a SPCC Plan for it to be effective to satisfy the requirements. 40 CFR 112.3(d)(1) By means of this certification the Professional Engineer attests: (i) I am familiar with the requirements of 40 CFR Part 112 Oil Pollution Prevention; (ii) I or my agent has visited and examined this facility; (iii) This SPCC Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of this part; (iv) Procedures have been established for required inspections and testing; and (v) This SPCC Plan is adequate for the facility. 40 CFR If you are the owner or operator of a facility subject to this part you must prepare a Plan in accordance with good engineering practices. The Plan must have the full approval of management at a level of authority to commit the necessary resources to fully implement the Plan. You must prepare the Plan in writing. If you do not follow the sequence specified in this section for the Plan, you must prepare an equivalent Plan acceptable to the Regional Administrator that meets all of the applicable requirements listed in this part, and you must supplement it with a section cross-referencing the location of requirements listed in this part and the equivalent requirements in the other prevention plan. If the Plan calls for additional facilities or procedures, methods, or equipment not yet fully operational, you must discuss these items in separate paragraphs, and must explain separately the details of installation and operational startup. I am familiar with the requirements of 40 CFR Part 112. Either I, or my agents, have visited and examined this facility. This SPCC Plan has been prepared in the sequence specified in This SPCC Plan has been carefully thought-out and was prepared in accordance with good engineering practices. The designing engineer has certified containment structures, rate of flow calculations, and drainage modifications. If procedures, methods, or equipment are not yet fully operational, the details are discussed within the body of this Plan. This Plan has the full approval of the ODOT Maintenance and Operations Branch. The Plan has been reviewed by the local manager directly responsible for the facility. Procedures have been established for required inspections and testing. I believe that implementation of this Plan provides adequate protection of navigable water from reasonable discharge of oil. Lucinda M. Moore, PE State Maintenance Engineer Date Madras Maintenance Yard Page 4 of 34

6 TABLE OF CONTENTS Introduction... 1 Background... 2 Revisions, Amendments, and Periodic Evaluations... 3 Professional Engineers Certification... 4 Table of Contents Conformance with Requirements Facility Description Oil Storage Discharge Prevention Measures Discharge and Drainage Controls Countermeasures Disposal of Recovered Materials Contacts Response Plan Information and Procedures Emergency Procedures Potential Discharges Due to Equipment Failure Secondary Containment of Potential Discharges Secondary Containment or Diversion Not Practicable Inspections, Tests and Records Training Training Designated Person Discharge Prevention Briefings Security Tank Car and Tank Truck Load/Unloading Rack Loading/Unloading Rack Secondary Containment Adequate Warning Systems for Disconnect to Transfer Lines Bulk Tanker Truck Inspection Prior to Departure Field-Constructed Aboveground Containers Applicable State Requirements Oil-Filled Operational Equipment Specific Discharge Prevention and Containment Facility Drainage Oil Storage Containers Piping Definitions Applicability Of The Substantial Harm Criteria SPCC Requirements At A Glance SPCC Plan History Appendices A MAPS AND SITE DRAWINGS B SECONDARY CONTAINMENT ASSESSMENTS AND DRAWINGS C FORMS D OPERATIONS & MAINTENANCE MANUALS The italicized portions of the following document are citations of applicable portions of the regulation. Madras Maintenance Yard Page 5 of 34

7 1 CONFORMANCE WITH REQUIREMENTS 40 CFR (a)(1) Include a discussion of your facility's conformance with the requirements listed in this part. Summary of 40 CFR 112.7(a)(2) Comply with all applicable requirements listed in this part. Your Plan may deviate from the requirements, with the exception of secondary containment requirements for tanks and portable containers, so long as equivalent environmental protection is provided by some other means. You must state the reasons for non-compliance in your Plan and describe in detail alternative methods and how you will achieve equivalent environmental protection. The Madras Maintenance yard currently complies with all the requirements of 40 CFR 112. Specific secondary containment has been provided for oil containers 55 gallons or greater with the exception of portable paving oil equipment that described below. Secondary containment is discussed in Sections and of this document. Size specific secondary containment has been determined impractical for the portable paving oil tank. Impracticality determinations are allowed provided periodic integrity tests are performed. In addition, there must be an emergency plan and a written commitment of manpower and materials to cleanup the spill. These conditions have been met and are discussed in Sections 3.4 and of this document. General secondary containment has been installed for potential oil discharge areas. Potential oil discharge areas are discussed in Section 3.3. Environmentally equivalent protection is provided for the following: Warning vehicle about aboveground piping ( 112.8(d)(5)). See Section for details. Security measures, routine inspections, employee training, and emergency procedures have been established and implemented (Sections 6, 4, 5, and 3.1 respectively). 2 FACILITY DESCRIPTION 40 CFR (a)(3) Describe in your Plan the physical layout of the facility and include a facility diagram, which must mark the location and contents of each fixed oil storage container and the storage area where mobile or portable containers are located. The facility diagram must identify the location of and mark as exempt underground tanks that are otherwise exempted from the requirements of this part under 112.1(d)(4), and produced water containers and any associated piping and appurtenances downstream from the container, that are otherwise exempted from the requirements of this part under 112.1(d)(12). The facility diagram must also include all transfer stations and connecting pipes, including intra-facility gathering lines that are otherwise exempted from the requirements of this part under 112.1(d)(11). Madras Maintenance Yard is located on the south side of NW Cherry Lane; east of the intersection of NW Cherry Lane and Highway 26. The site is rectangular with an inner curve along the southeast boundary. The facility occupies approximately 10-acres of property owned by ODOT. The property is fenced at the perimeter and is accessible by a gated driveway near the center of the north property boundary. The gate is operated on an automatic locking mechanism and is kept unlocked during operational hours. Madras Maintenance Yard Page 6 of 34

8 Approximately 30-percent of the property is improved with asphalt pavement or buildings. Impervious areas are located at the northwest corner of the property. Pervious portions of the property are graveled. In general, the property slopes gently downward toward the east and south. No stormwater catch basins are located onsite. Stormwater sheetflows off impervious surfaces. Stormwater flows toward an onsite infiltration pond. The location of the pond and impervious area are shown on the site diagram. Overflow from the stormwater pond occasionally flow under the fence and into the roadside ditch The property adjoins Siphon Creek at approximately river mile 2. According to DEQ s online records Siphon Creek is a tributary to Willow Creek (about 1 mile southwest of the property). A large earthen dike protects Siphon Creek. Water from the ditch flows under the road toward a low spot on the north side of the dike. The facility does not discharge into Siphon Creek. A topographic map, aerial photograph, and site diagram are located in Appendix A of this document. 2.1 Oil Storage You must also address in your Plan: 40 CFR (a)(3)(i) The type of oil in each fixed container and its storage capacity. For mobile or portable containers, either provide the type of oil and storage capacity for each container or provide an estimate of the potential number of mobile or portable containers, the types of oil, and anticipated storage capacities; Table 1 provides general information on oil storage containers located at this facility. Oil-filled equipment, mobile refuelers, and motive power containers are discussed in Sections 10 and Oil containers with a shell capacity of less than 55 gallons are addressed in the EMS Manual and are not considered in this SPCC Plan. Table 1 Bulk Oil Containers (fixed location) Tank ID Volume Description Contents 234 6,000 gallons Double-walled tank Diesel F41602-UO gallons Double-walled tank Used oil Underground Storage Tanks (USTs) Tank ID Volume Contents None Mobile / Portable Containers Quantity Volume Description Typical Location 1 90 gallons Mobile refueler diesel Shop Building gallons Paving oil tank Pole Building Various 55 gallons Drum new oil - various Shop Building Madras Maintenance Yard Page 7 of 34

9 2.2 Discharge Prevention Measures 40 CFR (a)(3)(ii) Discharge prevention measures including procedures for routine handling of products (loading, unloading, and facility transfers, etc.); General BMPs for oil handling are listed in the EMS Manual. BMPs include locating absorbent in oil handling areas, keeping containers closed, storing containers on a paved surface, and storing containers indoors. Additional discharge prevention measures are discussed in Sections 4, 5, 6, 7, 10, and 11 of this document. 2.3 Discharge and Drainage Controls 40 CFR (a)(3)(iii) Discharge or drainage controls such as secondary containment around containers and other structures, equipment, and procedures for the control of a discharge; The Madras Maintenance yard has spill cleanup materials onsite and has employees trained in spill prevention and response. Spill cleanup supplies are located inside the shop and near the fuel dispenser. Supplies consist of various absorbent materials (e.g. pads, pillows, booms, and granular). Specific control measures are discussed in Sections 3.3, 10, and 11 of this document. 2.4 Countermeasures 40 CFR (a)(3)(iv) Countermeasures for discharge discovery, response, and cleanup (both the facility's capability and those that might be required of a contractor); Discovery of spills, should spills occur, is discussed in Sections 3.3, 10, and 11 of this document. Detection and response times may also be listed in the secondary containment assessment located in Appendix B of this document. Countermeasures for response and cleanup are located in Section of this document, in the EMS Manual, in the "ODOT First Responders Guide to Highway Incident Response" and in the "ODOT Emergency Operations Plan" in the Chapter on Incident Management. In addition, ODOT hires a qualified environmental contractor for environmental services outside the scope and training of ODOT employees. 2.5 Disposal of Recovered Materials 40 CFR (a)(3)(v) Methods of disposal of recovered materials in accordance with applicable legal requirements; and Recovered materials are managed according to State and Federal regulations. Oil-contaminated absorbent from cleaning small spills, leaks, and drips is managed as solid waste (e.g. taken to a permitted landfill or a used oil recycler). Solid waste disposal is allowed provided the absorbent is saturated but not dripping. Refer to the EMS Manual for additional information on the disposal of oil saturated absorbent. Madras Maintenance Yard Page 8 of 34

