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Cross Hudson Project Confidential Trade Secret Critical Infrastructure CROSS HUDSON PROJECT ENVIRONMENTAL MANAGEMENT AND CONSTRUCTION PLAN ATTACHMENT H Spill Prevention Plan 02:OO2398_CC12_04-B2311 H-l R_EMCP Hudson River Segmenl.doc-2n9108 SPILL PREVENTION PLAN Cross Hudson Project Manhattan, New York ENSR Corporation February 2008 Document No.: 10923~12·100 H-3 H-4 Spill Prevention Plan ENSR' AECOM Cross Hudson Project February 2008 TABLE OF CONTENTS SECTION CROSS REFERENCE CHECKUST III SPP REVIEW LOG VII CONSTRUCTION ADMINISTRATOR APPROVAL VIII PROFESSIONAL ENGINEER CERTIACATION VIII DISCHARGE RESPONSE REPORTING - QUICK REFERENCE SUMMARY .IX 1.0 INTRODUCTION 1 2.0 SITE DESCRIPTION 1 3.0 FAOUTY DRAINAGE AND MANAGEMENT OF RUNOFF 2 3.1 Topography 2 3.2 Surface Water 3 3.3 Direction of Flow 3 3.3.1 Upland Segment 3 3.3.2 Hudson River 4 4.0 OIL STORAGE OPERATIONS 4 4.1 Refueling Protocols 5 4.1.1 Land-Based Equipment 5 4.1.2 Marine Equipment 5 4.2 In-Process Use Oils 6 4.2.1 cable Installation 6 5.0 LOADING/UNLOADING PROCEDURES 7 5.1 Bulk Fuel Transfer 7 5.2 Drum Transfers 8 6.0 INSPECTIONS AND RECORDS 9 7.0 SECURITY 9 8.0 PERSONNEL TRAINING 10 9.0 EMERGENCY RESPONSE 10 9.1 Emergency Equipment 10 9.2 Emergency Procedures 11 10.0 NOTIFICATIONS 13 10.1 Oral Notifications 14 10.2 Written Notifications 14 H-5 Spill Prevention Plan ENSR I AECOM Cross Hudson Project February 2008 11.0 SUBSTANTIAL HARM 16 12.0 PLAN AMENDMENTS 16 12.1 Plan Review 16 12.2 Professional Engineer (PEl certification 16 13.0 ENGINEERING DEACIENOES 17 APPENDICES Appendix A sampleInspection and Reporting Forms & Spill Response Equipment AppendiX B Sample SPP Training Outline Appendix C certification of the Applicability of the Substantial Harm Criteria Appendix D Tables Table 1-1 Emergency Contacts Table 4-1 Oil Source Summary Appendix E Site Plan Figure ii H-6 Spill Prevention Plan ENSR I AECOM Cross Hudson Project February 2008 CROSS REFERENCE CHECKUST 4OCFIl112 Reclulrilmenbl spp 5ectIon . section " SUb rt A':'~ IIC!1blj~ii~nJtlliia;.l &...l:~~~rgt~I\:~lltIi'~AI/Typei of\OIlll ~ , . 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"/;;-' , .," '-: General applicability and exclusions: Non-transportation related facility that uses oil in quantitiesthat could be expected to discharge oil quantities that may be harmful to navigable waters of U.s, or adjoining shorelines must implement an SPP, Does not apply to: • Equipment not subjectto 311(j)(1)(C) of CWA • Facility not reasonably expected to havea discharge of oil N/A Equipment subjectto authority of USOOT 112,1 • General Total underground storage S 42,000gallons • Information Total aboveground storage S 1,320gallons • Only • Containers with capacity of < 55 gallons • UST/ancillary equipmentsubjectto technical requirements of Part 280/281 • Facility used exclusively for wastewater treatment (production, recovery, recycling of oil is not treatment) Key Definitions: BulkStrJr.Jge Container- container used to storeoil, used for purposes including the storage of oil prior to use, while being Used, or prior to further distribution in commerce, Oil-filled electrical, operation, or manufacturing equlprnent is not a bulk storage container. N/A 112.2 Navigable Wale<s-watersof the U.S. including: General • Waters used for interstateor foreign commerce Information • Waters subjectto ebb and flow of tide Only • Interstate watersand wetlands • Intrastate waters, wetland, mudflats, etc., which if used could affect interstate or foreign commerce (including travel, recreation, fishing, industry, etc.) Timeline to prepare and Implement SPP: N/A • If operational prior to Aug. 16, 2002: amend plan by Apr. 17, 2003 and implement by Oct. 18, 2003 112.3(a-c) General If operational between Aug. 16, 2002and 18, 2003: prepareand implement by • Oct. Information Oct. 18, 2003 Only • If operational after Oct. 18,2003: prepare and implement before operations begin Certification Requirements: A licensed Professional Engineer (PE) must review the Plan for it to be effective. certificationshould state: • The PE is familiar with requirements of 40 CFR 112. The PE (or an agentof the PEl hasvisited and examined facility. 112.3(d) • Page V • Plan hasbeenprepared in accordance with good engineering practice and applicable industry standards. • Procedures for required inspections and testing have been established. • Plan is adequate for facility. Reeordkeeplng: Plan must be maintained at the facility, if facility is normally attended at 112.3(e) least4 hours per day or at the nearest field officeand must be available to EPA for on-site 6.5 reviewduring normal working hours. 112.3(f) Requests for Extensions: EPA may authorize extensions to plan deadlines. N/A ... 