SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN

Transcription

1 2/5/92 (Model) SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN Reference: Federal Regulation 40CFR Part 112, Part II Type of Facility: Petroleum Products Marketing Bulk Plant Facility: Able Oil Company Street Address: 101 Betterway Road Mailing Address: P.O. Box 1000, High Prospects, N.C MANAGEMENT APPROVAL Authorized Agents Name Title Signature ENGINEERING CERTIFICATION The undersigned certifies and attests that he is (1) familiar with this Regulation, (2) that he has visited and examined this facility, (3) that the Plan has been prepared in accordance with good engineering practice and with the requirements of this regulation, (4) that any required testing has been completed, (5) the Plan is adequate for the above-named facility. Signature Date 1

2 TABLE OF CONTENTS ITEM PAGE Contact List and Telephone Numbers General Description of Physical Plant General Spill Prevention Controls and Countermeasures Spill Reporting Documentation Prediction of Spill Characteristics Containment and Drainage Control Structures Alterative Oil Spill Contingency Plan Inspections, Tests, Records Personnel Training and Spill Prevention Procedures Security Loading/Unloading Facilities Facility Drainage Bulk Storage Tanks Facility Transfer Operations APPENDIX Plot Drawing of Facility General Area Map, Facility Designated ATTACHMENT C-II Certification Of Substantial Harm Determination Form 2

3 CONTACT LIST AND TELEPHONE NUMBERS (Ref ) 1. Local Fire Department 2. "Person-In-Charge" of Facility Spill Response Home Telephone Number and Street Address 3. Local Emergency Planning Committee or Haz-Mat Response Team, Telephone Number 4. Emergency Cleanup Contractor or Response Facility Name, Telephone Number 5. State Division of Environmental Management 6. National Response Center 7. State Emergency Response Commission 8. Downstream Water Suppliers Who Need to be Notified 3

4 GENERAL DESCRIPTION OF PHYSICAL PLANT (Ref ) This facility is a petroleum bulk storage plant for marketing and redistribution of petroleum light products, gasoline, kerosene, and No. 2 diesel fuel oil. A supplemental drawing, next to the last item of the Plan, describes the configuration of the bulkplant, including storage and transfer facilities, property boundaries, access roads, drainage patterns, on-site buildings, and a reference to the nearest "navigable water". A general area map is the last item of the Appendix, and it describes the Facility's geographic location, access roads, and nearest navigable waters. Physical facilities and operational procedures, as described herein are intended to achieve, in principle, EPA Regulation 40 CFR-Part 112. Facilities generally comply with most provisions of the National Fire Protection Standard 30, "Flammable and Combustible Liquids Code" and, where dispensing to vehicles occurs, to NFPA Standard 30A, "Automotive and Marine Service Station Code". Some features relate to special provisions of the North Carolina Fire Code, Volume V. Newly constructed facilities should substantially meet all of the above standards. Any aboveground storage tanks, piping, pumps, and loading/unloading arrangements conform to NFPA 30 requirements. Any underground storage tank facilities comply with Federal U.S.T. Regulation Part 280 and are, therefore, exempt from this Plan's inclusion. Bulk deliveries of liquid petroleum products made to this operation are received from truck-transport tankers and are transferred into the storage tanks. Liquid product are transferred from storage tanks to a loading rack where transfers are made to "tankwagon vehicles" for smaller bulk deliveries to residential and commercial customers in the surrounding area of service. For facilities with aboveground storage tanks the pumps are arranged to transfer products from transport tanker vehicles into the tanks and, concurrently, supply products to the loading rack for loading account tank-vehicles making local deliveries. 4

