January 31, 2019 2018-3756 Mr. Ragesh R. Patel Regional Manager

January 31, 2019 2018-3756

Mr. Ragesh R. Patel Regional Manager Environmental Cleanup and Brownfields Pennsylvania Department of Environmental Protection 2 East Main Street Norristown, Pennsylvania

RE: Response to PADEP Request for Characterization and Demonstration of Attainment of a Cleanup Standard for Groundwater Former Marcus Hook Pump Station 1111 West Ridge Road Lower Chichester Township Delaware County

Dear Mr. Patel;

Advanced GeoServices Corp., a Montrose Environmental Group company (AGC/Montrose), on behalf of the Interstate Energy Company, LLC (IEC) is submitting this letter in response to the Pennsylvania Department of Environmental Protection’s (PADEP) letter dated December 21, 2018 (PADEP letter) to Mr. Curtis Rounds, approving the Act 2 Final Report dated October 10, 2018 (Final Report) for the Former Marcus Hook Pump Station (MHPS). In that letter, the PADEP granted IEC an Act 2 release of liability for No. 2 and No. 6 fuel oils in soils at the Former MHPS, as set forth under Act 2.

However, the PADEP letter also stated “Information provided in the Final Report indicates groundwater was encountered in multiple excavations where contaminated soil was removed. The potential for groundwater contamination may violate environmental laws that DEP administers, including, but not limited to, the Clean Streams Law, and may constitute a public nuisance. DEP requests that you [IEC] enter Act 2, characterize, and demonstrate attainment of a cleanup standard for groundwater.”

We have carefully considered the Department’s request in light of the data collected during the soil remediation and provided in the Final Report and AGC/Montrose’s extensive knowledge of the site from its 25-year history of providing environmental consulting services for IEC’s MHPS. As outlined below, there is no indication that groundwater is impacted above the PADEP groundwater Statewide Health Standards (SHSs) at the MHPS. As such, we do not believe that further groundwater investigation is warranted.

Final Report: Groundwater Information

The underground piping and foundation demolition project along with the associated soil excavation occurred from July to September 2018, a period in which there was extensive rainfall at the site. As a result, stormwater had to be pumped from all excavations with soil impacts into frac tanks for off-site treatment/disposal. After completing the removal of impacted soils and

1055 Andrew Drive T: 610.840.9100 G:\Projects\2018\20183756 - Marcus Hook Pump Station E&S\Sec Suite A F: 610.840.9199 Files\Correspondence\2019- Response to PADEP Soil Apporival\Final -Response to West Chester, PA 19380 AdvancedGeoServices.com DEP Act 2 Soil Approval -1-31-19.docx Offices Nationwide Montrose-Env.com

Mr. Ragesh R. Patel 2018-3756 January 31, 2019 Page 2 of 4 stormwater in each area, only Sites 2 and 5 still had water in the excavations. This was assumed to be groundwater infiltrating into the excavations; therefore, samples of the groundwater were collected from these sites. Specifically, four groundwater samples were collected: three from Site 2 (subareas 2A, 2B and 2C) and one from Site 5. As shown in Table 1, all the groundwater results were below the Act 2 SHSs for No. 2 and No. 6 fuel oil criteria pursuant to the PA Act 2 Short List of Petroleum Products for groundwater in a non-residential, used-aquifer setting. This groundwater analytical data from Sites 2 and 5 indicates that the groundwater within the area of the excavations was not impacted.

Final Report: Temporary Piezometers

To further support that the groundwater beneath the excavation areas was not impacted, temporary piezometers were installed within 25 feet of the edges of the excavation at Site 2. On July 24, 2018, AGC/Montrose installed five temporary piezometers (TW-1 through TW-5) around Site 2, subarea 2A to determine impact to groundwater in the excavation area. Five soil samples were collected from the boring at a depth just above the water level for each piezometer, as summarized below.

MHPS Temporary Piezometers, Date: 7/24/18 Total Depth GW Depth Soil Sample Sample Depth Name (ft. bgs) (ft. bgs) Collected (ft. bgs) TW-1 8 (5.5) 4 TW-1 3.5 TW-2 10.5 8 TW-2 7.5 TW-3 11 7 TW-3 6.5 TW-4 12 7 TW-4 6.5 TW-5 10.5 6 TW-5 5.5

Note: TW-1 originally 8 ft. Boring collapsed to 5.5 ft.

The soil samples were analyzed for No. 2 and No. 6 fuel oil constituents, pursuant to the PA Act 2 Short List of Petroleum Products (PADEP Table IV-9). These soil sample results were all below the Act 2 SHSs for No. 2 and No. 6 fuel oil criteria pursuant to the PA Act 2 Short List of Petroleum Products for soil in a non-residential, used-aquifer setting (See Table 2). These results indicate that oil would not be expected on the groundwater table.

On July 25, 2018, one day after the piezometers were installed, AGC/Montrose utilized a dual- phase water oil interface probe to evaluate the presence of potential product (oil) levels and thickness in the five piezometers. Product was not identified in any of the five piezometers. The piezometer soil analytical data and the absence of product in the five piezometers indicates that there were no oil releases impacting groundwater near Area 2. This evaluation supports the lack of evidence that the limited soil impacts in these excavations had impacted groundwater.

Historical Property Information Not Presented in the Final Report

As previously discussed, AGC/Montrose has been providing environmental consulting services to IEC at the Property for over 25 years. AGC/Montrose is providing the following historical

G:\Projects\2018\20183756 - Marcus Hook Pump Station E&S\Sec Files\Correspondence\2019- Response to PADEP Soil Apporival\Final -Response to DEP Act 2 Soil Approval -1-31-19.docx Mr. Ragesh R. Patel 2018-3756 January 31, 2019 Page 3 of 4 information that supports AGC/Montrose’s and IEC’s position that there is not sufficient evidence of groundwater contamination to warrant an additional groundwater investigation at the Property.

In response to a release of oil at the property, Gulf Interstate Pipeline, the previous owner of the Property, conducted a Limited Environmental Assessment at the Property in 1989 that included the installation of five groundwater monitoring wells. The Limited Environmental Assessment Report concluded the following:

 the water table on the property is very shallow,  groundwater flows in a southwesterly direction,  the soil has low permeability (clay-like) based on a low water yield on the monitoring wells, and  there was no detectable groundwater contamination present on the property based on the groundwater sample analyses.

The Limited Environmental Assessment Report dated June 1989 is presented as Attachment A. Groundwater surface elevations developed from the five wells on May 19, 2000 is presented as Attachment B.

Shortly after IEC began operating the Property, IEC voluntarily sampled the five on-site monitoring wells, and a total of 14 groundwater sampling events were conducted from March 1992 through July 2003. The groundwater analyses included benzene, toluene, ethylbenzene, xylene (BTEX), and total petroleum hydrocarbons. Select groundwater sampling events included analyses of semi-volatile organic compounds and MTBE. All results from the sampling performed throughout this period were below laboratory detection limits. Groundwater sampling results are tabulated and summarized in Attachment C.

Because oil was stored and transferred at MHPS, IEC had maintained and followed a Spill Prevention and Response Plan. A copy of the plan, dated April 13, 1993, Revised October 2014, and certified by a Pennsylvania Professional Engineer, Tom Legel of AGC/Montrose is provided as Attachment D. The Plan required that IEC conduct observations and monitoring activities that included:

 an inspection of the T-1 above ground storage tank at least every 72 hours when the tank was in service,  weekly facility inspections to identify signs of leaks from terminal components,  annual storm water discharge inspections, and  monthly maintenance operations inspections for above ground storage tanks.

Section 2.4 of the plan states “There have been no releases to land or water of SARA Title III Section 313 water priority chemicals by this facility at any time during the past ten years [2004 through 2014].” Based on a review of other historical information the last documented oil release was in 1993.

The MHPS ceased oil transport operations shortly thereafter in December 2014 and all oils were removed from onsite storage tanks. In 2016 all oils were removed from piping at the property. AGC/Montrose, on behalf of IEC, decommissioned four of the five Site monitoring wells in May 2015. Information regarding the May 2015 well decommissioning is presented in Attachment E, which did not indicate any groundwater impacts in the four wells during the decommissioning activities. The fifth monitoring well, MW-1, was previously decommissioned in 1995.

This historical information shows that there is no evidence of groundwater contamination at the MHPS based the absence of known oil releases after 1993 and on groundwater monitoring conducted up to 2003 after that last known release to soil.

Conclusions

While we did encounter localized shallow soil impacts in certain areas during the demolition activities and 2 of the excavation areas did apparently encounter groundwater, the impacts were limited to the soils. Based on the information provided above, including ten years of groundwater monitoring following the last known oil release, and the data in the Final Report, we do not see evidence of groundwater contamination. Therefore, we are not inclined to enter the voluntary Act 2 program for groundwater. If you have additional information or data, please let us know.

If you have any questions regarding this matter, please contact Mr. Bernard Beegle by e-mail at [email protected] or by telephone at 610-639-2783.