10 Cleanup and disposal of oil-contaminated materials from significant releases (e.g. reportable spills), should such releases occur, are completed in conjunction with the ODOT Region HazMat staff. 2.6 Contacts 40 CFR (a)(3)(vi) Contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with whom you have an agreement for response, and all appropriate Federal, State, and local agencies who must be contacted in case of a discharge as described in 112.1(b). Oregon Emergency Response System National Response Center Emergency Services (Police, fire, ambulance) 911 EPA Environmental Hot Line Contact the Transportation Operation Center ( ) or consult the "ODOT First Responders Guide to Highway Incident Response" for additional contacts Owner ODOT District N. Highway 97, Bend, OR Operator ODOT District 10 North PO Box 339, Prineville, OR Facilities Management ODOT Facilities Department 855 Airport Road SE, Salem, OR Individual Contacts Name Title Telephone Pat Creedican (or incumbent) District 10 Manager Jim Scholtes (or incumbent) Assistant District 10 Manager Richard Foltz District 10 North Transportation Maintenance Manager (or incumbent) (Madras is part of the D10-North maintenance area) RESPONSE PLAN INFORMATION AND PROCEDURES 40 CFR (a)(4) Unless you have submitted a response plan under , provide information and procedures in your Plan to enable a person reporting a discharge as described in 112.1(b) to relate information on the exact address or location and phone number of the facility; the date and time of the discharge, the type of material discharged; estimates of the total quantity discharged; estimates of the quantity discharged as described in 112.1(b); the source of the discharge; a description of all affected media; the 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; and, the names of individuals and/or organizations who have also been contacted. Madras Maintenance Yard Page 9 of 34

11 This SPCC Plan and appendices provide sufficient information to enable a person to report a discharge to the appropriate agencies. The "Spill Response Notification Form for Spills in Maintenance Yards" located in Appendix C of this document will be used to record information about a reportable spill, should such an event occur. Spill notification procedures are also located in the EMS Manual and in the "ODOT Emergency Operations Plan. 3.1 Emergency Procedures 40 CFR (a)(5) Unless you have submitted a response plan under , organize portions of the Plan describing procedures you will use when a discharge occurs in a way that will make them readily usable in an emergency, and include appropriate supporting material as appendices. Emergency procedures are contained in the "ODOT First Responders Guide to Highway Incident Response" and the "ODOT Emergency Operations Plan. Emergency contact information is posted near the SDS book. Contact information is updated as needed. 3.2 Potential Discharges Due to Equipment Failure 40 CFR (b) Where experience indicates a reasonable potential for equipment failure (such as loading or unloading equipment, tank overflow, rupture, or leaks, or any other equipment known to be a source of a discharge), include in your Plan a prediction of the direction, rate of flow, and total quantity of oil which could be discharged from the facility as a result of each type of major equipment failure. ODOT Assessments of Appropriate Secondary Containment describe general oil release scenarios that have a possibility of occurring at ODOT Maintenance yards. These secondary containment assessments provide details on the activity/equipment, maximum spill volume (should such an event occur), and predicted discharge rates. Releases of reportable quantities of oil occur infrequently at ODOT Maintenance yards. Assessments for oil-related activities and equipment at this facility are included in Appendix B. Site-specific volume calculations are included, where necessary, in secondary containment designs. BMPs for minor equipment failures (e.g. drips during oil handling) are located in the EMS Manual. Spills and leaks are cleaned up promptly. Oil transfers, piping, and/or oil-filled equipment at this facility that have a potential to impact navigable water (should a catastrophic release occur and should secondary containment measures fail) are summarized in the table below. Oil transfers, piping, and/or oil-filled equipment that have been determined by a secondary containment assessment as having a small spill volume are not included in this table unless the activity occurs in a high risk area (e.g. near a stormdrain). Details are provided in Section 3.3 of this document. Source Most likely type of failure Most likely volume of oil Maximum rate of discharge Predicted flow pathway Quick connect delivery of bulk fuel Rupture of fuel hose or failed connection 96 gallons plus tributary flow 200 gal/min South into concrete containment structure Used oil pickup from tank Overfilling collection tank 15 gallons 60 gal/min Retained on asphalt on west side of shop Madras Maintenance Yard Page 10 of 34

12 Source Most likely type of failure Most likely volume of oil Maximum rate of discharge Predicted flow pathway Fuel dispensing Nozzle falling out of vehicle 15 gallons 40 gal/min Southeast into gravel or infiltration pond Shop lube lines Hose rupture 55 gallons 14 gal/min Shop floor drains then closed loop system 3.3 Secondary Containment of Potential Discharges 40 CFR (c) Provide appropriate containment and/or diversionary structures or equipment to prevent a discharge as described in 112.1(b), except as provided in paragraph (k) of this section for qualified oilfilled operational equipment, and except as provided in 112.9(d)(3) for flowlines and intra-facility gathering lines at an oil production facility. The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system, such as a tank, will not escape the containment system before cleanup occurs. In determining the method, design, and capacity for secondary containment, you need only to address the typical failure mode, and the most likely quantity of oil that would be discharged. Secondary containment may be either active or passive in design. At a minimum, you must use one of the following prevention systems or its equivalent: (1) For onshore facilities: (i) Dikes, berms, or retaining walls sufficiently impervious to contain oil; (ii) Curbing or drip pans; (iii) Sumps and collection systems; (iv) Culverting, gutters, or other drainage systems; (v) Weirs, booms, or other barriers; (vi) Spill diversion ponds; (vii) Retention ponds; or (viii) Sorbent materials. General secondary containment is required for areas and activities that have a potential to discharge oil into navigable water. Potential discharges have been grouped into two categories: oil transfer activities and oil-filled pipelines. Oil-filled operational equipment is discussed in Section 10. Appropriate secondary containment volumes have been identified in the assessments described in Section 3.2. Copies of assessments that are applicable for this facility are located in Appendix C of this document. Site specific factors and methods for providing secondary containment are described in the following sections. Size specific secondary containment measures for bulk containers, including mobile/portable containers, are listed in Section 11.2 of this document Transfer Areas A transfer operation is when oil is moved from one piece of equipment or storage device into another piece of equipment or storage device (e.g. dispensing fuel into a gas tank, delivering fuel into a bulk tank, or placing used oil into a tank). Madras Maintenance Yard Page 11 of 34

13 Bulk Fuel Delivery Secondary containment for bulk fuel delivery is provided by a secondary containment structure on the south side of the fuel tank. The structure was constructed during the spring of The containment structure consists of a three-sided, concrete pad with a manually operated valve at the low point. The fill pipes for the fuel tanks are situated so the tanker truck must be inside the containment structure in order to deliver fuel. The drainage valve is closed prior to delivering fuel. The valve is kept open when fuel is not being unloaded to provide drainage for the structure. Water leaving the structure discharges onto the ground surface. Highly visible instructions directing the fuel delivery driver to close the containment valve prior to filling the fuel tank are posted near the valve handle. Quick connection couplings are used to connect transfer hoses to the fuel tank. Based on the current configuration of the fuel delivery area, containment measures should be able to contain at least 96 gallons plus tributary flow. The containment structure has a storage capacity of 1,320 gallons. The designing engineer has determined that this capacity provides adequate containment for bulk fuel delivery plus sufficient freeboard. A copy of the design is located in Appendix B of this document. A generic Operations and Maintenance (O&M) Manual for the containment system is located in Appendix D of this document. The O&M Manual outlines crew responsibilities, operating instructions, periodic maintenance, and required inspections. Delivery drivers are expected to follow industry standards for spill prevention (e.g. utilize spill buckets or drip pans). ODOT expectations for fuel delivery drivers (in addition to industry standards) have been added to contracts between ODOT and fuel vendors. The Transportation Maintenance Manager is responsible for reviewing these expectations with the facility s fuel delivery drivers as necessary. Fuel Dispensing Secondary containment for fuel dispensing is provided by absorbent materials. ODOT policy requires drivers to remain with vehicles and equipment while dispensing fuel. Based on the secondary containment assessment, containment measures should be able to retain 15 gallons of oil. 'Oil-only' absorbent pads, pillows, and booms (or equivalent spill cleanup supplies), are kept in a labeled, weatherproof container near the fuel tank. The materials are sufficient to retain at least 20 gallons of fuel. In the event of a spill, the person dispensing the fuel is expected to use the materials inside the kit to cleanup the fuel. Materials are replenished when used. In addition, the drain valve for the containment basin may be closed to prevent a spill from flowing away from the fueling area. Madras Maintenance Yard Page 12 of 34

14 New Oil, Used Oil, and Routine Equipment Maintenance Occasionally new oil may be pumped from one drum to another using an electric, manually operated pump. The transfers occur within the shop and an employee is present during the entire transfer. A spill would likely be less than a quart and would only occur while the pump was turned on. Absorbent pads and grease sweep are stored in the shop. During routine oil changes, used oil is drained from equipment into a mobile sump. If the equipment is positioned improperly, the maximum potential spill during this activity is 11 gallons (the entire oil capacity of the engine a large truck). Used oil is pumped from the sump into a used oil tank with an air activated pump. Based on the secondary containment assessment, containment measures should be able to retain up to a quart of oil. The floor drains in the shop flow to a closed loop water treatment system. The shop floor is sloped to direct liquids toward the floor drains. This provides secondary containment for all oil transfer activities that occur within the shop. Absorbent pads and grease sweep are stored in the bay. Staged Paving Equipment Paving activities occur offsite during the spring and summer. Paving equipment is filled offsite, as needed, during the paving season. Specific secondary containment measures for portable containers are located in Section of this document. Refueling Backup Generator A backup generator is not installed at this facility. This section is not applicable Pipelines and Flowlines Aboveground piping is visually inspected monthly for signs of leaks, damage, or deterioration. Inspections are completed monthly using the EMS Monthly Audit. Repairs are completed as needed and are documented on the EMS Corrective Action Sheet. Specific requirements for pipes under 112.8(d) are located in Section 11.3 of this document. Fuel Piping Secondary containment is provided by concrete pavement under the piping. The fuel dispenser is mounted on a concrete pad on the west side of the fuel tank. Based on the secondary containment assessment, containment measures should be able to retain 5 gallons of fuel. Containment measures should not require a quick response time to be effective. If a release occurred for piping between the fuel tank and the dispenser, the fuel would likely be retained on the concrete pad, flow into the concrete containment structure, or seep into the surrounding gravel. Based on the small quantity of fuel and the porosity of the surrounding soil, a spill is unlikely to impact navigable water. If a release occurred, fuel would be cleaned up promptly once the spill was discovered. Madras Maintenance Yard Page 13 of 34