5 GENERAL SPILL PREVENTION CONTROLS AND COUNTERMEASURES (Ref (a)(b)(c)) The prevention of oil spillage and its reaching navigable water is inherent in the design of the plant's physical facilities and operating procedures which will be discussed in detail in subsequent paragraphs. Physical facilities feature storage designs which we include provisions for to prevent unauthorized access and thereby insure accountability storage tank ullages can be determined, both to prevent overfilling as well as to serve as leak detection capability. Spillage resulting from equipment failure such as broken valves, hose failure, etc. will be contained within secondary containments or diverted to such. The secondary containments are described in subsequent paragraphs. Although operating procedures include precautionary measures to prevent or anticipate overfills, unexpected discharges due to equipment failure, and smaller "house-keeping" drippages, this Plan also addresses contingent and emergent situations which will relate to spill reporting, emergency containment, spill stoppage, safety assurance, and remedial action. If physical facilities do not meet 40-CFR 112 specifications regarding fully effective discharge collection and containment, a full-scope contingency plan, reference 112.7(d), will be developed as part of this Plan. Regardless, however, an adequate amount of contingency planning is made for this facility to provide for personnel responsibilities and contact information, spill-response resources and telephone numbers, spill-reporting telephone numbers, and access to dedicated spill-response equipment. 5

6 SPILL REPORTING DOCUMENTATION (Ref (a)(1)) Name of Facility: Address, Geographic: Address, Mailing: Telephone Number of Facility: Spill Date Time-of-Day Type of material spilled Estimated Total Quantity spilled Estimated Quantity Spilled into Navigable Water Source of spill Description of Affected Medium Cause of Spill Damages or injuries caused by spill Actions used to stop, remove, mitigate spill effects Names of Persons or Organizations who have been contacted 6

7 PREDICTION OF SPILL CHARACTERISTICS (Ref (b)) This facility is provided with spill collection and containment facilities which are intended to prevent spillage from reaching and entering navigable water. Therefore, the predictions described as follows are based upon the failure of normal storage or piping facilities and the additional failure of collection and containment facilities to prevent spillage from escaping the facilities. The following predictions include direction, rate of flow, total quantity of oil that could be discharged as a result of each major type of failure. 1. Direction, route, including type of terrain, flow velocity of spill, intersected roads and culverts, name of stream or body or water, distance to water. 2. Estimated Quantity and Rate of Spillage (a) Tank and Storage Containment Failure (b) Transport Tanker Unloading Pad Containment Failure (c) Loading Rack Pad Containment Failure (d) Other sources of spillage 7

8 CONTAINMENT AND DRAINAGE CONTROL STRUCTURES (Ref (c)) Regulation CFR generally requires the following prevention systems or their equivalents: Dikes, berms, retaining walls, curbing, culverting, gutters, weirs, booms, spill diversion ponds, or impounding basins, or sumps, and sorbents. This facility is equipped as follows: Storage Tanks A dike constructed surrounds the aboveground tanks, and its net containment volume exceeds that of the single largest tank within the system plus and additional allowance for precipitation accumulation. The entire containment system, including walls and floors of the system have been constructed or modified so that they will be imperviors to oil for 72 hours and that oil will not permeate, drain, or escape in any way from the containment system and escape to navigable waters before cleanup occurs. Dike construction, materials description: Transport Tanker Unloading Pad A concrete pad is provided as the parked position of the transport tanker while being unloaded for transfer of products into the storage tanks. The pad is so constructed and contoured with raised perimeter or grate drains, that any spillage thereon will be received and diverted to an outlet drain. The spillage will be conducted to one of the following: (1) An oil-water separator with adequate oil storage capability, periodic effluent monitoring, and periodic separator checking for accumulation; or (2) A normally empty emergency overflow tank-receptor of adequate storage capacity. The receptor will be periodically and frequently checked for accumulation, and evacuation performed as required; or (3) Remote impoundment of spillage is performed by arrangement of a berm or retaining wall to which spillage will flow from the parked transport position while unloading. For methods (1), (2), or (3) the oil spill containment volume is at least equal to a full transport compartment volume. This volume is approximately gallons. Loading Rack Pad The loading rack pad is constructed similarly to or may be constructed in conjunction with the transport unloading pad. It provides the parked position for account tank-vehicles when their compartments are supplied by loading arms of the loading rack to which is piped petroleum products from storage tanks. Construction and containment alternatives are similar to those of the transport-tanker unloading pad, except that provision for total spillage will be less as based upon the smaller compartment volume of account tank-vehicles, approximately gallons. 8