Sincerely,

Advanced GeoServices Corp., a Montrose Environmental Group company

Bernard Beegle, PG. CPG Senior Project Geologist

Christopher T. Reitman, P.E. Senior Project Consultant

BBB:CTR:kk cc: Mr. Brown - PADEP Mr. de la Rosa - PADEP Ms. Bass - PADEP Lower Chichester Township Mr. Rounds – Interstate Energy Company Mr. Shamory -Talen Energy Mr. O’Rourke – Advanced GeoServices Mr. Reitman - Advanced GeoServices

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TABLES

Sample Location S-2-W2A S-2-W2B S-2-W2C S-5-Water Lab ID Pennsylvania Medium 460-161686-17 460-161686-18 460-162112-09 460-163372-09 Specific-Concentrations Sample Date 7/31/2018 7/31/2018 8/7/2018 8/27/2018 (MSCs) NonResidential Used Matrix Aquifers TDS <2500 Groundwater Groundwater Groundwater Groundwater Remarks Parameter ug/L Units Result Q MDL Result Q MDL Result Q MDL Result Q MDL Volatiles 1,2,4-Trimethylbenzene 62 ug/L 1.9 0.37 0.57 J 0.37 U 0.37 7.3 0.37 1,3,5-Trimethylbenzene 1,200 ug/L 0.52 J 0.33 U 0.33 U 0.33 2 0.33 Benzene 5 ug/L U 0.43 U 0.43 U 0.43 1.6 0.43 Ethylbenzene 700 ug/L U 0.3 U 0.3 U 0.3 1.5 0.3 Isopropylbenzene 3,500 ug/L 0.37 J 0.34 U 0.34 U 0.34 0.43 J 0.34 MTBE 20 ug/L U 0.47 U 0.47 U 0.47 U 0.47 Naphthalene 100 ug/L 1.1 0.41 3.2 0.41 U 0.41 6.6 0.41 Toluene 1,000 ug/L U 0.38 U 0.38 U 0.38 5.2 0.38 Semivolatiles Chrysene 2 ug/L NA NA U 0.91 U 0.91 Phenanthrene 1,100 ug/L NA NA 0.91 J 0.58 1.8 J 0.58 Pyrene 130 ug/L NA NA U 1.6 U 1.6

NA - Not Analyzed Applicable PA Act 2 Groundwater standards are shown in black ug/L: All concentrations reported in micrograms per liter (parts per billion) MSC: Medium-Specific Concentration TDS: Total Dissolved Solids J: Result is less than the RL but greater than or equal to the MDL and the concentration is an approximate value. U: Not detected above the Method Detection Limit (MDL) = Applicable Non-Residential Statewide Health Standard = Concentration exceeds Non-Residential Statewide Health Standard

G:\Projects\2018\20183756 - Marcus Hook Pump Station E&S\Work Documents\2018 Fuel Oil #6 PA Act 2 Cleanup\Report Tables\Final Tables TABLE 2 SITE 2 - TRANSFER PUMP SITE - PIEZOMETER SOIL SAMPLES Former Marcus Hook Pump Station Marcus Hook, Pennsylvania

Sample Location Pennsylvania Medium Specific-Concentrations (MSCs) TW-1 TW-2 TW-3 TW-4 TW-5 Direct Contact Soil to Groundwater Numeric Values Lab ID Numeric Values Used Aquifers TDS<2500 460-161139-01 460-161139-02 460-161139-03 460-161139-04 460-161139-05 Sample Date Non-Residential Non-Residential 7/24/2018 7/24/2018 7/24/2018 7/24/2018 7/24/2018 Matrix 2-15 feet 100X Generic Soil Soil Soil Soil Soil Remarks GW MSC Value Parameter mg/kg mg/kg mg/kg Units Result Q MDL Result Q MDL Result Q MDL Result Q MDL Result Q MDL Volatiles 1,2,4-Trimethylbenzene 640 6.2 35 mg/kg U 0.000095 0.00019 J 0.000091 0.00078 0.000071 U 0.000066 0.00034 J 0.000091 1,3,5-Trimethylbenzene 10,000 120 210 mg/kg U 0.00012 U 0.00011 0.00035 J 0.000087 U 0.000081 0.00014 J 0.00011 Benzene 330 0.5 0.13 mg/kg U 0.00026 U 0.00025 U 0.00019 U 0.00018 U 0.00025 Ethylbenzene 1,000 70 46 mg/kg U 0.0002 0.0019 0.00019 0.0044 0.00015 U 0.00014 0.0031 0.00019 Isopropylbenzene 10,000 350 2,500 mg/kg U 0.00013 U 0.00012 0.00017 J 0.000095 U 0.000088 0.00014 J 0.00012 MTBE 9,900 2 0.28 mg/kg U 0.00013 U 0.00012 U 0.000094 U 0.000088 U 0.00012 Naphthalene 190,000 10 25 mg/kg U 0.00019 U 0.00018 0.00094 0.00014 U 0.00013 0.00021 J 0.00018 Toluene 10,000 100 44 mg/kg U 0.00063 U 0.0006 U 0.00047 U 0.00044 U 0.00061 Conventionals Percent Moisture - - - % 19.9 1 20.5 1 19.3 1 18.5 1 18.3 1 Percent Solids - - - % 80.1 1 79.5 1 80.7 1 81.5 1 81.7 1

Applicable PA Act 2 Soil-to-Groundwater standards are shown in black; standards that do not apply are shown in gray text mg/kg: All concentrations reported in milligrams per kilogram (parts per million) U: Not detected above the Method Detection Limit (MDL) MSC: Medium-Specific Concentration = Applicable Non-Residential Statewide Health Standard TDS: Total Dissolved Solids = Concentration exceeds Non-Residential Statewide Health Standard NA: Not analyzed J: Result is less than the RL but greater than or equal to the MDL and the concentration is an approximate value.

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ATTACHMENT A

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ATTACHMENT B

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ATTACHMENT C

Sample Location MW-1 Sample Date 3/3/1992 5/7/1993 11/4/1993 6/2/1994 1/26/1995 8/16/1995 Parameter Units Result Result Result Result Result Result Volatiles Benzene ug/l NA ND ND ND ND ND Toluene ug/l NA ND ND ND ND ND Ethylbenzene ug/l NA ND ND ND ND ND o-Xylene ug/l NA ND ND ND ND ND m-Xylene ug/l NA ND ND ND ND ND p-Xylene ug/l NA ND ND ND ND ND Total Petroleum Hydrocarbon ug/l ND ND ND ND 800 ND

Notes: ND - Not detected above the limit of quantitation. NA - Not Analyzed ug/l - microgram per liter MW-1 was closed and abandoned following the 8/16/95 sampling event.

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Sample Location MW-2 Sample Date 3/3/1992 5/7/1993 11/4/1993 6/2/1994 1/26/1995 8/16/1995 2/20/1996 8/20/1996 2/13/1997 6/23/1999 5/19/2000 6/28/2001 6/24/2002 7/3/2003 Parameter Units Result Result Result Result Result Result Result Result Result Result Result Result Result Result Volatiles Benzene ug/l NA ND ND ND ND ND ND ND ND ND ND ND ND ND Toluene ug/l NA ND ND ND ND ND ND ND ND ND ND ND ND ND Ethylbenzene ug/l NA ND ND ND ND ND ND ND ND ND ND ND ND ND Isopropylbenzene ug/l NA NA NA NA NA NA NA NA NA ND ND ND ND ND MTBE ug/l NA NA NA NA NA NA NA NA NA NA NA ND ND ND o-Xylene ug/l NA ND ND ND ND ND ND NA NA NA NA NA NA NA m-Xylene ug/l NA ND ND ND ND ND ND NA NA NA NA NA NA NA p-Xylene ug/l NA ND ND ND ND ND ND NA NA NA NA NA NA NA Total Xylenes ug/l NA NA NA NA NA NA NA ND ND NA NA ND ND ND Naphthalene ug/l NA NA NA NA NA NA NA NA NA ND ND ND ND ND Total Petroleum Hydrocarbon Total Petroleum Hydrocarbon ug/l ND ND ND ND 300 ND ND 500 ND NA NA NA NA NA Semivolatiles Acenaphthene ug/l NA NA NA NA NA NA NA NA NA NA NA NA ND NA Acenaphthylene ug/l NA NA NA NA NA NA NA NA NA NA NA NA ND NA Anthracene ug/l NA NA NA NA NA NA NA NA NA ND NA NA ND NA Benzo(a)anthracene ug/l NA NA NA NA NA NA NA NA NA ND NA ND ND ND Benzo(a)pyrene ug/l NA NA NA NA NA NA NA NA NA ND NA ND ND ND Benzo(b)fluoranthene ug/l NA NA NA NA NA NA NA NA NA ND NA ND ND ND Benzo(g,h,i)perylene ug/l NA NA NA NA NA NA NA NA NA ND NA ND ND ND Benzo(k)fluoranthene ug/l NA NA NA NA NA NA NA NA NA NA NA NA ND NA Chrysene ug/l NA NA NA NA NA NA NA NA NA ND ND ND ND ND Dibenz(a,h)anthracene ug/l NA NA NA NA NA NA NA NA NA NA NA NA ND NA Fluoranthene ug/l NA NA NA NA NA NA NA NA NA NA NA NA ND NA Fluorene ug/l NA NA NA NA NA NA NA NA NA ND ND NA ND NA Indeno(1,2,3-cd)pyrene ug/l NA NA NA NA NA NA NA NA NA NA NA ND ND ND Naphthalene ug/l NA NA NA NA NA NA NA NA NA NA NA NA ND NA Phenanthrene ug/l NA NA NA NA NA NA NA NA NA ND ND NA ND NA Pyrene ug/l NA NA NA NA NA NA NA NA NA ND ND ND ND ND