15 Piping for delivering fuel into the tank is emptied by the delivery driver; secondary containment is not required. Lube Lines Lube lines deliver oil and grease from drums in the storage bay to hose reels mounted on the ceiling of the lube bay. Based on the secondary containment assessment, containment measures should be able to retain 55 gallons of oil. Containment measures should not require a quick response time to be effective. A release from the ceiling mounted reels would flow into the shop floor drains. The floor drains are connected to a closed loop waste water treatment system located near the wash rack. Secondary containment is provided by the closed loop water recycling system. A spill, should such an event occur, would be contained within the system. Used Oil Pipelines Secondary containment is provided by the pavement under the piping and by absorbent materials stored in the shop. Oil is transferred from a mobile sump to a tank (located on the west side of the shop) through a fixed pipe system using an air activated pump. An employee must manually activate the pump to transfer the oil. Employees verify that sufficient capacity is available in the tank before operating the pump control. Based on the secondary containment assessment, containment measures should be able to retain a small pool of oil (less than 1 quart). If a release occurred, oil would be cleaned up promptly using spill cleanup supplies stored in the shop bays. 3.4 Secondary Containment or Diversion Not Practicable 40 CFR (d) Provided your Plan is certified by a licensed Professional Engineer under 12.3(d), or, in the case of a qualified facility that meets the criteria in 112(g), the relevant sections of your Plan are certified by a licensed Professional Engineer. If you determine that the installation of any of the structures or pieces of equipment listed in paragraphs (c) and (h)(1) of this section, and 112.8(c)(2), 112.8(c)(11), 112.9(c)(2), (c), (c)(2), and (c)(11) to prevent a discharge as described in 112.1(b) from any onshore or offshore facility is not practicable, you must clearly explain in your Plan why such measures are not practicable; for bulk storage containers, conduct both periodic integrity testing of the containers and periodic integrity and leak testing of the valves and piping; and, unless you have submitted a response plan under , provide in your Plan the following: (1) An oil spill contingency plan following the provisions of part 109 of this chapter. (2) A written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful General containment measures have been implemented for bulk fuel delivery, oil transfer areas, piping, and oil-filled equipment. Specific containment measures have been implemented for oil containers. Descriptions of containment measures are located in Sections 3.3 and of this document. In addition to secondary containment measures described in this Plan, the "ODOT First Responders Guide to Highway Incident Response" satisfies the provisions of 40 CFR part 109 Criteria for State, Local, and Regional Oil Removal Contingency Plans. Madras Maintenance Yard Page 14 of 34

16 In the event of a spill, ODOT will commit the manpower, equipment, and materials to expeditiously control and remove any harmful quantity of oil discharged. This commitment includes the following process: (a) Stop the spill, work with others to stop the spill, or minimize spill movement where feasible; (b) Collect and remove the spilled oil, unless not feasible in which case ODOT, its contractors, or the responsible party, shall take all practicable actions to contain, treat, and remove the spilled oil; (c) Proceed to correct the cause of the spill; (d) Notify the appropriate authorities; (e) Take steps to prevent a recurrence; and (f) Ensure the cleanup of oil spills proceeds in a timely and diligent manner. 4 INSPECTIONS, TESTS AND RECORDS 40 CFR (e) Conduct inspections and tests required by this part in accordance with written procedures that you or the certifying engineer develop for the facility. You must keep these written procedures and a record of the inspections and tests, signed by the appropriate supervisor or inspector, with the SPCC Plan for a period of three years. Records of inspections and tests kept under usual and customary business practices will suffice for purposes of this paragraph. Cursory visual observations are made daily during routine activities. Visual inspections of oil containers, oil transfer areas, and oil-filled equipment are conducted monthly, at a minimum, using EMS Monthly Audit. Written procedures for completing the monthly inspection are located in the EMS Manual. The Madras Transportation Maintenance Manager, or his representative, signs records of these inspections. Records are kept onsite for at least three years. A generic Operations and Maintenance (O&M) Manual for the bulk fuel transfer containment system is located in Appendix D of this document. The O&M Manual outlines crew responsibilities, operating instructions, periodic maintenance, and required inspections. Information about integrity inspections is located in Section of this document. 5 TRAINING 5.1 Training 40 CFR (f)(1) At a minimum, train your oil-handling personnel in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and, the contents of the facility SPCC Plan. ODOT maintenance employees are instructed in the operation and maintenance of job specific equipment. Initial SPCC Training (Course number: MA006521) typically includes the following items: Watch the SPCC video Review the SPCC checklist Review Spill FAQ Sheet in EMS Manual Madras Maintenance Yard Page 15 of 34

17 Annual refresher training is provided by the discharge prevention briefings described in Section 5.3 of this document. The Transportation Maintenance Manager, or his representative, reviews the content of this Plan with new hires and other employees as needed. ODOT maintenance employees receive annual First Responder training that includes information on hazardous material identification and notification procedures for spills and other incidents. First Responder courses are intended to train individuals who are likely to witness or discover a hazardous substance release. In addition, people who dispense fuel are knowledgeable in safe fueling. Formal safe fueling training is recommended (but not required) for this facility. A copy of the Fire Safety Training Safe Fueling Guidelines is located in Appendix P of the EMS Manual. All ODOT employees receive training on the EMS program. The EMS program focuses on appropriate material management and includes information on spill prevention and cleanup. Transportation Maintenance Managers, Supervisors, and crewmembers responsible for completing EMS paperwork receive additional EMS training. Training records are kept by ODOT s Human Resources Department. 5.2 Designated Person 40 CFR (f)(2) Designate a person at each applicable facility who is accountable for discharge prevention and who reports to facility management. The District 10 North Transportation Maintenance Manager is the designated person accountable for spill prevention at the Madras Maintenance yard. 5.3 Discharge Prevention Briefings 40 CFR (f)(3) Schedule and conduct discharge prevention briefings for your oil-handling personnel at least once a year to assure adequate understanding of the SPCC Plan for that facility. Such briefings must highlight and describe known discharges as described in 112.1(b) or failures, malfunctioning components, and any recently developed precautionary measures. Spill prevention is discussed annually, at a minimum. Near misses or incidents are discussed, as needed, in order to prevent reoccurrence. Employee feedback and recommendations are encouraged in spill prevention and operation. A SPCC Review Discharge Prevention Briefing (Course number: MA006522) typically includes the following items Review the SPCC checklist Review Spill FAQ Sheet in EMS Manual Discuss changes (if any) to SPCC practices or spill prevention measures Discuss spills, near misses, or incidents Discharge prevention briefings are typically conducted during employee safety meetings. Records of employee training are kept by ODOT s Human Resources Department. Madras Maintenance Yard Page 16 of 34

18 6 SECURITY 40 CFR (g) (g) Security (excluding oil production facilities). Describe in your Plan how you secure and control access to the oil handling, processing and storage areas; secure master flow and drain valves; prevent unauthorized access to starter controls on oil pumps; secure out-of-service and loading/unloading connections of oil pipelines; and address the appropriateness of security lighting to both prevent acts of vandalism and assist in the discovery of oil discharges. Access to Oil Handling and Storage Areas The property is fenced at the perimeter. The entrance to the facility is gated. The gate is equipped with an auto-locking mechanism with a keypad entry. The gate is locked during nonbusiness hours (e.g. nights and weekends). The buildings are locked when the facility is not occupied. ODOT believes that these measures are adequate to protect against potential oil spills from unauthorized access and/or vandalism. Master Flow and Drain Valves Multiple valves must be open to permit the outward flow of oil from the distributor bar on the paving oil tank. If paving oil is stored onsite, the equipment is typically stored inside the pole building. Small discharges may puddle on the floor of the pole building, but are unlikely to flow outside the building before hardening. Other oil containers do not have flow valves or drain valves that permit direct outward flow. Oil containers are discussed in Section 11.2 of this document. Access to Starter Controls on Oil Pumps The fuel dispenser is operated on a cardlock system. Cards are only distributed to authorized users. Connections of Oil Pipelines The fuel tank fill lines are securely capped when not in use. The pipelines are emptied by the delivery driver after filling the tank. Lighting Lights illuminate the facility after sunset. Exterior lighting is equipped with dusk to dawn sensors. The lighting is adequate to assist in the discovery of spills during nighttime hours and to discourage vandalism. 7 TANK CAR AND TANK TRUCK LOAD/UNLOADING RACK 7.1 Loading/Unloading Rack Secondary Containment Adequate 40 CFR (h)(1) Where loading/unloading rack drainage does not flow into a catchment basin or treatment facility designed to handle discharges, use a quick drainage system for tank car or tank truck loading/unloading racks. You must design any containment system to hold at least the maximum capacity of any single compartment of a tank car or tank truck loaded or unloaded at the facility. ODOT does not load or unload tank cars or tank trucks. This section is not applicable. Madras Maintenance Yard Page 17 of 34

19 7.2 Warning Systems for Disconnect to Transfer Lines 40 CFR (h)(2) Provide an interlocked warning light or physical barrier system, warning signs, wheel chocks or vehicle brake interlock system in the area adjacent to a loading/unloading rack, to prevent vehicles from departing before complete disconnection of flexible or fixed oil transfer lines. ODOT does not load or unload tank cars or tank trucks. This section is not applicable. However, fuel delivery drivers are expected to use wheel chocks, other physical barrier, or warning system to prevent truck departure prior to disconnection of flexible or fixed transfer lines. 7.3 Bulk Tanker Truck Inspection Prior to Departure 40 CFR (h)(3) Prior to filling and departure of any tank car or tank truck, closely inspect for discharges the lowermost drain and all outlets of such vehicles, and if necessary, ensure that they are tightened, adjusted, or replaced to prevent liquid discharge while in transit. ODOT does not load or unload tank cars or tank trucks. This section is not applicable. However, fuel delivery drivers are expected to inspect the lowermost drain and all vehicle outlets for oil discharges before leaving the facility. 8 FIELD-CONSTRUCTED ABOVEGROUND CONTAINERS 40 CFR (i) If a field-constructed aboveground container undergoes a repair, alteration, reconstruction, or a change in service that might affect the risk of a discharge or failure due to brittle fracture or other catastrophe, or has discharged oil or failed due to brittle fracture failure or other catastrophe, evaluate the container for risk of discharge or failure due to brittle fracture or other catastrophe, and as necessary, take appropriate action. Field-construct aboveground containers are not located at this facility. This section is not applicable. 9 APPLICABLE STATE REQUIREMENTS 40 CFR (j) In addition to the minimal prevention standards listed under this section, include in your Plan a complete discussion of conformance with the applicable requirements and other effective discharge prevention and containment procedures listed in this part or any applicable more stringent State rules, regulations, and guidelines. Stormwater discharge for all ODOT maintenance yards is covered under a statewide National Pollutant Discharge Elimination System Municipal Separate Storm Sewer System Discharge Permit (NPDES-MS4) issued by the Oregon Department of Environmental Quality. The NPDES-MS4 permit includes provisions for pollution source identification, stormwater monitoring, and implementation of structural and non-structural BMPs to reduce discharge of pollutants to the maximum extent possible. 10 OIL-FILLED OPERATIONAL EQUIPMENT 40 CFR (k) The owner or operator of a facility with oil-filled operational equipment that meets the qualification criteria in paragraph (k)(1) of this sub-section may choose to implement for this qualified oil-filled operational equipment the alternate requirements as described in paragraph (k)(2) of this sub-section in lieu of general secondary containment required in paragraph (c) of this section. Madras Maintenance Yard Page 18 of 34