9 ALTERNATIVE OIL SPILL CONTINGENCY PLAN Ref (d)) (Applicable only if containment structures and provisions of preceding paragraph, "Containment and Drainage Control Structures", are not practicable. Owner must demonstrate the impracticability by explanation and justification. This CONTINGENCY Plan must be a "stand-alone" section of the SPCC Plan and must be sent to the EPA Regional Administrator, Region IV, Atlanta, GA for his review and approval.) Facility Able Oil Company Street Address 101 Betterway Road Mailing Address P.O. Box 1000, High Prospects, N.C MANAGEMENT APPROVAL Authorized Person's Name Signature CONTENTS 1. CONTINGENCY Plan Details Demonstration and Justification of Impracticability Integrity Tests: Tanks each five years; piping each year Description of Response plans Personnel needs Methods of Mechanical containment Methods of Spilled Oil Removal Access and Availability of Sorbents, containment booms, accessories 2. Commitment of Manpower, Equipment, and Materials 9

10 CONTINGENCY PLAN DETAILS Demonstration and Justification of Impracticability This facility was constructed approximately 45 years ago when fire, safety, and environmental codes were either non-existent or profoundly simple. The continuing arrangement of storage facilities, the available space limitations, and the loading/unloading facilities arrangement, all make an effective containment system impossible. the only feasible alternatives would be either to demolish the bulkplant and begin anew or to continue functioning with a suitable contingency provisions. Contingency provisions are described below. Integrity Tests Storage Tanks will be given a formal tightness test upon receipt of approval of this Contingency Plan and will be subsequently tested at five year intervals. The integrity test will consist of a test at the "full" level, including consideration of temperature compensation. A leak detection sensitivity of 0.10 gallon per hour will be the test criteria. Tests may also use the criteria of sonics, ultra-sonics, or radiographics if testing resources utilize these methods to achieve results acceptable within EPA specified limits. A Form for recording integrity tests is included with this SPCC Plan and is found on page. Aboveground tanks will also be checked for leakage by inventory control procedures that consider gross gallon receipts, metered loading rack outputs, and periodic gauge readings of the tank. Aboveground storage tanks will be visually checked daily by employees during the normal performance of their duties. As explained in another section of this Plan, formal inspections of tanks and their inspections will be made periodically. Description of Response Plans Spill detection and reporting procedures will be made according to the following restatement of "Contact List and Telephone Numbers" from page of this SPCC Plan: 10

11 CONTACT LIST AND TELEPHONE NUMBERS 1. Local Fire Department 2. "Person-In-Charge" of Facility Spill Response Home Telephone Number and Street Address 3. Local Emergency Planning Committee or Haz-Mat Response Team, Telephone Number 4. Emergency Cleanup Contractor or Response Facility: Name, Telephone Number 5. State Division of Environmental Management 6. National Response Center 7. State Emergency Response Commission 8. Downstream Water Suppliers Who Need to be Notified The Response Plan will be administered by the "Person-In-Charge" as named above. It will depend upon specific duties to be performed by designated persons as identified in the subparagraphs below. As explained under "Personnel Training", all employees have been rehearsed in a spill scenario. Appropriate personnel have investigated the potential route of moving spillage and have noted available curbs, storm drains, culverts, and ditching that are accessible for counteraction efforts: erection of ditches or barricades, berms, absorbent booms, siphons, and sandbags. In an oil spill emergency, the following steps will to taken: 1. Source of spill will be stopped, if possible, by person having control of the related facility or by the person discovering such spill. 2. The office will be notified at once, and the "Person-In-Charge" for oil spill events and oil prevents will be summoned at once. The employee who is designated to perform emergency contacts is. 3. The "Contact" person shall immediately summon the fire department which shall assess and abate fire safety hazards as necessary. The use of foam rather than water will be urged for abating flammability hazards. (See Contact list). If the spill occurs within diked areas, water will be introduced at once to foam a layer under the oil. Employees will observe OSHA Standards as necessary regarding respirators, fire safety, etc. 4. The "Contact" person shall then notify the Local Emergency Planning Committee and its Haz. Mat Team, if the situation, as assessed by the "Person-In-Charge", so requires. (See Contact List) 5. Concurrent with steps 3 and 4, the "Person-In-Charge" or his designee, shall verify that containment of the spillage is effective or begin taking countermeasure actions in the spill pathway as necessary. He shall also determine if general evacuation of employees from the premises is advisable at this time and take action accordingly. 11