Notes: ND - Not detected above the limit of quantitation. NA - Not Analyzed ug/l - microgram per liter

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Sample Location MW-3 Sample Date 3/3/1992 5/7/1993 11/4/1993 6/2/1994 1/26/1995 8/16/1995 2/20/1996 8/20/1996 2/13/1997 6/23/1999 5/19/2000 Parameter Units Result Result Result Result Result Result Result Result Result Result Result Volatiles Benzene ug/l NA ND ND ND ND ND ND ND ND ND ND Toluene ug/l NA ND ND ND ND ND ND ND ND ND ND Ethylbenzene ug/l NA ND ND ND ND ND ND ND ND ND ND Isopropylbenzene ug/l NA NA NA NA NA NA NA NA NA ND ND MTBE ug/l NA NA NA NA NA NA NA NA NA NA NA o-Xylene ug/l NA ND ND ND ND ND ND ND NA NA NA m-Xylene ug/l NA ND ND ND ND ND ND ND NA NA NA p-Xylene ug/l NA ND ND ND ND ND ND ND NA NA NA Total Xylenes ug/l NA NA NA NA NA NA NA NA ND NA NA Naphthalene ug/l NA NA NA NA NA NA NA NA NA ND ND Total Petroleum Hydrocarbon Total Petroleum Hydrocarbon ug/l ND ND ND ND 300 ND ND ND ND NA NA Semivolatiles Acenaphthene ug/l NA NA NA NA NA NA NA NA NA NA NA Acenaphthylene ug/l NA NA NA NA NA NA NA NA NA NA NA Anthracene ug/l NA NA NA NA NA NA NA NA NA ND NA Benzo(a)anthracene ug/l NA NA NA NA NA NA NA NA NA ND NA Benzo(a)pyrene ug/l NA NA NA NA NA NA NA NA NA ND NA Benzo(b)fluoranthene ug/l NA NA NA NA NA NA NA NA NA ND NA Benzo(g,h,i)perylene ug/l NA NA NA NA NA NA NA NA NA ND NA Benzo(k)fluoranthene ug/l NA NA NA NA NA NA NA NA NA NA NA Chrysene ug/l NA NA NA NA NA NA NA NA NA ND ND Dibenz(a,h)anthracene ug/l NA NA NA NA NA NA NA NA NA NA NA Fluoranthene ug/l NA NA NA NA NA NA NA NA NA NA NA Fluorene ug/l NA NA NA NA NA NA NA NA NA ND ND Indeno(1,2,3-cd)pyrene ug/l NA NA NA NA NA NA NA NA NA NA NA Naphthalene ug/l NA NA NA NA NA NA NA NA NA NA NA Phenanthrene ug/l NA NA NA NA NA NA NA NA NA ND ND Pyrene ug/l NA NA NA NA NA NA NA NA NA ND ND

Notes: ND - Not detected above the limit of quantitation. NA - Not Analyzed ug/l - microgram per liter

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Sample Location MW-4 Sample Date 3/3/1992 5/7/1993 11/4/1993 6/2/1994 1/26/1995 8/16/1995 2/20/1996 8/20/1996 2/13/1997 6/23/1999 5/19/2000 Parameter Units Result Result Result Result Result Result Result Result Result Result Result Volatiles Benzene ug/l NA ND ND ND ND ND ND ND ND ND ND Toluene ug/l NA ND ND ND ND ND ND ND ND ND ND Ethylbenzene ug/l NA ND ND ND ND ND ND ND ND ND ND Isopropylbenzene ug/l NA NA NA NA NA NA NA NA NA ND ND MTBE ug/l NA NA NA NA NA NA NA NA NA NA NA o-Xylene ug/l NA ND ND ND ND ND ND ND NA NA NA m-Xylene ug/l NA ND ND ND ND ND ND ND NA NA NA p-Xylene ug/l NA ND ND ND ND ND ND ND NA NA NA Total Xylenes ug/l NA NA NA NA NA NA NA NA ND NA NA Naphthalene ug/l NA NA NA NA NA NA NA NA NA ND ND Total Petroleum Hydrocarbons Total Petroleum Hydrocarbons ug/l ND ND ND ND 600 ND 400 600 ND NA NA Semivolatiles Acenaphthene ug/l NA NA NA NA NA NA NA NA NA NA NA Acenaphthylene ug/l NA NA NA NA NA NA NA NA NA NA NA Anthracene ug/l NA NA NA NA NA NA NA NA NA ND NA Benzo(a)anthracene ug/l NA NA NA NA NA NA NA NA NA ND NA Benzo(a)pyrene ug/l NA NA NA NA NA NA NA NA NA ND NA Benzo(b)fluoranthene ug/l NA NA NA NA NA NA NA NA NA ND NA Benzo(g,h,i)perylene ug/l NA NA NA NA NA NA NA NA NA ND NA Benzo(k)fluoranthene ug/l NA NA NA NA NA NA NA NA NA NA NA Chrysene ug/l NA NA NA NA NA NA NA NA NA ND ND Dibenz(a,h)anthracene ug/l NA NA NA NA NA NA NA NA NA NA NA Fluoranthene ug/l NA NA NA NA NA NA NA NA NA NA NA Fluorene ug/l NA NA NA NA NA NA NA NA NA ND ND Indeno(1,2,3-cd)pyrene ug/l NA NA NA NA NA NA NA NA NA NA NA Naphthalene ug/l NA NA NA NA NA NA NA NA NA NA NA Phenanthrene ug/l NA NA NA NA NA NA NA NA NA ND ND Pyrene ug/l NA NA NA NA NA NA NA NA NA ND ND

Notes: ND - Not detected above the limit of quantitation. NA - Not Analyzed ug/l - microgram per liter

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Sample Location MW-5 Sample Date 3/3/1992 5/7/1993 11/4/1993 6/2/1994 1/26/1995 8/16/1995 2/20/1996 8/20/1996 2/13/1997 6/23/1999 5/19/2000 6/28/2001 6/24/2002 7/3/2003 Parameter Units Result Result Result Result Result Result Result Result Result Result Result Result Result Result Volatiles Benzene ug/l NA ND ND ND ND ND ND ND ND ND ND ND ND ND Toluene ug/l NA ND ND ND ND ND ND ND ND ND ND ND ND ND Ethylbenzene ug/l NA ND ND ND ND ND ND ND ND ND ND ND ND ND Isopropylbenzene ug/l NA NA NA NA NA NA NA NA NA ND ND ND ND ND MTBE ug/l NA NA NA NA NA NA NA NA NA NA NA ND ND ND o-Xylene ug/l NA ND ND ND ND ND ND ND NA NA NA NA NA NA m-Xylene ug/l NA ND ND ND ND ND ND ND NA NA NA NA NA NA p-Xylene ug/l NA ND ND ND ND ND ND ND NA NA NA NA NA NA Total Xylenes ug/l NA NA NA NA NA NA NA NA ND NA NA ND ND ND Naphthalene ug/l NA NA NA NA NA NA NA NA NA ND ND ND ND ND Total Petroleum Hydrocarbon Total Petroleum Hydrocarbon ug/l ND 300 ND ND 300 ND ND ND ND NA NA NA NA NA Semivolatiles Acenaphthene ug/l NA NA NA NA NA NA NA NA NA NA NA NA ND NA Acenaphthylene ug/l NA NA NA NA NA NA NA NA NA NA NA NA ND NA Anthracene ug/l NA NA NA NA NA NA NA NA NA ND NA NA ND NA Benzo(a)anthracene ug/l NA NA NA NA NA NA NA NA NA ND NA ND ND ND Benzo(a)pyrene ug/l NA NA NA NA NA NA NA NA NA ND NA ND ND ND Benzo(b)fluoranthene ug/l NA NA NA NA NA NA NA NA NA ND NA ND ND ND Benzo(g,h,i)perylene ug/l NA NA NA NA NA NA NA NA NA ND NA ND ND ND Benzo(k)fluoranthene ug/l NA NA NA NA NA NA NA NA NA NA NA NA ND NA Chrysene ug/l NA NA NA NA NA NA NA NA NA ND ND ND ND ND Dibenz(a,h)anthracene ug/l NA NA NA NA NA NA NA NA NA NA NA NA ND NA Fluoranthene ug/l NA NA NA NA NA NA NA NA NA NA NA NA ND NA Fluorene ug/l NA NA NA NA NA NA NA NA NA ND ND NA ND NA Indeno(1,2,3-cd)pyrene ug/l NA NA NA NA NA NA NA NA NA NA NA ND ND ND Naphthalene ug/l NA NA NA NA NA NA NA NA NA NA NA NA ND NA Phenanthrene ug/l NA NA NA NA NA NA NA NA NA ND ND NA ND NA Pyrene ug/l NA NA NA NA NA NA NA NA NA ND ND ND ND ND