20 40 CFR (k)(1) The owner or operator of a facility that has had no single discharge as described in 112.1(b) from any oil-filled operational equipment exceeding 1,000 U.S. gallons or no two discharges as described in 112.1(b) from any oil-filled operational equipment each exceeding 42 U.S. gallons within any twelve month period in the three years prior to the SPCC Plan certification date, or since becoming subject to this part if the facility has been in operation for less than three years (other than oil discharges as described in 112.1(b) that are the result of natural disasters, acts of war or terrorism); and. 40 CFR (k)(2) If secondary containment is not provided for qualified oil-filled operational equipment pursuant to paragraph (c) of this section, the owner or operator of a facility with qualified oil-filled operational equipment must: (i) Establish and document the facility procedures for inspections or a monitoring program to detect equipment failure and/or a discharge; and (ii) Unless you have submitted a response plan under , provide in your Plan the following: (A) An oil spill contingency plan following the provisions of part 109 of this chapter. (B) A written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful. Oil-filled operational equipment at this no located at this facility. This section is not applicable. 11 SPECIFIC DISCHARGE PREVENTION AND CONTAINMENT If you are the owner or operator of an onshore facility (excluding a production facility), you must: 40 CFR (a) Meet the general requirements for the Plan listed under 112.7, and the specific discharge prevention and containment procedures listed in this section. The conformance with general requirements has been described in the previous sections of this document. Conformance with specific requirements is described in this section Facility Drainage This section describes situations where drainage is used to provide secondary containment and may include information about secondary containment structures (e.g. curbs, berms, or retaining walls), water treatment systems (e.g. oil/water separator), or devices that stop water from going into a pipe or catch basin (e.g. in-line valves or drain mats). Sections and describe inspection requirements and valve requirements for areas where structures are used to provide secondary containment (e.g. retaining walls or spill pads). Sections and describe requirements when either a method of water treatment or a physical barrier (to prevent water from getting into a drain) is used to provide secondary containment Drainage from Secondary Containment Structures (e.g. curbs, berms, or retaining walls) 40 CFR (b)(1) Restrain drainage from diked storage areas by valves to prevent a discharge into the drainage system or facility effluent treatment system, except where facility systems are designed to control such discharge. You may empty diked areas by pumps or ejectors; however, you must manually activate these pumps or ejectors and must inspect the condition of the accumulation before starting, to ensure no oil will be discharged. The secondary containment structure is designed to retain oil from bulk fuel transfers on the paved surface while the valve is closed. The structure is located south of the fuel tank. The structure consists of a three-sided concrete basin with a manually operated drain valve. The drain valve is located at the low point of the system; pumps or ejectors are not used to empty the system. Madras Maintenance Yard Page 19 of 34

21 The valve is normally kept open to allow stormwater to flow through the structure. The valve is closed while the structure is providing containment (e.g. transferring bulk fuel into the fuel tank). Instructions are posted near the valve. The structure discharges to the graveled ground surface immediately adjacent to the structure. The containment area is inspected monthly during the EMS Monthly Audit Valves for Secondary Containment Structures 40 CFR (b)(2) Use valves of manual, open-and-closed design, for the drainage of diked areas. You may not use flapper-type drain valves to drain diked areas. If your facility drainage drains directly into a watercourse and not into an on-site wastewater treatment plant, you must inspect and may drain uncontaminated retained stormwater, as provided in paragraphs (c)(3)(ii), (iii), and (iv) of this section. The valve on the containment structure is a manual, open-and-close design. The ball valve is located on the outflow pipe and is operated by a lever handle on top of valve. The valve is normally kept open to allow stormwater to flow through the system. If stormwater is retained while the valve is closed, the water is visually inspected for oil sheen before opening the valve. If oil is observed, the oil is removed before opening the valve. Valve operation is checked during the EMS Monthly Audit Drainage from Non-structural Containment Areas 40 CFR (b)(3) Design facility drainage systems from undiked areas with a potential for a discharge (such as where piping is located outside containment walls or where tank truck discharges may occur outside the loading area) to flow into ponds, lagoons, or catchment basins designed to retain oil or return it to the facility. You must not locate catchment basins in areas subject to periodic flooding. Floor drains inside the shop and the wash rack are connected to a close loop water treatment system. The closed loop treatment system is located near the wash rack. The closed loop system is designed to remove oil. Clean water is stored in a holding tank. Additional information about the system is located in Appendix B of this document. The area is not subject to periodic flooding Diversion System Alternative for Drainage from Non-Structural Containment 40 CFR (b)(4) If facility drainage is not engineered as in paragraph (b)(3) of this section, equip the final discharge of all ditches inside the facility with a diversion system that would, in the event of an uncontrolled discharge, retain oil in the facility. Diversion systems are not used to provide secondary containment. This section is not applicable Pump Transfers Between Drainage Treatment Systems 40 CFR (b)(5) Where drainage waters are treated in more than one treatment unit and such treatment is continuous, and pump transfer is needed, provide two "lift" pumps and permanently install at least one of the pumps. Whatever techniques you use, you must engineer facility drainage systems to prevent a discharge as described in 112.1(b) in case there is an equipment failure or human error at the facility. Multiple-unit drainage treatment systems are not used. This section is not applicable. Madras Maintenance Yard Page 20 of 34

22 11.2 Oil Storage Containers Compatibility of Oil Storage Containers (fixed and portable) 40 CFR (c)(1) Not use a container for the storage of oil unless its material and construction are compatible with the material stored and conditions of storage such as pressure and temperature. Oil containers are constructed of welded steel or other oil compatible material. Shop-fabricated containers are manufactured in accordance with applicable industry standards Secondary Containment for Fixed Location Oil Storage Containers 40 CFR (c)(2) Construct all bulk storage tank installations (except mobile refuelers and other nontransportation-related tank trucks) so that you provide a secondary means of containment for the entire capacity of the largest single container and sufficient freeboard to contain precipitation. You must ensure that diked areas are sufficiently impervious to contain discharged oil. Dikes, containment curbs, and pits are commonly employed for this purpose. You may also use an alternative system consisting of a drainage trench enclosure that must be arranged so that any discharge will terminate and be safely confined in a facility catchment basin or holding pond. Bulk fuel is stored in a shop-fabricated, double-walled tank. The bulk fuel tank was manufactured with an outer secondary tank around the primary inner tank. The containment capacity of the secondary tank is at least 100-percent of the storage capacity of the primary tanks. The tank interior is not exposed to rainwater; additional containment capacity for freeboard is not required. Used oil is stored in a shop-fabricated, double-walled tank. The used oil tank was manufactured with an outer secondary tank around the primary inner tank. The containment capacity of the secondary tank is at least 100-percent of the storage capacity of the primary tank. The tank is sealed; additional containment capacity for freeboard is not required Drainage for Structurally Contained Oil Container Storage Areas (fixed and portable) 40 CFR (c)(3) Not allow drainage of uncontaminated rainwater from the diked area into a storm drain or discharge of an effluent into an open watercourse, lake, or pond, bypassing the facility treatment system unless you: (i) Normally keep the bypass valve sealed closed. (ii) Inspect the retained rainwater to ensure that its presence will not cause a discharge as described in 112.1(b). (iii) Open the bypass valve and reseal it following drainage under responsible supervision; and (iv) Keep adequate records of such events, for example, any records required under permits issued in accordance with (j)(2) and (m)(3) of this chapter. Structures are not used to provide secondary containment of oil containers. This section is not applicable Corrosion Protection of Underground or Partially Buried Oil Storage Tanks 40 CFR (c)(4) Protect any completely buried metallic storage tank installed on or after January 10, 1974 from corrosion by coatings or cathodic protection compatible with local soil conditions. You must regularly leak test such completely buried metallic storage tanks. (5) Not use partially buried or bunkered metallic tanks for the storage of oil, unless you protect the buried section of the tank from corrosion. You must protect partially buried and bunkered tanks from corrosion by coatings or cathodic protection compatible with local soil conditions All oil products are stored in aboveground containers. This section is not applicable. Madras Maintenance Yard Page 21 of 34

23 Integrity Testing for Oil Containers (fixed and portable) 40 CFR (c)(6) Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs. You must determine, in accordance with industry standards, the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections, which take into account container size, configuration, and design (such as containers that are: shop-built, field-erected, skid-mounted, elevated, equipped with a liner, double-walled, or partially buried). Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing. You must keep comparison records and you must also inspect the container's supports and foundations. In addition, you must frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices satisfy the recordkeeping requirements of this paragraph. Cursory visual inspections of oil containers are conducted during normal day-to-day operations. Fixed Location Containers (e.g. fuel tank and used oil) ODOT uses shop-fabricated, double-walled tanks with non-corrosive interior and exterior coatings to store bulk fuel. Fuel tanks are fabricated with skids or supports to prevent contact with the ground surface. In addition, the bulk fuel tank at the Madras Maintenance yard is installed on a concrete pad. The exterior surface of oil tanks (including tank supports and foundations) are visually inspected monthly for signs of deterioration, corrosion, leaks, and oil accumulation during the completion of the EMS Monthly Audit. ODOT Facilities schedules non-destructive shell testing (tank tightness testing) for bulk fuel tanks as part of routine building inspections. Integrity tests are conducted 15 years after installation and every 5 years thereafter. Weather resistant tags that list scheduled and completed tank tightness test dates are attached to bulk fuel tanks. Inspections are completed by STI certified vendors. This testing schedule exceeds the Steel Tank Institutes (STI) Standard SP001, 3 rd edition guidelines for shop fabricated tanks. According to the STI Standard SP001, 3 rd edition guidelines, integrity testing is not required for tanks with a capacity less than 1,100 gallon as long as secondary containment is provided. ODOT believes that monthly visual inspections by ODOT personnel provide adequate integrity testing for small tanks. If minor corrosion is observed on fixed location tanks, the tank is cleaning and repainting before the corrosion becomes problematic. If excessive corrosion is discovered, either the frequency of integrity testing is increased or the tank is replaced. Portable Containers (e.g. drums) Oil-filled drums are kept indoors, under cover, or otherwise protected from exposure to rainwater (e.g. only stored outdoors when not raining) and other corrosive elements (e.g. stored off the ground surface). Industry standards state that single-use drums require only visual inspection. The exterior surface of oil drums are visually inspected monthly for signs of deterioration, corrosion, discharge, and oil accumulation using the EMS Monthly Audit. Madras Maintenance Yard Page 22 of 34