12 6. The "Countermeasure" actions in "5" will include access to an on-site, dedicated, identified cache of emergency response items including: ( ) bags absorbent pellets; ( ) absorbent pillars; ( ) 8"x10'long (approx.) absorbent booms; set of assorted hand tools; prefabricated drain seal; 2" portable transfer pump; ( ) 1000 gallon empty tanks; ( ) sandbags; and ( ) half-mask respirators (for gasoline exposure). The actions will require the following employees to assist the "Person-In-Charge". (a) (b) (c) (d) (e) 7. Concurrent with steps "5" and "6", the contact person will report the spill to the N.C. State Division of Environmental Management and the National Response Center. (see Contact List). 8. If the magnitude and difficulty of the spill appear to increase the probability of loss of control and loss of containment, the "Person-In-Charge" shall summon a prearranged oil spill emergency cleanup contractor to mobile oil spill response unit as owned by the local cooperative. This unit is identified as (4) under Contact List and Telephone Number on page. 9. The "Contact" person will report the spill to the State Emergency Response Commission (see Contact List). 10. The "Contact" person, as advised by the "Person-In-Charge" according to the circumstances, will notify downstream water suppliers. (see Contact List) 11. The "Person-In-Charge" will direct that retrieval of spilled oil be initiated at the earlist feasible time. Retrieval methods will utilize absorbents, portable transfer pump and holding tank, skimmer pump, or other appropriate equipment. 12. Contaminated soil will be removed by the cleanup contractor or the facility's employees and placed upon plastic or in trucks for transportation to disposal site. The extent of soil removal and site remediation will be under the explicit guidance of the N.C. Division of Environmental Management Regional Office. The Facility's "Person-In-Charge" will assure that the necessary tests, documents, and train of events as required by the D.E.M. be in full compliance. Final method of disposal of contaminated soil will depend, in part, upon the D.E.M. and may include land-farm application, incineration, or integration into brick-making. Commitment of Manpower, Equipment, Materials The Owner has made careful study and consideration of this Contingency Plan, and his financial requirements to achieve immediate compliance. He also has assessed the financial impact of an oil spill cleanup situation with respect to the costs of employee's time, costs of a cleanup contractors or oil-spill cooperative use, costs of remediation, and costs of recordkeeping and documentation. By the "Authorized Signature" under "Management Approval" on the cover sheet of this Contingency Plan, the owner/operator also commits for necessary financial commitment. (END OF CONTINGENCY PLAN) 12

13 INSPECTIONS, TESTS, RECORDS (Ref (e)) The inspections are for the basic part of the Plan. All inspection and test records are to be kept for a period of five years. (All inspections monthly except as noted) STORAGE TANKS Tank Leakage (visual) Water Test Valves Manhold Covers & Gaskets (visual) Vents, Open & Operative Deformation in vicinity of piping connection PUMPS & PIPING Piping, Aboveground Piping, Underground (Annually tightness test) Gaskets Unions Hydrostatic Relief Valves Valves, Gate Check Strainers Unloading Hoses, Dry-Rotting Unloading Couplings Pumps, Lubrication, Supports LOADING RACK Piping Valves, Gate Valves, Self-Closing Loading Arms Meters Fire Extinguishers Static Ground Cables Platform and Stops SECONDARY CONTAINMENT Diking State-of-Repair, as Applicable Pads for Loading & Unloading Berm State of Repair, as Applicable 13