Notes: ND - Not detected above the limit of quantitation. NA - Not Analyzed ug/l - microgram per liter

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ATTACHMENT D

1111 West Ridge Road Marcus Hook, PA 19061 Lower Chichester Township, Delaware County Facility ID: 23-40759

The following plan was prepared by:

ADVANCED GEOSERVICES CORP. 1055 Andrew Drive, Suite A West Chester, PA 19380-4293

April 13, 1993 (REVISED October 2014) Project No. 92-054-03

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A RECORD OF CHANGES MADE TO PLAN

DATE OF CHANGE CHANGE MADE TO NATURE OF CHANGE CHANGE PAGE AUTHORIZED BY

1. 3/23/94 Various Annual Notification List Update D. Cummings

2. 3/21/97 Various Revise for NPDES Permit # PAR900007 D. Cummings

3. 10/13/97 Various Revise Titles & Phone Numbers D. Cummings

4. 10/97 to 2008 Removed from Requirements D. Cummings

5. 5/1/2009 Various Complete Update D. Cummings

6. 4/7/2010 Various Update Appendixes D. Cummings

7. 3/22/2012 Various Revise Titles & Phone Numbers C. Rounds

8. 5/3/2012 Various Updated MSDS (Appendix A) C. Rounds

9. 9/12/2012 Various Revise Contractor list C. Rounds

10. 12/16/13 Various Revise Manager Name C. Rounds

11. 10/07/2014 Various Added PE, Mgm’t & Substantial Harm C. Rounds Certifications

12.

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TABLE OF CONTENTS PAGE NO. 1.0 Introduction ...... 1

1.1 Applicability of Substantial Harm Criteria ...... 1 1.2 Engineers Certification ...... 3 1.3 Management Approval ...... 4 1.4 Facility Address and Owners/Operators ...... 5 1.5 Scope ...... 5

2.0 Description of Facility ...... 7

2.1 Description of Industrial Activity ...... 7

2.1.1 Facility Drainage ...... 7 2.1.2 Tankage ...... 8 2.1.3 Piping ...... 9 2.1.4 Storm Water Treatment ...... 10 2.1.5 Transformer Station ...... 11 2.1.6 Detailed Drawings ...... 11

2.2 Description of Related Emergency Response Plans ...... 11 2.3 Material and Waste Inventory ...... 12

2.3.1 Fuel Oil ...... 12 2.3.2 Therminol ...... 13 2.3.3 Cleaning Solvent ...... 13

2.4 Pollution Incident History ...... 13 2.5 Implementation Schedule For Plan Elements Not Currently In Place ...... 13

3.0 Description of How Plan Is Implemented By Organization ...... 14

3.1 Organizational Structure of Facility For Implementation ...... 14

3.1.1 Plan Development and Maintenance ...... 14 3.1.2 Plan Implementation ...... 15

3.2 List of Emergency Coordinators ...... 15 3.3 Duties and Responsibilities of Coordinators ...... 17

3.3.1 Emergency Coordinator ...... 17 3.3.2 Spill Operations Supervisor ...... 17 3.3.3 Public Relations ...... 18 3.3.4 Environmental Site Coordinator Responsibilities ...... 18

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i TABLE OF CONTENTS PAGE NO. 3.4 Chain of Command ...... 19

4.0 Spill Leak Prevention and Response...... 20

4.1 Pre-Release Planning ...... 20

4.1.1 Pipeline ...... 20 4.1.2 Tank T-1...... 21 4.1.3 Tank V-3 ...... 21 4.1.4 Tank V-4 ...... 21 4.1.5 Booster Pumps, Metering Area and Heater Area ...... 21 4.1.6 Main Pumps ...... 22 4.1.7 Transformer Station ...... 22

4.2 Material Compatibility ...... 22 4.3 Inspections and Monitoring Program ...... 22

4.3.1 Visual Inspections ...... 23 4.3.2 Cathodic Protection Inspection ...... 24 4.3.3 Storm Water Discharge Inspection ...... 24

4.4 Preventative Maintenance ...... 25 4.5 Housekeeping ...... 26 4.6 Erosion and Sedimentation Control ...... 26 4.7 Security ...... 26 4.8 External Factor Planning ...... 27 4.9 Training ...... 27

5.0 Countermeasures ...... 29

5.1 Countermeasures To Be Undertaken By Facility ...... 29

5.1.1 Automated Response ...... 29 5.1.2 Internal Alert ...... 29 5.1.3 Contingency and Response Team ...... 29 5.1.4 Initial Response ...... 30 5.1.5 Containment ...... 30 5.1.6 Repair ...... 30 5.1.7 Cleanup and Disposal ...... 31

5.2 Countermeasures To Be Undertaken By Contractors ...... 31

5.2.1 Approved Response Contractors...... 32

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ii TABLE OF CONTENTS PAGE NO. 5.3 Internal and External Communications and Alarm Systems ...... 33 5.4 Evacuation Plan For Installation Personnel ...... 33

5.5 Emergency Equipment ...... 34

6.0 Emergency Spill Control Network...... 35

6.1 Arrangements With Local Authorities ...... 35 6.2 External Notifications ...... 35

6.2.1 Federal Notifications ...... 35 6.2.2 State and Local Notifications ...... 38

6.3 Downstream Water Users On The Delaware River ...... 43

LIST OF TABLES TABLE PAGE NO. 3.1 In-House Contingency and Response Team ...... 16

LIST OF FIGURES

FIGURE FOLLOWING PAGE NO. 2.1 Location Plan ...... 7 2.2 Facility Drainage ...... 8 2.3 Facility Tank Locations ...... 9

LIST OF APPENDICES

APPENDIX A MSDS Sheet B Leak Detection Checklist C Storm Water Discharge Inspection Report D T-1 Above Ground Storage Tank Visual Inspection Form E Weekly T-1 Tank Inspection Form F Monthly Maintenance Operation Checklist for Aboveground Storage Tanks

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iii 1.0 INTRODUCTION

1.1 APPLICABILITY OF SUBSTANTIAL HARM CRITERIA

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 NO

Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and, within any storage area, 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?

Yes No NO

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 (as calculated using the appropriate formula (Appendix C, Federal Register, Vol. 59, No. 126, July 1, 1994) or a comparable formula such that a discharge from the facility would cause injury to fish and wildlife and sensitive environments?

Yes No NO

Does the facility have a total storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the appropriate formula (Appendix C, Federal Register, Vol. 59, No. 126, July 1, 1994) or a comparable formula such that a discharge from the facility would shut down a public drinking water intake?

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1 Yes No NO

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 spill in an amount greater than or equal to 10,000 gallons within the last 5 years?

Yes No NO

CERTIFICATION

I certify under penalty of law that I have personally examined and am familiar with the information submitted in this declaration, and that based on my inquiry of those individuals responsible for obtaining information, I believe that the submitted information is true, accurate, and complete.

Signature Name (Please type or print) Title Date

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1.3 MANAGEMENT APPROVAL

This Spill Response Plan has been carefully reviewed by PPL Interstate Energy Company management. Management concurs and supports the programs and procedures which are to be implemented and periodically reviewed and updated in accordance with The Pennsylvania Storage Tank and Spill Prevention Act (Act 32 – 1989). Management approval has been extended at a level with authority to commit the necessary resources, including manpower, equipment and materials required to expeditiously control and remove any quantity of oil discharge that may be harmful. Management Approval Signature: Date: Name: Drew D. Cummings Title: General Manager

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4 1.4 FACILITY ADDRESS AND OWNERS/OPERATORS

PPL Interstate Energy Company (PPLIEC) operates a pipeline pumping station for PPL. This facility, Marcus Hook Pump Station, is located on 1111 West Ridge Road, in Marcus Hook, Lower Chichester Township, Delaware County, Pennsylvania. The facility address, owner and operator information are as follows:

Facility Name/Address

Marcus Hook Pump Station Facility ID: 23-40759 1111 West Ridge Road County: Delaware Linwood, PA 19061 Capacity: 173,102 gallons

Facility Owner

PPL Interstate Energy Company 214 Shoemaker Road Pottstown, PA 19464

Facility Operator

PPL Interstate Energy Company 214 Shoemaker Road Pottstown, PA 19464

1.5 SCOPE

A fuel oil/hazardous substance spill or discharge at Marcus Hook Pump Station requires the immediate coordination of efforts of PPLIEC employees and the assistance of outside agencies and contractors.

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5 This Spill Prevention Response Plan is designed to aid PPLIEC personnel in responding quickly and effectively to the problems presented by accidental spills. Its primary goal is to limit damage from spills or discharges, and at the same time assure the safety of all employees and members of the public who may be affected. To this end, this Spill Prevention Response Plan identifies types of spills/discharges which are reportable, who is responsible for reporting and to whom the report is made; as well as preventive measures utilized to avoid spills, and corrective action for isolating, containing, and cleaning up a spill or discharge. Regulations affecting this document include:

1. NFPA 30 Flammable & Combustible Liquids Code 2. PA Code, Title 25, Chapter 101 - Pennsylvania Water Resources Regulations 3. Act 32 The Storage Tank and Spill Prevention Act 4. PA Code, Title 25, Chapters 91-97 - Surface Water Quality 5. PA Code, Title 25, Chapter 102 - Sedimentation and Erosion Control 6. PA Code, Title 25, Chapter 105 - Dams and Waterways

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6 2.0 DESCRIPTION OF FACILITY

2.1 DESCRIPTION OF INDUSTRIAL ACTIVITY

The Marcus Hook Pump Station is a petroleum pumping station located on the PPLIEC hot oil pipeline. The pipeline transports No. 2 fuel oil and residual oils to the Martins Creek electric power generating station. The PPLIEC pipeline spans 84 miles in length originating at the Marcus Hook Pump Station and terminating at Martins Creek Terminal near Martins Creek, Pennsylvania. The Marcus Hook Pump Station is located approximately 1 mile from the Delaware River. A portion of a USGS map showing the location of the Marcus Pump Station is shown on Figure 2.1.