24 Empty drums are typically returned to the vendor however, some drums may be reused onsite. Drums that show visible signs of deterioration are recycled as scrap metal or used to store solid materials (e.g. bolts or trash). ODOT believes these measures are adequate to prevent an oil release due to container failure Internal Heating Coil on Aboveground Oil Tanks 40 CFR (c)(7) Control leaks through defective internal heating coils by monitoring the steam return and exhaust lines for contamination from internal heating coils that discharge into an open watercourse, or pass the steam return or exhaust lines through a settling tank, skimmer, or other separation or retention system. ODOT does not use internal heating coils to control leaks. This section is not applicable Overfill Protection for Oil Containers (fixed and mobile) 40 CFR (c)(8) Engineer or update each container installation in accordance with good engineering practice to avoid discharges. You must provide at least one of the following devices: (i) High liquid level alarms with an audible or visual signal at a constantly attended operation or surveillance station. In smaller facilities an audible air vent may suffice. (ii) High liquid level pump cutoff devices set to stop flow at a predetermined container content level. (iii) Direct audible or code signal communication between the container gauger and the pumping station. (iv) A fast response system for determining the liquid level of each bulk storage container such as digital computers, telepulse, or direct vision gauges. If you use this alternative, a person must be present to monitor gauges and the overall filling of bulk storage containers. (v) You must regularly test liquid level sensing devices to ensure proper operation. The fuel tank is equipped with overfill protection described in (i), (ii), and (iv) of (b)(8) that includes a high level sensing alarm, an audible alarm, emergency shut-off, an overfill prevention valve, an anti-siphon valve, and a liquid level gauge. The used oil tank is equipped with overfill protection described in (iv) of (b)(8) that includes a direct vision gauge. Employees ensure there is adequate available capacity in the tank before transferring oil. Mobile refuelers are typically filled at the fuel dispenser. The dispenser nozzle is equipped with an automatic shut-off as described in 112.8(c)(8)(ii). In addition, employees are present the entire time the tank is being filled. The paving oil tank is not filled onsite. ODOT believes that these measures are adequate to prevent a release from impacting navigable water Observation of Effluent Treatment Facilities 40 CFR (c)(9) Observe effluent treatment facilities frequently enough to detect possible system upsets that could cause a discharge as described in 112.1(b). The effluent is treated through a closed loop system; waste water is used to wash equipment and retreated to remove pollutants. This section is not applicable. Madras Maintenance Yard Page 23 of 34

25 Correction of Visible Discharges 40 CFR (c)(10) Promptly correct visible discharges which result in a loss of oil from the container, including but not limited to seams, gaskets, piping, pumps, valves, rivets, and bolts. You must promptly remove any accumulations of oil in diked areas. Visible leaks that result in a loss of oil from seams, gaskets, pipes, valves, rivets, and bolts that are large enough to cause the accumulation of oil are promptly corrected by in-house repair or outside contractor, as appropriate Containment of Mobile or Portable Oil Containers 40 CFR (c)(11) Position or locate mobile or portable oil storage containers to prevent a discharge as described in 112.1(b). Except for mobile refuelers and other non-transportation-related tank trucks, you must furnish a secondary means of containment, such as a dike or catchment basin, sufficient to contain the capacity of the largest single compartment or container with sufficient freeboard to contain precipitation. This section includes oil containers (tanks and drums) that can be moved from one location to another. Oil containers with a shell capacity of less than 55 gallons (e.g. small transfer tanks, buckets, or quarts) are excluded from SPCC regulation. BMPs for small oil containers are listed in the EMS Manual. Motive power containers Motive power containers (e.g. vehicle fuel tanks) including any ancillary vehicle equipment (e.g. hydraulics, heat transfer units, or gearboxes) are not included in this SPCC Plan. Motive power containers provide fuel for movement or some other operational function (e.g. lubrication of moving parts or operation of onboard hydraulic equipment). US DOT regulates motive power containers. Motive power containers do not include storage tanks mounted on a vehicle for any purpose other than powering the vehicle itself. Truck-mounted tanks (e.g. slip-ins or mobile refuelers) with a shell capacity greater than 55 gallons are included in the SPCC Plan as mobile/portable containers. BMPs for the storage and routine maintenance of fleet and equipment are located in the EMS Manual. The Fleet Guidelines Manual also lists required maintenance and inspection actions. Spill response equipment is kept inside vehicles as appropriate. Drums Drums (55 gallons) of oil are stored inside the shop building. Drums are located so that potential for vehicle contact is minimized. Manufactured spill pallets are used to provide secondary containment for oil drums. The pallets are designed to hold, at a minimum, the entire contents of the largest container stored on the pallet. The drums are not exposed to rainwater so freeboard is not required. Alternative containment methods (e.g. curbing, dead-end sumps, or booms) that offer the same degree of protection may also be used to provide secondary containment for oil drums. Madras Maintenance Yard Page 24 of 34

26 Spill response supplies provide general secondary containment when oil drums are moved (e.g. from one building to another or from a transport truck into a building). BMPs for the storage and handling of oil containers with a shell capacity of less than 55 gallons (e.g. gas cans or quarts of oil) are located in the EMS Manual. Mobile Refuelers A 90-gallon mobile refueling tank is mounted to the bed of one of the trucks. Secondary containment is not required for mobile refuelers. In the event of a spill, ODOT will cleanup the spill in accordance with Section 3.4 of this document. Slip-ins and Asphalt Paving Tanks An 1000-gallon slip-in tank is stored inside the pole building. The tank is typically stored at this facility during the off-season. During the off-season the tank is empty. However, the tank may occasionally be stored onsite if crews are paving in the area. Secondary containment for the tank is impractical. If the tank is full when onsite, the tank typically stored in the pole building. Paving oil is viscous and unlikely to flow; therefore, a release is unlikely to impact navigable water. The area at the around the pole building is paved and would restrict the surface flow of paving oil. In the event of a release, ODOT will cleanup the spill in accordance with Section 3.4 of this document Piping This section describes piping used to transfer oil to and from aboveground and underground storage containers (e.g. fuel tank to dispenser) Buried Piping 40 CFR (d)(1) Provide buried piping that is installed or replaced on or after August 16, 2002, with a protective wrapping and coating. You must also cathodically protect such buried piping installations or otherwise satisfy the corrosion protection standards for piping in part 280 of this chapter or a State program approved under part 281 of this chapter. If a section of buried line is exposed for any reason, you must carefully inspect it for deterioration. If you find corrosion damage, you must undertake additional examination and corrective action as indicated by the magnitude of the damage. Oil-filled piping at this facility is aboveground. This section is not applicable Terminal Connections 40 CFR (d)(2) Cap or blank-flange the terminal connection at the transfer point and mark it as to origin when piping is not in service or is in standby service for an extended time. Pipelines are capped when not in use. The pipe start point (or end point) is identified, as appropriate Pipe Supports 40 CFR (d)(3) Properly design pipe supports to minimize abrasion and corrosion and allow for expansion and contraction. Pipe supports allow for expansion and contraction and are designed to minimize abrasion and corrosion. Madras Maintenance Yard Page 25 of 34

27 Inspection of Piping and Valves 40 CFR (d)(4) Regularly inspect all aboveground valves, piping, and appurtenances. During the inspection you must assess the general condition of items, such as flange joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces. You must also conduct integrity and leak testing of buried piping at the time of installation, modification, construction, relocation, or replacement. Aboveground pipes, valves, and pipe supports are visually inspected monthly for signs of leaks and/or deterioration using the EMS Monthly Audit. Visible portions of the lube lines that run thorough a below ground pipe chase are also inspected Vehicle Warning of Aboveground Piping 40 CFR (d)(5) Warn all vehicles entering the facility to be sure that no vehicle will endanger aboveground piping or other oil transfer operations. Environmentally equivalent protection is provided for warning (e.g. posted signs) vehicles about aboveground piping. ODOT considers barriers and/or pipe placement a more effective means of protection than warning signs or verbal communication. Piping associated with the aboveground fuel tank is mounted to the tank and is protected by the foundation and barrier. Piping for the used oil tank is mounted next to the wall. Pipes are unlikely to be struck by vehicles. Madras Maintenance Yard Page 26 of 34

28 DEFINITIONS Active secondary containment means the containment measure requires a certain action by facility personnel before or after a discharge occurs. These actions are also referred to as countermeasures. Examples include placing a cover over a drain, closing a drainage valve, and using spill kits. (SPCC Guidance for Regional Inspectors; dated 11/28/05.) Bulk storage container means any container that is used to store oil. These containers are used for purposes including, but not limited to, the storage of oil prior to use, while being used, or prior to further distribution in commerce. Oil-filled electrical, operating, or manufacturing equipment is not a bulk storage container. (40 CFR Definitions) Discharge includes, but is not limited to, any spilling, leaking, pumping, pouring, emitting, emptying, or dumping of oil, but excludes discharges in compliance with a permit under Section 402 of the Clean Water Act (CWA); discharges resulting from circumstances identified, reviewed, and made a part of the public record with respect to a permit issued or modified under Section 402 of the CWA, and subject to a condition in such permit; or continuous or anticipated intermittent discharges from a point source, identified in a permit or permit application under Section 402 of the CWA, that are caused by events occurring within the scope of relevant operating or treatment systems. For purposes of this part, the term discharge shall not include any discharge of oil that is authorized by a permit issued under Section 13 of the River and Harbor Act of 1899 (33 U.S.C. 407). (40 CFR Definitions) Facility means any mobile or fixed, onshore or offshore building, structure, installation, equipment, pipe, or pipeline (other than a vessel or a public vessel) used in oil well drilling operations, oil production, oil refining, oil storage, oil gathering, oil processing, oil transfer, oil distribution, and waste treatment, or in which oil is used, as described in Appendix A to this part. The boundaries of a facility depend on several site-specific factors, including, but not limited to, the ownership or operation of buildings, structures, and equipment on the same site and the types of activity at the site. (40 CFR Definitions) General secondary containment means secondary containment for the most likely oil discharge. Containment method, design, and capacity are determined by good engineering practice to contain an oil discharge until cleanup occurs. (SPCC Guidance for Regional Inspectors; dated 11/28/05.) Loading/unloading rack means a fixed structure (such as a platform, gangway) necessary for loading or unloading a tank truck or tank car, which is located at a facility subject to the requirements of this part. A loading/unloading rack includes a loading or unloading arm, and may include any combination of the following: piping assemblages, valves, pumps, shut-off devices, overfill sensors, or personnel safety devices. (40 CFR Definitions) Maximum extent practicable means within the limitations used to determine oil spill planning resources and response times for on-water recovery, shoreline protection, and cleanup for worst case discharges from onshore non-transportation-related facilities in adverse weather. It includes the planned capability to respond to a worst case discharge in adverse weather, as contained in a response plan that meets the requirements in or in a specific plan approved by the Regional Administrator. (40 CFR Definitions) Madras Maintenance Yard Page 27 of 34