14 INTEGRITY TESTS FOR TANKS & PIPING (Ref (d)) (Copies of Test Reports by Testing Company to be Inserted After this Page) DATE TANKS TANK SUPPORTS TESTING COMPANYTEST RESULTS EACH FIVE YEARS (OR EACH TEN YEARS IF CONTINGENCY PLAN IS NOT REQUIRED) DATE PIPING TESTING COMPANY TEST RESULTS EACH YEAR 14

15 PRECIPITATION RELEASE FROM SECONDARY CONTAINMENTS (Ref (c)(3)) (Evacuation from dikes, impoundments, overflow receptors) TREATMENT ABSORBENT WATER INSPECTOR'S DATE REQUIRED? DISCHARGED INITIALS 15

16 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES (Ref (f)) Facilities Designated Person For Oil Spill Prevention: Training Scope and Frequency At least annually all personnel are given training in oil spill prevention, including operation and maintenance of equipment. They are given thorough reviews of all parts of this SPCC Plan, both for routine operations and for emergency situations. Where specific responsibilities are assigned, these requirements will be reviewed. All such training occasions will be documented with an employee roster which is signed by each employee. This document will be kept in the master binder or file of the SPCC Plan. A copy of the Plan will be on display, accessible to all employees at all times. New employees will be given as much spill prevention training as is commensurate with his new status and ability to be effective. This training will be provided within one week of his employment. Training for all employees will include references and analysis of any past spills and the experience resulting therefrom. The Person-In-Charge oil Oil Spill Prevention (generally, the same for supervising oilspill reactions and coutnermeasures) will designate specific personnel to (1) make contacts and report spills in a spill incident, (2) undertake control of spillage, assure containment, retrieve spillage, (3) restore property and remediate contaminated property except where an outside cleanup contractor may perform this function. The designated spill response cmployees, with the Person-In-Charge in command, will undertake a rehearsal of a spill incident. The rehearsal will include an investigation of the potential flow route of spillage with special attention given to strategic points to achieve barricading, sealing, and containment: curbs, drains, culverts, open ditches. The Person-In-Charge will utilize the "Contact List and Telephone Numbers" on page in developing a training session for oil-spill response. All employees will be reviewed in the basic and essential of the Hazard Communications Standard (Employee Right-To-Know) and Material Safety Data Sheets for all products will be accessible to them. Where their duties place them in contact with exposed petroleum products and petroleum-handling equipment, their on-the-job training will include such practices that will tend to minimize exposures and hazards that might be injurious. 16

17 SECURITY (Ref (g)) Fencing This facility is equipped with security fencing and lockable gates which are closed and locked during non-operating hours and unattended hours. Valves The master flow valve on each tank is closed and locked in position during non-operating and unattended hours. Pumps The electrical power to the transfer pumps shall pass through at least one switch in the "off" position and accessible only to authorized personnel during non-operating and unattended hours. Piping Piping connections not in service or out of service for six months or more shall be capped or blank-flanged. All piping connections in service shall be color-coded or equipped with product identification signs. Lighting This facility is equipped with automatic area lights so positioned as to illuminate the bulkplant and office facilities. The site drawing of this SPCC Plan shows the location of area lights. 17