At the Marcus Hook Pump Station, product is stored at the adjacent Sun Refinery Tank Farm, and transferred via pipeline to the pump station. Residual fuel oil entering the Marcus Hook Pump Station from the Sun Refinery Tank Farm is directed to booster pumps. The booster pumps are used to increase the suction pressure of the oil at the mainline pumps. As the oil leaves the booster pumps, it passes through a metering system. From this point, the oil is sent to either the mainline pumps or to the direct-fired heaters, depending on the oil's viscosity. If required, the product is heated to 150F before entering the mainline pumps. The mainline pumps discharge the oil through a pressure control valve to the main pipeline.

The facility also has the ability to provide heat to the Sun Refinery Tank Farm. This heat is provided through a closed-loop heat exchange system. A heat transfer fluid (Therminol 55) is pumped through a direct-fired heater, and circulated through the residual oil tanks heat exchangers in the Sun Refinery Tank Farm.

2.1.1 Facility Drainage

The closest river/stream to the Marcus Hook Pump station is Naamans Creek which flows approximately 1/2 mile to the southeast of the facility. This creek receives the storm water runoff from the Marcus Hook Pump Station.

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Offsite surface water runoff which flows onto the property is separated (diverted) from onsite surface water runoff in order to minimize the volume of water that can be impacted by facility elements and activities. The offsite runoff is collected at the property line and conveyed through the facility by a system of culverts and drainage channels and released downstream of the facility’s secondary containment berm.

Onsite runoff is collected within one (1) of three (3) primary containment areas and then conveyed through culverts and channels to the secondary containment area. Both the primary and secondary containment is achieved with berms and remotely operated sluice gates. Storm water collected in the secondary containment area discharges offsite through two culverts located at the southwest corner of the facility. A Sick Sleuth oil spill detection monitor and alarm system is located within the secondary containment area. Upon the detection of oil, this monitor will automatically close all the sluice gates at the facility.

From the Marcus Hook Pump Station, both the onsite and diverted offsite surface water runoff flows into an existing drainage channel, located in Delaware, and flows southwestward along a railroad siding for approximately 1,100 feet. The flow then continues southward entering a series of storm culverts which extend approximately 1,300 feet under railroad tracks, an abandoned parking lot, a railroad mainline, Route 13 (Philadelphia Pike), and the parking lot of BOC Gases. Runoff then enters Naamans Creek, also in Delaware, and flows to the Delaware River approximately 1/2 mile downstream. Facility drainage features are shown on Figure 2.2.

2.1.2 Tankage

Onsite tankage at the Marcus Hook Pump Station consists of three above ground storage tanks as described below:

 Tank T-1 is the No. 2 fuel oil tank, a welded steel tank with a 168,000-gallon capacity. This tank is temporarily out of service.

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 Tank V-4 is the slop oil holding tank, a welded steel tank with a 2,540-gallon capacity.

 Tank V-3 is the heat transfer fluid (Therminol 55) holding tank mounted approximately 10' above ground surface, a welded steel tank with 2,562-gallon capacity.

Tanks T-1, V-3, and V-4 were constructed and hydrostatically tested in accordance with API and ASME specifications, as appropriate, at the time of installation. Facility tank locations are shown on Figure 2.3.

Tank T-1 is resting on compacted soil in a diked area consisting of an earthen berm 6'3" in height 62' long and 50' wide, with sides sloped at 1:1. The tank bottom is included in the cathodic protection system (See Section 4.2). The containment dike and base are lined with 12 inches of compacted, select clayey soils and covered by 3 inches of crushed rock. The diked area has the capacity to contain the entire volume of the tank, plus six inches of accumulated rain water. This tank is equipped with a remote gauge which is monitored through PPLIEC’s SCADA System.

Tank V-3 is equipped with a high and low level alarm that annunciates in the control building. This vessel is insulated, banded in aluminum casing, and, generally filled to a volume 1/3 its capacity for normal operations. A concrete pad area 9' x 25' x 4” is constructed under the tank, with a drain that flows to a holding tank.

Tank V-4 sits within a 20' x 22' x 18" high bermed area and is painted for corrosion protection. The bermed area is sufficient to contain the total tank volume plus 8" of precipitation.

2.1.3 Piping

Piping at the facility generally consists of welded steel pipe ranging in size from 1" to 24" diameter. Designated gravel roads throughout the station property direct vehicular traffic away from piping structures and concrete barriers protect pipes form vehicular impact.

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Being part of a heated oil pipeline system, aboveground piping at the Station is wrapped in 2 inches of foam glass or urethane insulation and banded in aluminum casing. Pipeline elbows are covered by nylon mesh with a mastic outer covering. Underground insulated piping is covered with Pitt Wrap or isocyanurate insulation and is protected from corrosion by an impressed current cathodic protection system (See Section 4.2). Underground uninsulated pipe is either heat traced or below frost level and cathodically protected. Additionally, high pressure shutdown switches are installed on station piping to prevent overpressuring.

2.1.4 Storm Water Treatment

Storm water which contacts facility equipment is separated from storm water that contacts roofs and open gravel covered areas as described below:

 Exposed mechanical equipment, Tank V-3, and heaters at the facility are located on concrete pads surrounded by concrete curbs. Tank T-1 is located within a containment berm. Storm water contacting this equipment is collected on the pad and containment area. Each pad and the T-1 containment area have a drain which connects to a closed water collection system. Water collected from these drains is transferred by gravity to an underground tank for pumping to the Sun Oil Refinery for processing. Tank V-4 sits within a 20' x 22' x 18" high bermed area and is painted for corrosion protection. The bermed area is sufficient to contain the total tank volume plus 8" of precipitation.

 Storm water which falls on the roofs and open gravel covered areas at the site is collected in storm water channels within one of the three primary containment areas and then conveyed through culverts to the secondary containment area as described previously.

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2.1.5 Transformer Station

The Marcus Hook Pump Station contains a transformer station surrounding by a chain-link fence. The transformer contains 1,530 gallons of oil and is supported on a concrete pad. A concrete curb is located around the concrete pad to provide containment; the containment area can hold up to 1,530 gallons of liquid with 2 inches of freeboard.

Surface water runoff flows from the concrete pad into a 4-inch diameter pipe installed at an opening in the curb and discharges into an adjacent swale. An Imbiber Beads® Enclosed 1- Chamber (Class III) Shut-Off System is located along the alignment of the 4-inch diameter pipe. If oil should leak from the transformer and enter the Imbiber Beads® chamber, the system will block flow from discharging into the adjacent swale.

2.1.6 Detailed Drawings

Additional drawings of Marcus Hook Pump Station such as piping, site layout, tanks, electrical systems and buildings are maintained in the Marcus Hook Pump Station Control building. These plans are available for review during normal business hours, upon prior notice, and at any time when a discharge incident or imminent discharge necessitates consulting them.

2.2 DESCRIPTION OF RELATED EMERGENCY RESPONSE PLANS

This plan was originally prepared in April 1993 as a PPC Plan and has been modified to a Spill Prevention Response (SPR) Plan. In addition to this, PPLIEC maintains an oil spill response plan entitled "Response Plan for Onshore Oil Pipelines" which was developed to meet the requirements of the U.S. Department of Transportation as set forth in 49 CFR Part 194 and the Federal Oil Pollution Act of 1990. That plan applies to spill response along the entire pipeline including the pump station at Marcus Hook. The “Response Plan for Onshore Oil Pipelines” serves as a compliment to this SPR plan.

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The scope of the "Response Plan for Onshore Oil Pipelines" covers the following topics:

1. Notification Procedures 2. Spill Detection and Mitigation 3. Response Activities 4. Roles and Responsibilities of Response Team 5. Lists of Contacts 6. Training Procedures 7. Drill Procedures 8. Response Plan Review and Update Procedures 9. Response Zones

2.3 MATERIAL AND WASTE INVENTORY

2.3.1 Fuel Oil

No. 2 fuel oil is stored onsite in storage tank T-1 and is used to fuel four onsite oil heaters. The oil is supplied to the facility from the adjacent Sun Refinery Tank Farm by underground pipeline, and is also transferred to the heaters by underground pipeline. The maximum volume of No. 2 fuel oil stored on-site at any time is 4,000 barrels. T-1 is temporarily out of service.