111 H-7 Spill Prevention Plan ENSR I AECOM Cross Hudson Project February 2008 CROSS REFERENCE CHECKUST 40CFR 112 Requirements . Spp 5ectIon 5ectIon Significant Spill Reports: SignifICant oil spills to navigable waters require filing of a report to EPAand the State (include information in 112.4). Significant spills include single 10.2, 112.4 discharges> 1,000 gallons or two or more discharges> 42 gallons within 12 month period. Appendix B The SPP may be required to be formally amended and submitted to EPA for approval. I Amendments: Plan review and evaluation required every S years. Necessary amendments (i.e., those that include more effective prevention and control technology) must be made 112.5 within 6 months and the updated Plan must be implemented within 6 months of the update. 12.0 Document these reviews and include in Plan. A Professional Engineer must certify technical amendments. Management Approval: Plan must have full approval of management to commit the 112.7 Page V necessary resources to fully implement the Plan. Cross Plan Elements - Confonnance: Include discussion of facility's conformance/ compliance reference 112.7(a)(1-2) with applicable requirements. Checklist 1.0 Plan Elements - Facility Diagram: Describe physical layout of facility and include facility 2.0 112.7(a)(3) diagram. Diagram must show: location and contents of each container; completely buried tanks; transfer stations; connecting pipes. Rgure 1-1 112.7(a)(3)(i, iii), Plan Elements ­ Storage and Control: Discuss type and amount of oil in containers, 4.0 & (b), (c) controls (e.g. secondary containment), and other structures. Table 4-1 Plan Elements - Discharge Prevention: Discuss discharge prevention including 4.0& 112.7(a)(3)(ii) procedures for routine handling of products (loading/unloading). Table 4-1 Plan Elements - Countermeasures: Discuss countermeasures fordischarge recovery, 112.7(a)(3)(iv-v) 9.0 response, and cleanup (include methods of disposal/recovery). Plan Elements - Notifications: Include contact list and phone numbers for facility 112.7(a)(3)(vi) response coordinator, National Response Center, cleanup contractors, and appropriate 10 Federal, State, and local agencies who must be contacted. Plan Elements - Emergency Response: Provide procedures to enable a person to 112.7(a)(4-S) 9.2 respond to a discharge and report necessary information. Plan Elements - Facility Drainage: Include prediction of direction, rate of flow, and 112.7(b & c) quantity that could be discharged as a result of major equipment failure. Provide 3.0 appropriate containment and/or diversionary structures or equipment. plan Elements - Non-Conformance: If conformance is not practicable, explain why and provide an oil spill contingency plan (per Part 109) along with a written commitment of 112.7(d) N/A personnel, equipment, and materials required to control and remove any quantity of oil discharged that may be harmful. IV H-8 Spill Prevention Plan ENSR I AECOM Cross Hudson Project February 2008 CROSS REFERENCE CHECKUST - 40CFIt 112 Requirements Spp section section Plan Elements - Inspections, Tests, and Records: Conduct inspections, tests, and 112.7(e) records in accordance with written procedures developed for the facility. Maintain records for 6.0 3 years. Plan Elements - Training: At leastannually, train/brief oil handling personnel in 112.7(f)(t,3) 8.0 equipment/facility operations, discharge procedures, applicable regulations. Plan Elements ­ Designated Individual: Designate a person who is accountable for 112.7(f)(2) 2.0 discharge prevention and who reports to facility management. Plan Elements - security: Ensure your facility hasadequate security to prevent vandalism and respond to emergencies: • Fence oil storageareas and lock/guard when facility is unattended. 112.7(g)(t-5) • Ensure masterflow valves and valves pennilting outward flow remain closed. 7.0 • Lock starter controls in 'off" position and allow access to authorized personnel. • Securely cap or blank-flange loading/unloading connections of piping. • Provide facility lighting. Plan Elements ­ loading/Unloading: Design loading/unloading areas to containthe lt2.7(h)(I) 5.0 maximum capacity of any single compartment of a tank car/truck. Plan Elements - Loading/Unloading: Provide interlockwarning light or physical barrier 112.7(h)(2-3) system (e.g., wheel chocks) to preventvehicle departure beforedisconnection of transfer 5.0 lines. Priorto filling/departure, closely inspect vehicle. Plan Elements - Repairs: Evaluate aboveground container if it undergoes a 112.7(i) 6.0 repair/alteration or a change in service that might affect riskof discharge. Plan Elements - Conformance, Additional Regulations: Include discussion of 112.7(j) 1.0 confonnance with morestringent State rules, regulations, and guidelines. Requirements for Petroleum Oils and N"n"Petroleum Oils, Except animal Fats and Oils and G~ and fish and Marine Mammal Oils; and Vegetllble Oils (Including 01l.1roIn Seecb,.Nuts, Fruits, and Kernels): .­ , ",..; " 112.8(a) Meetgeneral requirements listed underSect. 112.7. (see above) Plan Elements - Facility Drainage: Diked areas ­ drainage must be manual, keep bypass valveclosed, inspect retained rainwater, open the bypass valve and reseal it 112.8(b)(1-5) following drainageunder supervision, keep records. Undiked areas With a ootential for a 3.0 and (c)(3) discharoe ­ designflow so oil is retained or returned to facility, provide redundancy for pumps used to treat drainage.
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