18 LOADING/UNLOADING FACILITIES (Ref (h)) Loading and Unloading Pads The "Tanker Transport Unloading Pad" and "Loading Rack Pad" are described under "Containment and Drainage Control Structures" on page. Drainage from these pads is piped to one of the following (underline the one in use): (1) Oil-Water Separator, monitored periodically, capacity, including supplemental tank to hold a full compartmental volume. (2) Quick-drainage catchment basin or tank, normally empty, with storage capacity equal to full compartmental volume. Disconnections Warning signs are provided in the Loading Rack area to caution drivers departing before complete disconnection of flexible or fixed transfer lines. Departures Prior to filling and departure of any tank vehicle, the lower drain and all other outlets will be checked for leakage. Any problems will be corrected before departure. Procedures for Transferring Products When reloading products into the compartments of account tank vehicles at the loading rack, the following steps will be followed: (1) No one in tank vehicle and brakes set. (2) When gasoline is to be transferred through open top hatches, the tank vehicle will be electrically connected through a bond wire with the loading rack before the gauging or transfer starts. (3) The ullage of each compartment is determined before transfer to prevent overfilling (or automatic fill limit controls are used) (4) The fill-arm extension is inserted to the bottom of the compartment for gasoline transfers (bottom loading if Stage I Vapor Recovery is applicable to outgoing gasoline at the Loading Rack.) (5) The self-closing valve is held open manually by the operator. (6) When filling is complete, the arm is withdrawn and allowed to drain briefly into the compartment to minimize after-drip (7) During filling each compartment all other compartment hatches are kept closed. When unloading transport compartments by transfer to storage tanks, the following steps will be taken with an attendant continuously present to monitor the process: (1) No one in transport and brakes set. (2) Quick-connectors on the transfer hose connect compartments and respective pump intakes (or underground tanks directly.) (3) The ullage of each tank shall be determined before starting transfer process (or automatic fill limit controls are interlocked.) (4) If gasoline is transferred, Stage I Vapor Recovery connections are made. (5) During the transfer the attendant remains alert for proper venting and transfer hose integrity. (6) When the transfer is complete, the pump is stopped, the compartmental valve is closed. (7) The transfer hose is elevated at the compartmental end and the pump restarted to evacuate wet hose or the wet hose is drained into an appropriate receptable, not on the ground. (8) If gasoline was transferred, the vapor return hose is disconnected at tank end and transport manifold end. 18

19 FACILITY DRAINAGE (Ref (b)) Drainage From Diked Areas Diking systems approved under this regulation will accumulate water; such water will not infitrate or seep away. Therefore, drainage of water accumulation must be restrained for evaluation before release. If water has no perceptible contamination, it may be removed by one of the following methods. The underlined method applies to this facility. (1) External; lockable valve (gate, ball, 1/4 turn, or plug cock) (2) Accumulation sump and manually controlled sump pump (3) Siphon arrangement, manually started. If water has perceptible contamination it will be transferred to a holding tank for subsequent treatment or it will be transferred to the oil-water separator when such facility is installed. Each occasion of water removal from the diked area is recorded on the form, "Precipitation Accumulation In Secondary Containments" found under INSPECTIONS, TESTS, RECORDS on page. Drainage From Undiked Areas For facilities having storage and transfer arrangements without secondary containment provisions all drainage shall flow into ponds, lagoons, or catchment basins designed to retain oil spillage. This facility has secondary containment for its storage and transfer arrangements, and the foregoing provision does not apply. 19