No. 6 fuel oil is not stored at this facility; however the facility is used to transport No. 2 and No. 6 fuel oil through an 18-inch diameter pipeline to an electric generating station located in Northampton County. These fuels are supplied to the facility from the adjacent Sun Refinery Tank Farm by a separate underground pipeline. The transport of fuel oils could occur twice each year for a period of approximately two to four weeks. The pipeline is filled with nitrogen during the remainder of the year. The facility has two onsite nitrogen storage tanks; these tanks are filled prior to the transport of fuel oil.

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2.3.2 Therminol

Therminol is a nonhazardous heat transfer fluid. Its chemical name is C14-30 Alkylaromatic derivative and its CAS number is 68855-24-3. The Therminol is contained within a closed loop piping system and expansion tank (Tank V-3). The capacity of Tank V-3 is 2,562 gallons, however it is generally kept less than half full. The closed loop pipeline can circulate hot oil from one of the on-site heaters to heat exchangers within several storage tanks located in the adjacent Sun Refinery Tank Farm. This pipeline is above ground, insulated and banded in aluminum casing. Therminol is produced by Monsanto Company, St. Louis, MO.

2.3.3 Cleaning Solvent

The maintenance building contains a 35-gallon self-contained solvent storage vessel filled with Dyna 143º, a general purpose cleaner and degreaser. As needed, Dyna 143º is ordered to replenish the supply. An MSDS sheet for this solvent is included in Appendix A.

2.4 POLLUTION INCIDENT HISTORY

There have been no releases to land or water of SARA Title III Section 313 water priority chemicals by this facility at any time during the past ten years.

2.5 IMPLEMENTATION SCHEDULE FOR PLAN ELEMENTS NOT CURRENTLY IN PLACE

All plan elements are currently in place.

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13 3.0 DESCRIPTION OF HOW PLAN IS IMPLEMENTED BY ORGANIZATION

3.1 ORGANIZATIONAL STRUCTURE OF FACILITY FOR IMPLEMENTATION

3.1.1 Plan Development and Maintenance

The Manager Operations has overall responsibility for development and maintenance of this Spill Prevention and Response Plan. The plan will be reviewed annually by the Manager Operations or his designee. This review will include an evaluation of spill incidents within the previous year (if any) and the effectiveness of the response activities. The plan will then be updated to incorporate the recommendations of the evaluation.

The Manager Operations is also responsible for establishment of training and educational programs for facility personnel and organizing the Contingency and Response Team.

The Contingency and Response Team is responsible for the following activities:

 Identification of materials and wastes handled at the facility  Identification of potential spill sources  Establishment of spill reporting procedures  Risk assessment  Coordinating inspection programs  Review of past incidents and countermeasures  Response to spills  Notification of authorities  Establishment of training and educational programs for installation personnel  Review of construction and process changes at the facility relative to this plan  Evaluate the effectiveness of the plan  Recommending appropriate changes to the Plan

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3.1.2 Plan Implementation

The Contingency and Response Team is responsible for implementing this plan. The organizational structure of the Contingency and Response Team is shown in Table 3.1.

3.2 LIST OF EMERGENCY COORDINATORS

Primary Coordinator Curtis Rounds Office: (610) 327-5343 Home: (717) 687-7224 Mobile: (484) 226-4339 Alternate Coordinator Tom Dopsivic Office: (484) 373-2186 Home: (610) 252-4142 Mobile: (484) 256-0550 Environmental Coordinator Thomas Legel Office: (610) 840-9162 Home: (610) 286-0196 Mobile: (610) 389-2467

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15 TABLE 3.1 In-House Contingency and Response Team

TEAM MEMBER TITLE IEC OPERATIONS TITLE CURRENT INDIVIDUAL 1. Emergency Coordinator Manager Operations C. Rounds Alternate Pipeline Maintenance Manager T. Dopsovic and Engineer

2. Spill Operations Supervisor Pipeline Maintenance Supervisor G. Warfield Alternate Corrosion Specialist B. Roney

3. Recorder Supervisor Pipeline Controllers N. Gafford Alternate Dispatcher on Duty Varies Daily

4. Public Relations General Manager D. Cummings Alternate PPL Corp. Communications G. Lewis

5. Logistics Supervisor PAP & ROW K. McVeigh

6. Environmental Coordinator Consultant-Advanced Thomas Legel GeoServices Corp.

7. Response Team Support Pipeline Supervisor IEC personnel on-duty or Personnel Corrosion Specialist on-call at time of incident. Welder (1) Pipeline Attendants (2) Technicians (2)

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3.3 DUTIES AND RESPONSIBILITIES OF COORDINATORS

3.3.1 Emergency Coordinator

Immediate Actions:

1. Declare the IEC Response Plan into effect. 2. Notify the appropriate members of the Contingency and Response Team to report to their assigned area, and shutdown station operations, if warranted. Notify Sun Oil Company emergency response team (610-859-5400), if warranted. 3. Assure that notification has been given to the appropriate agencies (Federal, State and Local) (See Section 6.0). 4. Identify the cause of the incident. 5. Assess health and environmental hazards associated with the incident. 6. Coordinate efforts of Contingency and Response Team and Governmental Agencies in containment, repair and cleanup of oil spill. 7. Assure that notification has been given to PPL Management.

Supplemental Actions:

1. Submit the required written documentation to appropriate Governmental agencies (See Section 6.0).

3.3.2 Spill Operations Supervisor

Immediate Actions: 1. Notify all Response Team Support Personnel. 2. Coordinate the efforts to isolate the leak. 3. Dispatch the Response Team to assigned area. 4. Supervise efforts to contain and repair leak. 5. Mobilize emergency response contractor to assist in cleanup activities.

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Supplemental Actions:

1. Coordinate field cleanup efforts of all company personnel and emergency response contractors. 2. Keep Emergency Coordinator advised of progress on field activities. 3. Keep daily log of field activities.

3.3.3 Public Relations

1. Notify PPL Corporate Communications of spill 2. Keep Local Government officials advised of situation. 3. Act as Company Representative in issuing statements to the news media until Corporate Communications is on site. 4. Address questions and concerns from general public and special interest groups.

3.3.4 Environmental Site Coordinator Responsibilities

1. Provide 24 hour/365 days a year response capability to a spill site emergency upon notification by PPLIEC management. 2. Secure the services of a certified laboratory to analyze contaminated water and soil samples. 3. Maintain a comprehensive written log of all remedial actions performed at the spill site. 4. Interface with all Federal, State and Local Environment Officials at the spill site to insure compliance with Federal, State and Local environmental regulations. 5. Obtain samples of contaminated soil and water at the spill site. 6. Assure that all paperwork associated with samples are obtained for PPLIEC records. 7. Insure that lab samples are properly delivered to the certified lab for analysis.

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8. Assist PPLIEC personnel in evaluating the extent of environmental impact and recommend proper cleanup and disposal methods. 9. Assure that any contaminated spoils/water that are shipped off the spill site are documented and disposed in compliance with all Federal/State environmental regulations. 10. Within 30 working days after the completion of a spill incident, issue a detailed report to PPLIEC management with all supporting logs and documentation of soil/water samples disposal records and final clean-up reports to be filed in their permanent records. 11. Draft written reports to Regulatory Agencies as requested by PPLIEC.

3.4 CHAIN OF COMMAND

The Emergency Coordinator assumes primary responsibility, followed by the Field Supervisor, and finally the PPLIEC employees. Installation personnel will follow the set chain of command as will contractors brought on site in emergency situations.

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19 4.0 SPILL LEAK PREVENTION AND RESPONSE

4.1 PRE-RELEASE PLANNING

There are several sources and areas where potential spills or leaks may occur. These include the pipeline which is located throughout the site; the above ground storage tanks; pump areas and metering areas. Without the pollution prevention practices which are in place, spills would generally flow overland into the on-site drainage channels, which flow to the southern corner of the property, thence into off-site drainage channels.

The pollution prevention practices in effect for these possible sources include the following:

4.1.1 Pipeline

Pollution prevention practices related to the pipeline include inspections, pressure relief valves, thermal relief valves, insulation, cathodic protection and the primary and secondary containment areas. The primary and secondary containment areas are described in more detail below:

 Onsite runoff is collected as surface runoff within one of three primary containment areas and then conveyed through culverts and channels to the secondary containment area.

 Both the primary and secondary containment is achieved with berms and remotely operated sluice gates. The sluice gates contain a skimmer plate and a sump to separate oil and debris from the surface water flow. During manned operations, the sluice gates are closed and normal stormwater is monitored.

 Storm water collected in the secondary containment area discharges offsite through two culverts (containing remotely operated sluice gates) located at the southwest corner of the facility. In the event of a spill at the site, the sluice gates can be closed manually or remotely by the operator to minimize the discharge of

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spilled liquid and storm water from the site. In addition, a Sick Sleuth oil spill detection monitor and alarm system is located within the secondary containment area. Upon the detection of oil, this monitor will automatically close all the sluice gates at the facility

 The storage capacity of the secondary containment area is approximately 450,000 gallons.

4.1.2 Tank T-1

Pollution prevention practices related to Tank T-1 include visual observations of product transfer operations, corrosion protection, secondary containment by earthen dike, and the drain line to the collection tank.

4.1.3 Tank V-3

Pollution prevention practices related to Tank T-1 include visual inspections and liquid level monitoring, automatic high level alarm, corrosion protection, and the curbed concrete pad with the drain to the collection tank.