29 Mobile (or portable) container means any container (with a capacity of 55 gallons or more) that operates exclusively within the confines of the facility (e.g. drums) or that is used offsite but contain oil when stored (e.g. slip-ins, transfer tanks, or skid tanks). (SPCC Guidance for Regional Inspectors; dated 11/28/05.) Mobile refueler means a bulk storage container onboard a vehicle or towed, that is designed or used solely to store and transport fuel for transfer into or from an aircraft, motor vehicle, locomotive, vessel, ground service equipment, or other oil storage container. (40 CFR Definitions) Motive power container means any onboard bulk storage container used primarily to power the movement of a motor vehicle, or ancillary onboard oil-filled operational equipment. An onboard bulk storage container which is used to store or transfer oil for further distribution is not a motive power container. The definition of motive power container does not include oil drilling or workover equipment, including rigs. (40 CFR Definitions) Navigable waters means the waters of the United States, including the territorial seas. (1) The term includes: (i) All waters that are currently used, were used in the past, or may be susceptible to use in interstate or foreign commerce, including all waters subject to the ebb and flow of the tide; (ii) All interstate waters, including interstate wetlands; (iii) All other waters such as intrastate lakes, rivers, streams (including intermittent streams), mudflats, sandflats, wetlands, sloughs, prairie potholes, wet meadows, playa lakes, or natural ponds, the use, degradation, or destruction of which could affect interstate or foreign commerce including any such waters: A. That are or could be used by interstate or foreign travelers for recreational or other purposes; or B. From which fish or shellfish are or could be taken and sold in interstate or foreign commerce; or, C. That are or could be used for industrial purposes by industries in interstate commerce; (iv) All impoundments of waters otherwise defined as waters of the United States under this section; (v) Tributaries of waters identified in paragraphs (1)(i) through (iv) of this definition; (vi) The territorial sea; and (vii) Wetlands adjacent to waters (other than waters that are themselves wetlands) identified in paragraph (1) of this definition. (2) Waste treatment systems, including treatment ponds or lagoons designed to meet the requirements of the CWA (other than cooling ponds which also meet the criteria of this definition) are not waters of the United States. Navigable waters do not include prior converted cropland. Notwithstanding the determination of an area's status as prior converted cropland by any other Federal agency, for the purposes of the CWA, the final authority regarding CWA jurisdiction remains with EPA. (40 CFR Definitions) Non-petroleum oil means oil of any kind that is not petroleum-based, including but not limited to: Fats, oils, and greases of animal, fish, or marine mammal origin; and vegetable oils, including oils from seeds, nuts, fruits, and kernels. (40 CFR Definitions) Madras Maintenance Yard Page 28 of 34

30 Non-transportation-related onshore and offshore facilities means oil storage facilities including all equipment and appurtenances related thereto as well as fixed bulk plant storage, terminal oil storage facilities, consumer storage, pumps and drainage systems used in the storage of oil. (Appendix A to Part Memorandum of Understanding Between the Secretary of Transportation and the Administrator of the Environmental Protection Agency) Non-transportation-related tank trucks include those used to store (for short periods of time) and transport fuel, crude oil, condensate, non-petroleum, or other oils for transfer to or from bulk storage containers; for example, a truck used to refill oil-filled equipment at an electrical substation or a pump truck at an oil production facility. (Federal Register: December 5, 2008 (Volume 73, Number 235) Oil means oil of any kind or in any form, including, but not limited to: fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and, other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil. (40 CFR Definitions) Oil-filled operational equipment means equipment that includes an oil storage container (or multiple containers) in which the oil is present solely to support the function of the apparatus or the device. Oil-filled operational equipment is not considered a bulk storage container, and does not include oil-filled manufacturing equipment (flow-through process). Examples of oilfilled operational equipment include, but are not limited to, hydraulic systems, lubricating systems ( e.g., those for pumps, compressors and other rotating equipment, including pumpjack 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. (40 CFR Definitions) Owner or operator means any person owning or operating an onshore facility or an offshore facility, and in the case of any abandoned offshore facility, the person who owned or operated or maintained the facility immediately prior to such abandonment. (40 CFR Definitions) Passive secondary containment means the containment measure remains in place regardless of the facility operations and therefore does not require personnel to act (e.g. double-walled tanks or containment structures with normally closed valves). (SPCC Guidance for Regional Inspectors; dated 11/28/05.) Portable (or mobile) container means any container (with a capacity of 55 gallons or more) that operates exclusively within the confines of the facility (e.g. drums) or that is used offsite but contain oil when stored (e.g. slip-ins, transfer tanks, or skid tanks). (SPCC Guidance for Regional Inspectors; dated 11/28/05.) Regional Administrator means the Regional Administrator of the Environmental Protection Agency, in and for the Region in which the facility is located. (40 CFR Definitions) Repair means any work necessary to maintain or restore a container to a condition suitable for safe operation, other than that necessary for ordinary, day-to-day maintenance to maintain the functional integrity of the container and that does not weaken the container. (40 CFR Definitions) Madras Maintenance Yard Page 29 of 34

31 Specific secondary containment means secondary containment for major container failure. Containment design, sizing, and freeboard requirements are specified in the SPCC rule. (SPCC Guidance for Regional Inspectors; dated 11/28/05.) Spill Prevention, Control, and Countermeasure Plan; SPCC Plan, or Plan means the document required by that details the equipment, workforce, procedures, and steps to prevent, control, and provide adequate countermeasures to a discharge. (40 CFR Definitions) Storage capacity of a container means the shell capacity of the container. (40 CFR Definitions) Transfer area means any area where oil is moved from or into some form of transportation, storage, equipment, or other device, into or from some other or similar form of transportation, such as a pipeline, truck, tank car, or other storage device. (67 FR 47130) (SPCC Guidance for Regional Inspectors; page 4-30; dated 11/28/05.) Transfer operation equipment means piping, valves, gauges, regulators, compressors, pumps and other mechanical devices used to transfer oil form one place to another within the facility (EPA Guidance Document: SPCC Requirements and Pollution Prevention Practices for Vehicle Service Facilities) Wetlands means those areas that are inundated or saturated by surface or groundwater at a frequency or duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include playa lakes, swamps, marshes, bogs, and similar areas such as sloughs, prairie potholes, wet meadows, prairie river overflows, mudflats, and natural ponds. (40 CFR Definitions) Madras Maintenance Yard Page 30 of 34

32 APPLICABILITY OF THE SUBSTANTIAL HARM CRITERIA 1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons? Yes No 2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation within any aboveground oil storage tank area? Yes No 3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? Yes No 4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance such that a discharge from the facility would shut down a public drinking water intake? Yes No 5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a reportable oil discharge in an amount greater than or equal to 10,000 gallons within the last 5 years? Yes No Madras Maintenance Yard Page 31 of 34

33 SPCC REQUIREMENTS AT A GLANCE Action Included Items Frequency Description of Action Records Visual inspection Periodic actions by yard staff Tanks and supports Portable tanks Drums Oil-filled equipment Piping (aboveground) Secondary containment Oil/water separators Drainage outlets Fencing Gate(s) Lighting Buried piping Spill cleanup supplies Routine maintenance of secondary containment structure Secondary containment valve Secondary containment structure Secondary containment structure Oil spills Tank alarms and overfill devices Emergency contact information Monthly Monthly Whenever exposed As needed As needed Monthly or as instructed in O&M Manual As needed Annual or as instructed in O&M Manual If a spill occurs Monthly Once, update as needed Look for evidence of leaks, spills, corrosion, and/or damage. Repair, maintain, or replace as needed. Look for damage. Look for evidence that additional security is needed Repair or replace as needed. Look for corrosion Repair or replace as needed Replenish supplies as needed to contain specified volume of oil for area. Make sure supplies are visible Store in weather resistant containers, where appropriate Remove debris Remove snow and ice Post instructions for delivery driver to close valve before delivering fuel Make sure valve works Check for the presence of oil before releasing stormwater Check integrity by allowing structure to partially fill with water Use secondary containment to keep spill onsite (within level of training) Notify supervisor Notify OERS of spills over reportable quantities Initiate cleanup Ensure alarms and monitoring equipment is functional Post near MSDS book Use EMS Monthly Audit and Corrective Action Sheet Use EMS Monthly Audit and Corrective Action Sheet Use Corrective Action Sheet None needed Use EMS Corrective Action Sheet Use EMS Corrective Action Sheet Use EMS Corrective Action Sheet Use EMS Corrective Action Sheet If quantity is reportable (42 gal of oil to ground or any to water), use the Spill Response Form for Spills in ODOT Maintenance Yards Use EMS Monthly Audit and Corrective Action Sheet Use Emergency Notification form in EMS Manual Madras Maintenance Yard Page 32 of 34