20 BULK STORAGE TANKS (Ref (c)) Aboveground Tanks (Also see site drawing) Tank I.D. Capacity Horiz./Verti. Product Stored ,000 gals. Vertical Gasoline, Reg. Unleaded ,000 gals. Vertical Gasoline, Plus Unleaded ,000 gals. Vertical Gasoline, Premium Unleaded ,000 gals. Vertical Diesel, No. 2-D ,000 gals. Vertical Diesel, No. 2-D ,000 gals. Vertical Kerosene, 2-K ,000 gals. Vertical Kerosene, 1-K All storage tanks are suitable for the product stored and are labeled UL-142. Emergency relief venting consists of weak weld seams between conical tops and shells of tanks to relieve at approximately 2.5 psig. pressure. Tanks are equipped with tape-type gauge systems, read near ground level. Each tank has a lockable valve on its main flow connection. (or refer to liftable manhole covers or large diameter vents if either of these alternatives are used.) The tank configuration is surrounded by a diking system as described under "Containment and Drainage Control Structures", page. These tanks will be integrity tested as required by Regulation 40 CFR-112 every ten years and when repairs are made. Integrity testing, as described also under "Contingency Plan" will use available field testing services that employ hydrostatic testing, radiographic testing, visual inspections, ultrasonic testing, accoustic emissions testing, non-destructive shell testing, or combinations of these tests. Records will be kept, using the Form, "Integrity Tests For Tanks & Piping" found under "Inspections, Tests, Records" of this SPCC Plan on page. Tank supports and foundations shall be included in these inspections. Overfill prevention is engineered to nearly fail-safe status for these tanks by the strictly enforced procedure of reading direct vision gauges for determining ullages before intiating product transfers as described under "Loading/Unloading Facilities", procedures for transferring products, page. Visible oil leaks from sources such tank seams, gaskets, rivets, and bolts sufficiently large to cause oil accumulations will be removed with 72 hours from the time the accumulation occurs in accordance with the SPCC Regulations. 20

21 FACILITY TRANSFER OPERATIONS (Ref (d)) Piping Locations Existing piping is aboveground from intake connections to pumps to storage tanks. Piping from pump discharges to the loading rack is substantially underground and re-emerges as risers to loading rack arms. Piping Characteristics and Corrosion Protection. All piping is Schedule 40 (Std. Wt.) wrought steel pipe fabricated with malleable iron fittings. Aboveground piping is painted for protection against corrosion. Underground piping has a galvanized coating. Any new, or replaced underground piping will meet the same standards as U.S.T. Regulation 40 CFR Part 280: either a properly coated and cathodically protected steel pipe or UL-approved fiberglas. Inspections and Testing All aboveground valves, piping, and attached equipment are subjected to monthly examinations by operating personnel. Such inspections are implemented using the form found under "Inspections, Tests, Records" on page of this SPCC Plan. The underground piping is tightness tested annually, using the same form described above for aboveground piping. Records of the above tests are kept for five years. Piping Protection Vehicular traffic into the bulkplant area is advised and warned orally to ensure that their vehicle will not damage piping or other facilities. Underground piping has been investigated to ensure that it is sufficiently deep or otherwise protected to prevent damage. Where aboveground piping and equipment is exposed to possible vehicular damage, protective steel barriers have been erected or concrete curbing or bases have been provided. 21

22 DRAWING OF FACILITY (Ref (a)(3)) 22

23 GENERAL AREA MAP, FACILITY DESIGNATED 23

24 ATTACHMENT C-II CERTIFICATION OF SUBSTANTIAL HARM DETERMINATION FORM FACILITY NAME: FACILITY ADDRESS: 1. Does the facility have a maximum storage capacity greater than or equal to 42,000 gallons and do the operations include over water transfers of oil to or from vessels? YES NO 2. Does the facility have a maximum storage capacity greater than or equal to one million (1,000,000) gallons and is the facility without secondary containment for each aboveground storage area sufficiently large to contain the capacity of the largest aboveground storage tank within the storage area? YES NO 3. Does the facility have a maximum storage capacity greater than or equal to one million (1,000,000) gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C-III or an alternative formula* considered acceptable by the RA) such that a discharge from the facility could cause injury to an environmentally sensitive area as defined in Appendix D? YES NO 4. Does the facility have a maximum storage capacity greater than or equal to one million (1,000,000) gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C-III or an alternative formula* considered acceptable by the RA) such that a discharge from the facility would shut down a public drinking water intake? YES NO 5. Does the facility have a maximum storage capacity greater than or equal to one million (1,000,000) gallons and within the past 5 years, has the facility experienced a reportable spill in an amount greater than or equal to 10,000 gallons? YES NO *If an alternative formula is used, documentation of the reliability and analytical soundness of the alternative formula must be attached to this form. CERTIFICATION I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate, and complete. Signature Title Name (please type or print) Date 24