4.1.4 Tank V-4

Pollution prevention practices related to Tank V-4 include visual inspections, liquid level monitoring, secondary containment by earthen dike, and corrosion protection.

4.1.5 Booster Pumps, Metering Area and Heater Area

Pollution prevention practices related to these elements include visual inspections, regular maintenance, and the curbed concrete pad with drain to the collection tank.

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4.1.6 Main Pumps

Pollution prevention practices related to the main pumps include visual inspections, regular maintenance, thermal safety valves, pressure relief valves, vibration monitoring system, and the concrete pad.

4.1.7 Transformer Station

Pollution prevention practices related to the transformer station include visual inspections, regular maintenance, a concrete pad with concrete curb and an Imbiber Beads® Enclosed 1- Chamber (Class III) Shut-Off System.

4.2 MATERIAL COMPATIBILITY

There are no material compatibility problems anticipated between the oil and the steel pipeline, however moisture on the exterior of the steel pipe, tanks and equipment could result in corrosion of the steel.

A cathodic protection system is installed at the Marcus Hook Pump Station to mitigate corrosion of the underground pipes and the tank bottom. The system consists of an impressed current rectifier unit, distributed graphite anode bed and pipeline bonding stations. Type NA graphite anodes are installed in surface configuration. The anodes are located at strategic intervals throughout the terminal.

Solvents are compatible with their container and the containers are checked regularly for evidence of external corrosion.

4.3 INSPECTIONS AND MONITORING PROGRAM

Early detection of potential or existing leaks or spills of oil or hazardous wastes will aid in mitigating damage, injury and loss associated with such emergencies if not avert the incident

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altogether. In order to provide a means for monitoring for leaks or other conditions that could lead to spills or emergency situations, inspections are routinely performed by terminal operators.

4.3.1 Visual Inspections

The following oil spill and leak detection procedure is performed by operators weekly and the Leak Detection Checklist (Appendix B) is then filed in the station control building. Although many of the inspections are part of daily operating procedures, the weekly checklist ensures that all areas of potential leak or spill are constantly examined.

The inspection is carried out in the following order:

1. Inspect inlet strainer connection for leaks. 2. Inspect booster pump area for leaks and spills (i.e., seals, piping, relief line, etc.). 3. Inspect V-4 dike area and check all piping for leaks. Visually check and record tank level. 4. Inspect V-3 sight glass and record level. Check hot oil circulating pumps and piping for leaks. Check drip cans. 5. Inspect effluent tank piping for leaks. 6. Inspect sample building inside and outside. Check sump and sample lines. 7. Inspect each meter run, prover and meter sump for evidence of tampering/leaks to station piping. Check sump level. 8. Check flushing pump for leaks or tampering. Examine the heater fuel supply pumps and their seals for leaks or spills. 9. Inspect the T-1 dike area and check all piping. Walk around the perimeter of the tank and check all manways and cleanouts. 10. Inspect the concrete heater pad area and associated pipes for spills and leaks. 11. Inspect the mainline pump area for leaks and spills (i.e., seals, seal sumps, drain piping, flushing oil piping, check valve bypass piping, etc.). 12. Inspect PCV area. Visually check flanges, connections and fittings for sign of leakage.

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13. Inspect pig launcher area for leaks, spills, or tampering. Check drip buckets. 14. Inspect natural gas piping for leaks. 15. Inspect drainage channels for evidence of oil. 16. Inspect sluice gate areas for evidence of floating oil. Check sluice gates for operability. 17. Inspect solvent storage container for leaks or corrosion. 18. Inspect facility for Fugitive Emissions.

In addition, specific components of Tank T-1 and its secondary containment area are inspected either every three days, weekly or monthly when the tank is in service. See Appendixes D, E and F for tank inspections forms.

4.3.2 Cathodic Protection Inspection

In accordance with Department of Transportation regulations contained within 49 CFR Part 195, an annual pipe-to-soil survey is performed by the PPLIEC Corrosion Technician in order to determine if the cathodic protection is adequate. Additionally, six times each year, at intervals not exceeding 2-1/2 months, the cathodic protection rectifier is inspected. Both these inspections are recorded, with record documents maintained for at least 3 years.

4.3.3 Storm Water Discharge Inspection

Qualified personnel will conduct the following site evaluation annually.

 Visual inspection of the sediment present at the discharge culverts of the secondary containment area and identification of substances present in the sediment. Identify areas contributing or having the potential to contribute pollutants to the storm water discharge and evaluate whether measures to reduce pollutant loading identified in this plan are adequate and properly implemented, or if additional control measures are necessary.

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 Visually inspect storm water discharge structures, drainage channels, collection pads, sumps, erosion control measures and other related drainage features to insure they are operating properly.

 Visually inspect spill response equipment located at the facility.

 Revise this plan as appropriate as a result of the inspection within 15 days and implement changes within 90 days.

 Complete the inspection report (Appendix C).

4.4 PREVENTATIVE MAINTENANCE

PPLIEC has a comprehensive maintenance program established for all on-site equipment such as pumps, valves, pressure gauges, thermal safety valves, etc. Each piece of equipment is maintained in accordance with a monthly, quarterly, semi-annual or annual schedule. Each maintenance routine is described in the Station's Operation and Maintenance Manual which is kept at the station at all times. This Manual contains diagrams showing the location and identification number of each piece of equipment and defines the schedule for inspection, testing, maintenance, and calibration of the equipment.

Maintenance routines are assigned to the station operators via a monthly assignment sheet. Quarterly routines are performed in March, June, September and December. Semi-annual routines are performed in March and September except pressure gauges and Thermal Safety Valves (TSV) which are calibrated in April and October. Annual routines are performed in three sections, in May, June and October.

As each routine is completed, the maintenance activity is recorded on the permanent service record which is kept on-site for each piece of equipment. In addition, as each assignment sheet

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is completed it is placed in a binder specifically for completed assignment sheets. TSV calibration sheets are kept as a permanent record while all other assignment sheets are kept for at least one year.

4.5 HOUSEKEEPING

In order to reduce the possibility of accidental spills and safety hazards to terminal personnel, good housekeeping practices are followed. These include prompt removal of small spillage, regular emptying of drip cans, regular refuse pick up and disposal, maintenance of dry, clean floors by use of brooms or mops, and provision for storage of small containers of lubricating oil and parts-cleaner in the maintenance building such that there are open walkways between them. The maintenance-related oils and parts cleaner solvent are stored in their original shipping containers to assure compatibility.

Absorbent materials are kept in the maintenance shed for cleanups of small liquid spills while conducting routine maintenance.

4.6 EROSION AND SEDIMENTATION CONTROL

Whenever construction activities occur at the facility which require earth disturbance the operator will insure that Erosion and Sedimentation are properly controlled with the use of sediment filters, silt fences, temporary cover material and other control measures.

4.7 SECURITY

Marcus Hook Pumping Station is enclosed by a chain link fence and a sign at the front gate identifies the facility. The facility is manned eight hours a day, five days a week. Additionally, the station grounds are well lighted at night and remotely monitored by cameras to enhance security as well as to aid in the detection of any spill or leak.

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The gate at the entry to the terminal is closed and locked at all times. Traffic approaching the gate must stop and communicate via intercom with the control room operator, or enter a security code to open the gate. During normal operating hours, non-company personnel on-site are accompanied at all times by a company employee and occasional vehicular traffic is warned verbally of above-ground piping to be avoided.

4.8 EXTERNAL FACTOR PLANNING

The Marcus Hook Pump Station is also controlled remotely from a central location, and can be shutdown within minutes in the case of natural catastrophe or unforeseen emergency. The pump station operating equipment is situated outside of the flood plain, but is prepared to shutdown in the case of floods. A fail safe shutdown system within the pump station controls is automatically enacted with a change of pressure exceeding the shutdown limit of the pipeline. This system monitors the pipeline and the pump system.

There is minimal potential of an employee strike since the on-site work force consists of non- union employees, however the system can be easily shutdown in the absence of operators.

Vibration sensors on the pump, used to indicate excessive bearing wear, would also pickup seismic vibrations in the event of an earthquake, and the fail safe shutdown would be automatically activated.

In the event of a power failure, the system shuts down automatically. Other natural emergencies can be offset by the automatic online fail safety shutdown, or by controlling the facility from a remote location involving no on-site personnel.

4.9 TRAINING

The PPLIEC Supervisor responsible for Marcus Hook Pump Station reviews operator personnel actions on a day-by-day basis.

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PPLIEC conducts safety meetings for maintenance and operator personnel. At these safety meetings, the Manager of Operations and/or the Safety Consultant review pertinent operations, hazardous waste information, and safety-related subjects. Topics include possible abnormal/emergency conditions and employee response to such events as well as chemical handling and storage, and spill response.

In addition, all supervisory level and maintenance personnel that would respond to a spill have received the 24 Hour HAZWOPER training to meet the requirements of OSHA regulation 29 CFR 1910.120 by using classroom, hands-on experience, and all aspects of spill reporting, containment, recovery, and cleanup on land and water.

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28 5.0 COUNTERMEASURES

5.1 COUNTERMEASURES TO BE UNDERTAKEN BY FACILITY

The facility will enact the following countermeasures in the event of a spill or other emergency.