34 Action Included Items Frequency Description of Action Records Outdoor tanks in a fixed location (e.g. fuel tank or used oil tank) 15 yrs plus every 10 yrs after first inspection Facilities will schedule periodic tank integrity testing. Notify Facilities if excessive corrosion occurs between tests Facilities will have tank tags updated. Keep copies of test results onsite. Testing by contractor Indoor tanks in a fixed location (e.g. new oil or used oil tank) Not required unless excessively corroded Notify Facilities if excessive corrosion is observed Request Facilities add tank to outdoor tank inspection schedule. Use EMS Corrective Action Sheet to document notified Facilities All tanks When repaired Have repair contractor test for leaks and integrity Keep repair and test records onsite. Buried piping When installed or repaired Have contractor test for integrity and leaks Keep records or repairs onsite Containment valve Before delivery Close containment valve before delivering fuel None Inspection and actions by fuel delivery driver Fuel tank Tanker truck Secondary containment structure Before delivery Before delivery Before opening containment valve Verify available volume Use wheel chocks Check for oil inside structure None None None Tanker truck Before leaving yard Check for delivery truck leaks and/or open valves None Spill prevention briefings Annual Discuss spill prevention for yard or SPCC Plan at a safety meeting Use safety meeting sign-in and agenda Spill Response Training Annual Have employees take First Responder Training Course Use employee training records Training SPCC Training Once per employee Additional at discretion of TMM Have each employee watch the SPCC video. Go over SPCC procedures, as needed, with employees and new hires. Contact ODOT Maintenance and Operations Branch to arrange additional training, as needed. Use employee training record ODOT Maintenance and Operations Branch keeps records of facilities that receive SPCC training SPCC Plan revisions and evaluations Periodic evaluation Amended SPCC Plan 5 years As needed Maintenance and Operations Branch will visit yard and revise SPCC Plan as needed If spill over 1,000 gals occurs If two spills over 42 gals occur in one year If changes occur that effect potential for oil discharge Revisions, amendments, and evaluations will be noted in SPCC History section this document Revised SPCC As needed New regulations New SPCC guidance Madras Maintenance Yard Page 33 of 34

35 SPCC PLAN HISTORY SPCC Plan Original plan stamped on: April 30, 2015 Prepared by: ODOT Maintenance and Operation Branch Maintenance and Owner Representative: Lucinda Moore, PE (State Maintenance Engineer) Madras Maintenance Yard Page 34 of 34

36 APPENDIX A LOCATION MAP AND SITE DRAWINGS

37 ½ Mile ¼ Mile Topographic Map Downloaded from the USGS National Map on February 17, 2015 Madras Maintenance Yard 210 NW Cherry Lane Madras, Oregon 97741

38 North Unit Main Canal Siphon Creek Additional information about fish presence and water quality limited waterways is located in the Statewide SharePoint folder. Aerial Overview Downloaded from Google Maps on February 18, 2015 Madras Maintenance Yard Basin: Deschutes Latitude: County: Jefferson Sub-Basin: Lower Deschutes Longitude: T:10S R:13E S:36

39 FACILITY INFORMATION F-Number: F41602 Land Owner: ODOT Acreage: acres Sewerage: Septic Potable Water: Municipal Aerial Detail Downloaded from Google Maps on February 18, 2015 Madras Maintenance Yard 210 NW Cherry Lane Madras, OR 97741

40 NW Cherry Lane KEY Deicer tank Shop Paved Private Road Fence Containment Stream Pole Building Wash rack Stormwater Infiltration Pond Graveled Siphon Creek Site Overview Not to Scale Updated April 17, 2015 Madras Maintenance Yard 201 NW Cherry Lane Madras, Oregon N

41 KEY Fuel dispensers Bulk fuel tank Containment valve U Paving oil tank (typical) Barrel storage (typical) Deicer tank Secondary Containment Cold mix Mobile refueler (typical) Water Treatment System Stormwater Infiltration Pond Storage Detail Not to Scale Updated April 17, 2015 Madras Maintenance Yard 201 NW Cherry Lane Madras, Oregon N

42 APPENDIX B SECONDARY CONTAINMENT ASSESSMENTS AND DRAWINGS

43

44 ODOT ASSESSMENT OF APPROPRIATE SECONDARY CONTAINMENT SITE: XYZ MAINTENANCE YARD PROCESS: FUEL TRANSFER FROM DISPENSER GENERAL DESCRIPTION: A vehicle is parked in front of the fuel dispenser. Hose nozzle is inserted into the vehicle fill spout and fueling commences until vehicle tank is full. ODOT policy requires all persons dispensing fuel from ODOT fuel tanks to remain with the vehicle during fueling. DETAILS A pump shutoff is located on the dispenser and is accessible during the fueling. The most likely cause of a spill is the fuel nozzle falling out of the vehicle tank. The dispenser transfers fuel at a maximum rate of 40 gallons per minute. An evaluation determined that a spill, should such an event occur, would not impede access to the shutoff valve and that the pump could be safely stopped within 15 seconds of the nozzle falling (based on past experience under similar circumstances). 20 seconds is considered a conservative estimate of the response time allowing extra time for recognition of the situation. CALCULATIONS: The maximum spill volume for this scenario is: (40 gal/min) x (1 min/60 sec) x (20 sec) = 13.3 gallons CONCLUSIONS: Active secondary containment measures should be able to collect at least 15 gallons of fuel. Transfers should occur over an impervious surface. (NOTE: This is a general template. If a storm drain is located within the dispensing area additional containment measures may be required. Response time to prevent a spill from reaching a storm drain or water body shall be based on site conditions and topography.) CONSIDERED SPILL SCENARIOS (IN ADDITION TO ABOVE): Vehicle tank is overfilled due to failure of trip valve on nozzle employee is required to remain with vehicle, so response time and spill volume match the above criteria. Vehicle drives away with nozzle still in the tank dispenser hoses have a shear valve which is designed to break away from the dispenser and shut off the flow of fuel. If the hose is an older style, the pump may be pulled off the mount. Pumps are equipped with anti-siphon valves to prevent fuel from leaking after pump is pulled loose. Spill volume will be less than the volume noted above. SPCC Secondary Containment Assessment for Fuel Dispensing Version 1.0 April 20, 2006

45 ODOT ASSESSMENT OF APPROPRIATE SECONDARY CONTAINMENT SITE: XYZ MAINTENANCE YARD PROCESS: HOSE REEL BULK FUEL TRANSFER GENERAL DESCRIPTION: A vendor s tank truck drives onsite and parks adjacent to the fuel tank. Delivery driver opens valves on the tank truck and turns on pump to pressurize fill line. Delivery driver pulls hose and nozzle from the truck reel to the top of the fuel tank. Delivery driver remains at the nozzle during the transfer operation. When tank is full, the nozzle is removed and the hose is reeled back into the truck. Pump is turned off and valves are closed. DETAILS A shutoff valve is located on the loading line and is accessible to the delivery driver. The most likely cause of a spill is a ruptured hose or failed connection. The truck transfers fuel at a maximum rate of 60 gallons per minute. An evaluation determined that a spill, should such an event occur, would not impede the delivery driver s access to the shutoff valve and the valve could be safely closed within 20 seconds of the rupture or failed connection (based on past experience under similar circumstances). 45 seconds is considered a conservative estimate of the response time allowing extra time to recognize the spill, climb down the tank ladder, and stop the flow of fuel from the truck. CALCULATIONS: The maximum spill volume for this scenario is: (60 gal/min) x (1 min/60 sec) x (45 sec) = 45 gallons CONCLUSIONS: Secondary containment measures should be able to hold at least 45 gallons of fuel plus expected tributary rainfall. Transfers should occur over an impervious surface. (NOTE: When assessing the containment recommendation for small tanks (e.g. backup generator tank) that are filled with a hose reel, a 20 seconds reaction time is considered adequate. Small tanks do not require the delivery driver to climb on top of the tank, subsequently shortening the time needed to close the shutoff valve. Active secondary containment measures should be able to collect at least 20 gallons of fuel.) CONSIDERED SPILL SCENARIOS (IN ADDITION TO ABOVE): Spill occurs between fill point and truck deliver drive might potentially need to approach truck through spill. This is considered standard procedure as determined from interviews with a fuel supplier. This factor is considered in the response time described above. Overfilling of the tank delivery driver remains at the nozzle so an overfill would be immediately detected. Response time would be faster than above. Fuel pump on truck fails and begins draining fuel from pump body response time is equivalent to above, but the rate of flow should be less. SPCC Secondary Containment Assessment for Hose Reel Fuel Transfers Version 1.0 April 20, 2006

46 ODOT ASSESSMENT OF APPROPRIATE SECONDARY CONTAINMENT SITE: XYZ MAINTENANCE YARD PROCESS: TRANSFER OF OIL PRODUCTS THROUGH SHOP LUBE LINES GENERAL DESCRIPTION: Routine vehicle maintenance such as changing oil and greasing are supported by lube line systems in the maintenance shop. Lube systems consist of ceiling or floor mounted hose reels with dispensing nozzles. Fixed and flexible piping connect the reels to pumps mounted on top of 55-gallon drums. DETAILS Pumps are operated by compressed air. Line pressures vary with grease pressures as high as 5000 PSI. Pumping rates range from 1 to 14 gallon per minute depending on the product. Pumps supply product as long as dispenser lever is depressed. The most likely cause of a spill is a ruptured hose. A rupture is assumed to discharge at the maximum rate of the pump until the drum is 'empty.' An evaluation determined that a spill, should such an event occur, would not always be noticed quickly as an event has potential to occur with or without employees present. Reaction times vary from immediately to several days. CALCULATIONS: The maximum spill volume for this scenario is: The largest spill volume is a full 55-gallon drum (worst case). CONCLUSIONS: Secondary containment measures should be able to collect and/ or hold at least 55 gallons of oil and should function passively. Alternative: The installation of a low-pressure shutoff valve (or equivalent action) in the distribution line reduces the recommended containment volume to 4 gallons of oil for each 100 of pipe or hose after the shutoff valve (assuming 1" or smaller diameter pipe). CONSIDERED SPILL SCENARIOS (IN ADDITION TO ABOVE): A conservative estimate of a release from a small leak (such as a loose fitting) is approximately 1 gallon per day. A small leak could occur without activating a lowpressure shutoff (if installed). The scenario above describes the largest possible spill at the fastest possible rate. SPCC Secondary Containment Assessment for Lube Lines Version 1.1 July 12, 2006

47 ODOT ASSESSMENT OF APPROPRIATE SECONDARY CONTAINMENT SITE: XYZ MAINTENANCE YARD PROCESS: QUICK CONNECTOR BULK FUEL TRANSFER GENERAL DESCRIPTION: A vendor s tank truck drives onsite and parks adjacent to the fuel tank fill nozzle. Delivery driver connects a flexible fill line between the truck pump and the tank nozzle. Connections are camlock or equivalent. Valves on the truck and fill nozzle are opened and pumping is initiated. When tank is full, the pump is reversed to suction fuel from the flexible fill line and the hard pipe mounted to the tank. Valves are closed and the flexible fuel line is put back on the delivery truck. In situations where a fuel trailer is hauled behind the delivery truck, the flexible fill line is run between the trailer and the truck. The truck suctions fuel from the trailer. DETAILS A shutoff valve is located on the fill line and is accessible to the delivery driver. Connection line between truck and tank is up to 25 feet long. The most likely cause of a spill is a ruptured hose or a failed connection/ coupling. The truck transfers fuel at a maximum rate of 200 gallons per minute. An evaluation determined that a spill, should such an event occur, would not impede the delivery driver s access to the shutoff valve and that the valve could be safely closed within 10 to 15 seconds of the rupture or failed connection (based on past experience under similar circumstances). 20 seconds is considered a conservative estimate of the response time allowing extra time for the driver to recognize the situation. CALCULATIONS: The maximum spill volume for this scenario is: (200 gal/min) x (1 min/60 sec) x (20 sec) = 67 gallons CONCLUSIONS: Secondary containment measures should be able to hold at least 70 gallons of fuel plus tributary rainfall. Transfers should occur over an impervious surface. CONSIDERED SPILL SCENARIOS (IN ADDITION TO ABOVE): Closed valve on fuel tank this could lead to a hose or connection failure as described above. Overfilling of the tank tanks are equipped with overfill alarms that indicate when the tank is nearing full. In addition, an operator and/ or ordering error would be required for this type of spill. Spills when fuel lines are disconnected delivery drivers are expected to follow industry standards for spill prevention (e.g. utilize spill buckets drip pans). If this type of spill occurs, the volume will be much less than the scenario described above. SPCC Secondary Containment Assessment for Quick Connect Fuel Transfers Version 1.0 April 20, 2006

48 ODOT ASSESSMENT OF APPROPRIATE SECONDARY CONTAINMENT SITE: XYZ MAINTENANCE YARD PROCESS: FUEL PIPING BETWEEN FIXED TANKS AND FIXED DISPENSERS GENERAL DESCRIPTION: Aboveground storage tanks generally have fixed steel piping that connect the dispenser to the tank. Some fuel remains in the pipe even when dispensing pumps are not operating. DETAILS Pipes are only under pressure when pumps are activated for dispensing ODOT s Environmental Management System requires monthly visual inspection of piping. The most likely cause of a spill is a minor leak occurring at a fitting. Discharge rates would vary. 1 gallon per day is considered a conservative estimate of a potential release. An evaluation determined that a spill, should such an event occur, would not always be noticed quickly as a leak has potential to occur with or without employees present. Reaction times vary from immediately to several days. Safety features ensure that potential leaks will not create a siphon and draw down the tank. CALCULATIONS: The maximum spill volume for this scenario is: (π(2in) 2 /4) x (1 SF/ 144 in 2 ) x (30 ft) x (7.48 gal/cf) = 4.9 gallons (NOTE: Calculation is based on 30 feet of pipe with a 2-inch diameter and should be adjusted for site-specific conditions.) CONCLUSIONS: Secondary containment measures should be able to collect at least 5 gallons of oil and should function passively. CONSIDERED SPILL SCENARIOS (IN ADDITION TO ABOVE): Catastrophic failure due to vehicle, tree, or other impact - piping is protected from all but a deliberate impact. Features such as barriers and buildings would be struck first. Spill volume would be the same as above with a faster discharge rate. Rupture of piping while fuel is being pumped - there is no evidence to support this as a likely spill scenario. SPCC Secondary Containment Assessment for Piping Version 1.0 April 20, 2006

49 ODOT ASSESSMENT OF APPROPRIATE SECONDARY CONTAINMENT SITE: XYZ MAINTENANCE YARD PROCESS: VEHICLE TRANSFER TANK TO MOBILE OR STATIONARY TANK GENERAL DESCRIPTION: An ODOT vehicle equipped with a portable fuel transfer tank parks along side a tank or piece of equipment. Transfer tank is fitted with a pump and dispensing hose. Employee turns on pump, removes dispenser nozzle from storage bracket, and inserts nozzle into the fill port. Employee remains with vehicle while filling the tank or equipment. Employee dispenses fuel until tank or equipment is full and removes dispensing nozzle. Dispensing nozzle is stowed and pump is turned off. DETAILS A pump power control is located on the transfer tank and is accessible during fueling. The most likely cause of a spill is the nozzle falling out of the fill port. The pump transfers fuel at a maximum rate of 20 gallons per minute. An evaluation determined that a spill, should such an event occur, would not impede access to the pump control and that the pump could be safely stopped within 10 seconds of the nozzle falling (based on experience with similar circumstances). 15 seconds is considered a conservative estimate of the response time allowing extra time for recognition of the situation. CALCULATIONS: The maximum spill volume for this scenario is: (20 gal/min) x (1 min/60 sec) x (15 sec) = 5 gallons CONCLUSIONS: Active secondary containment measures should be able to collect at least 5 gallons of fuel. Transfers should occur over an impervious surface where possible. CONSIDERED SPILL SCENARIOS (IN ADDITION TO ABOVE): Tank is overfilled due to failure to trip the auto-shutoff valve on nozzle employee is required to remain with vehicle so response time and spill volume match the scenario described above. Dispensing hose springs a leak discharge rate would be slower than the scenario described above. Response time would be nearly identical because employees remain with vehicle during fueling. SPCC Secondary Containment Assessment for Fuel Delivery from a Transfer Tank Version 1.0 April 20, 2006

50 ODOT ASSESSMENT OF APPROPRIATE SECONDARY CONTAINMENT SITE: XYZ MAINTENANCE YARD PROCESS: USED OIL PICK-UP FROM STORAGE TANK INTO MOBILE TANK GENERAL DESCRIPTION: A tank truck drives onsite and parks in the vicinity of the used oil tank. A suction line is inserted into or connected to the used oil tank. Contents are suctioned into tank truck for removal from the site. Driver remains with tank truck while used oil is suctioned. DETAILS Used oil tends to be viscous to extremely viscous and does not flow easily. The truck driver is near the pump controls during the transfer. The most likely cause of a spill (extremely low probability) is overfilling of the collection truck. This situation is only possible with a major operator error or internal valve failure. Used oil would leak out of the air vent line of the truck tank. Suction rate varies depending on the viscosity of the used oil. 60 gallons per minute is considered a reasonable discharge rate. An evaluation determined that a spill, should such an event occur, would not impede access to the pump control and that the pump could be safely stopped within 15 seconds of the release (based on past experience and history with similar conditions). 15 seconds is considered a reasonable estimate of the response time. CALCULATIONS: The maximum spill volume for this scenario is: (60 gal/min) x (1 min/60 sec) x (15 sec) = 15 gallons CONCLUSIONS: Active secondary containment measures should be able to collect at least 15 gallons of oil. Transfers should occur over an impervious surface where possible. (NOTE: This is a general template. If a storm drain is located within the transfer area additional containment measures may be required. Response time to prevent a spill from reaching a storm drain or water body shall be based on site conditions and topography.) CONSIDERED SPILL SCENARIOS (IN ADDITION TO ABOVE): Spill during disconnection of transfer line line is empty, driver wipes off excess with a rag as part of standard procedure. Broken transfer line line is under negative pressure when pump is running, air would be taken into the suction line at a break. If full line broke while pump was off the contents of the line could leak, but the volume would be less than the volume considered above. Spill from running the suction pump in reverse this would require multiple operator errors. No history of this kind of spill was found. SPCC Secondary Containment Assessment for Used Oil Transfers Version 1.0 April 20, 2006

51 ODOT ASSESSMENT OF APPROPRIATE SECONDARY CONTAINMENT SITE: XYZ MAINTENANCE YARD PROCESS: TRANSFERRING OIL INTO WASTE OIL TANK, MANUAL GENERAL DESCRIPTION: An employee carries used oil in a bucket, pan, or other container to the used oil tank and pours contents into the top of the tank using a funnel or spout. DETAILS Bucket or other container contents are less than 5 gallons. The most likely cause of a spill is drips from the bucket or pan during transfer. Pouring rates vary. The spill volume would likely be less than one gallon. However, the entire contents of the container (5 gallons) may be spilled. An evaluation determined that an employee would be immediately aware of a spill, so response time is minimal. CALCULATIONS: The maximum spill volume for this scenario is: The largest spill volume is a full 5-gallon container (worst case). CONCLUSIONS: Active secondary containment measures should be able to collect at least 5 gallons of oil. Transfers should occur over an impervious surface where possible. CONSIDERED SPILL SCENARIOS (IN ADDITION TO ABOVE): Overfilling of the used oil tank spill volume would not exceed the volume listed above. Spill of a larger container containers larger than 5 gallons are not typically used to transfer oil because the containers are too heavy and awkward to carry. SPCC Secondary Containment Assessment for Used Oil Transfers Version 1.0 April 20, 2006

52 ODOT ASSESSMENT OF APPROPRIATE SECONDARY CONTAINMENT SITE: XYZ MAINTENANCE YARD PROCESS: TRANSFERRING OIL INTO USED OIL TANK, MANUALLY CONTROLLED PUMP GENERAL DESCRIPTION: An employee manually activates a pump to transfer used oil from a container inside the maintenance shop (typically a sump dolly mounted on the grease pit rails) to a used oil tank via fixed and/ or flexible piping. Employee turns pump off when used oil container is empty. DETAILS Pumping rates are low; typically between 1 and 14 GPM. Operation times are short. The most likely cause of a spill is a leak from a pipe fitting or connection. Discharge rates would be small and would only occur during the transfer (while the pump was turned on) or shortly thereafter. An evaluation determined that a spill would likely consist of small drips. Drips may not be noticed immediately and a small amount of oil may accumulate before cleanup occurs. CALCULATIONS: The maximum spill volume for this scenario is: An accumulation of small drips; less than 1 quart. CONCLUSIONS: Active secondary containment measures should be able to collect at least 1 quart of oil. Transfers should occur over an impervious surface where possible. CONSIDERED SPILL SCENARIOS (IN ADDITION TO ABOVE): Overfilling of the waste oil tank employee must verify that the used oil tank has sufficient available capacity prior to transferring used oil. Verification may consist of checking the tank level, knowledge of the amount of used oil in the tank, or other similar methods. Pipe rupture pumps are low flow and low pressure type that do not have the capacity to rupture fixed piping. No history of this kind of spill was found. Piping is not connected to or comes loose from tank systems are checked for leaks during installation. Once the system is in place, there is no reason (under routine operations) for piping to be disconnected. SPCC Secondary Containment Assessment for Used Oil Transfers Version 1.0 April 20, 2006

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