5.1.1 Automated Response

Since the station is automated, shutdown capabilities are constantly in place. A fail safe shutdown system within the pipeline is automatically enacted with a change of pressure exceeding the shutdown limit of the pipeline. This system monitors the pipeline and the pump system.

5.1.2 Internal Alert

Anyone discovering a spill or leak of oil or hazardous substance from any station piping, tankage, container or equipment, whether large or small, will immediately inform the facility supervisor. It is the supervisor's responsibility to determine the seriousness and extent of the spill and whether or not further internal reporting is required. Minor spills (less than 5 gallons) onto an impervious surface, which can be cleaned up easily, require no further reporting; provided quantities or concentrations do not pose foreseeable risk or harm to public health or welfare, or to natural resources.

Spills not considered to be minor in nature will be reported to the Manager Operations. It is his responsibility to notify other company employees and in particular the members of the Company Contingency and Response Team.

5.1.3 Contingency and Response Team

A Contingency and Response Team consisting internal and external resources will be formed immediately upon being summoned by the Manager Operations. Whether the spill consists of oil or hazardous material, the response is the same.

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5.1.4 Initial Response

The first action at the site of a spill or discharge, which should be initiated by the person discovering the spill, is to attempt to locate the source of the discharge and stop further leakage of product, if possible. If the emergency involves fire or explosion or other life endangering circumstances, personal safety should take precedence. In addition, the sluice gates downstream of the spill/discharge shall be closed immediately.

5.1.5 Containment

Two stages of containment are inplace at the facility and will be activated when the sluice gates close. However, if the migration of oil can be minimized using additional containment, this can be accomplished by digging an impoundment basin near the leak and directing spilled oil into the impoundment basin from which it can be pumped. An above ground earth berm may be erected to contain movement of the oil. Additional barriers and basins should be constructed as necessary to prevent oil from entering into adjacent natural drainage areas. If on-site drainage ditches are already affected, the ditch shall be blocked downstream of the affected area with a berm and used as a containment area. The Field Supervisor shall take any necessary action to protect public health, environment and property. Fire Departments, Police, etc. shall be called, as necessary, to assist in any way until the emergency is under control and public safety is assured.

5.1.6 Repair

The Field Supervisor is responsible for coordinating the repair of the pipeline or other equipment to ensure that repairs are made in a safe manner. All repair work will be done in accordance with approved codes and specifications.

The PPLIEC Operations and Maintenance Manual for the facility contains complete details for pipeline and equipment repair.

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5.1.7 Cleanup and Disposal

Areas affected by an oil or hazardous waste spill will be cleaned up and restored to a condition satisfactory to PPLIEC management and to the satisfaction of the regulatory agencies. Oil collected from barriers or basins may be pumped into mobile tank trucks for transportation to PPLIEC tankage, the Sun Oil Company Tank Farm, or, if unsuitable for storage, to an approved waste disposal site in accordance with the degree of hazard of the waste and state regulations governing transportation and disposal. Contaminated spill handling material and saturated soil must also be removed and disposed of in an approved manner. Until cleanup procedures are completed, no material that may be incompatible with the discharged material should be stored in the affected area.

5.2 COUNTERMEASURES TO BE UNDERTAKEN BY CONTRACTORS

Depending upon the severity of the emergency, outside contractors may be contacted to aid in response efforts. The Field Supervisor is responsible for assembling needed personnel and equipment for use at the facility. Emergency contractors that may be requested to aid in cleanup or repair activities are presented below.

In addition, PPLIEC has contracted with Advanced GeoServices Corp., an environmental consulting firm. Under the contract, Advanced GeoServices Corp. will be used for engineering, consulting, and coordination of site cleanup and remediation during spill responses. A list of emergency equipment available for use at the Marcus Hook Pump Station is provided at the end of Section 5.5.

In the event of a significant release, the Sun Oil Company Response Team is available for immediate response. Their facility is located adjacent to the station, and they can generally respond within 15 minutes. If the spill threatens to migrate off-site, the Sun Oil Company response team is equipped to install booms in the off-site drainage channels and Naamans Creek. These booms are stored in a storage area adjacent to the station.

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5.2.1 Approved Response Contractors

A. The following contractors are fully equipped spill remediation contractors capable of providing the necessary material and equipment for removing pollution or hazards to the public health and safety. These contractors are approved by PPLIEC for immediate emergency response to a spill situation.

Primary Contractor

Lewis Environmental 1-800-258-5585 155 Railroad Plz Royersford, PA 19468-1953

Additional Service Contractors

Allstate Power-Vac Industrial/Environmental Services 1-800-876-9690 2527 Market Street Twin Oaks, PA 19014

Environmental Products and Services 532 State Fair Boulevard Syracuse, NY 13204 1 (800) THE-TANK

JMT Environmental Technologies 610-837-8000 3353 Gun Club Rd., Nazareth, PA 18064

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Preparedness Solutions Associates, LLC 2492 Jones Road Pottstown, PA 19465 610-842-4280 - Cell

Clean Venture/Cycle Chem 201 South First Street Elizabeth, NJ 07206 1 (908) 354-0210

HMHTTC Response Inc. 400 Valley Road, Suite 303 Mount Arlington. NJ 07856 1-800-927-9303

B. The following Environmental Consultant has been approved for immediate response to a spill situation:

1. Advanced GeoServices Corp. 1055 Andrew Drive, Suite A West Chester, PA 19380-4293

Phone: (610) 840-9100

Thomas Legel Home: (610) 286-0196 Mobile: 610-389-2467 Todd Trotman Home: (610) 466-7007 Mobile: 610-389-2472

5.3 INTERNAL AND EXTERNAL COMMUNICATIONS AND ALARM SYSTEMS

Due to the nature and small size of the Marcus Hook Pump Station, internal communication is carried out via vocal alert or two way radio. External communication consists of telephone and cellular phone.

5.4 EVACUATION PLAN FOR INSTALLATION PERSONNEL

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The Marcus Hook Pump Station is generally manned by no more than two people. Evacuation is achieved by exiting the site by foot or vehicle, leaving operational control to the central dispatch unit. Evacuation orders can be communicated by voice command or cellular phone. The primary evacuation route is through the front gate, the secondary route is over the fence at any location.

5.5 EMERGENCY EQUIPMENT

All emergency equipment and personnel is provided by Primary Contractors.

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34 6.0 EMERGENCY SPILL CONTROL NETWORK

6.1 ARRANGEMENTS WITH LOCAL AUTHORITIES

Local emergency services for the Marcus Hook Pump Station, should they be required, will be provided through the Lower Chichester Township Police Department. Whether the fire department, police or ambulance are required, all dispatching is performed through the police department's emergency number, 911. Receiving hospitals are selected by the Lower Chichester Paramedics, based upon type and severity of injury. Available hospitals include Chester Community Hospital and the Crozer Chester Burn Center.

Addresses and telephone numbers of these agencies are provided at the end of this section.

6.2 EXTERNAL NOTIFICATIONS

In accordance with his duties as Emergency Coordinator, the Manager Operations is responsible for reporting certain oil or hazardous material spills to appropriate governmental agencies. The following outlines both telephone and written reporting requirements at the federal, state and local levels. A listing of these governmental agencies and their addresses and/or telephone numbers is provided at the end of this section.

6.2.1 Federal Notifications

DOT-49CFR Part 195

Department of Transportation regulations contained within 49CFR Part 195 require that the U.S. Coast Guard National Response Center (NRC), 1-800-424-8802, be notified any time there is a pipeline failure as described below:

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Telephonic notice of certain accidents.

(a) At the earliest practicable moment following discovery of a release of the hazardous liquid or carbon dioxide transported resulting in an event described in §195.50, the operator of the system shall give notice, in accordance with paragraph (b) of this section, of any failure that: (1) Caused a death or a personal injury requiring hospitalization; (2) Resulted in either a fire or explosion not intentionally set by the operator; (3) Caused estimated property damage, including cost of cleanup and recovery, value of lost product, and damage to the property of the operator or others, or both, exceeding $50,000; (4) Resulted in pollution of any stream, river, lake, reservoir, or other similar body of water that violated applicable water quality standards, caused a discoloration of the surface of the water or adjoining shoreline, or deposited a sludge or emulsion beneath the surface of the water or upon adjoining shorelines; or (5) In the judgment of the operator was significant even though it did not meet the criteria of any other paragraph of this section.

(b) Reports made under paragraph (a) of this section are made by telephone to 800–424– 8802 and must include the following information: (1) Name and address of the operator. (2) Name and telephone number of the reporter. (3) The location of the failure. (4) The time of the failure. (5) The fatalities and personal injuries, if any. (6) All other significant facts known by the operator that are relevant to the cause of the failure or extent of the damages.

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Accident reports.

(a) Each operator that experiences an accident that is required to be reported under §195.50 shall as soon as practicable, but not later than 30 days after discovery of the accident, prepare and file an accident report on DOT Form 7000-1, or a facsimile. (b) Whenever an operator receives any changes in the information reported or additions to the original report on DOT Form 7000-1, it shall file a supplemental report within 30 days.

An accident report is required for each failure in a pipeline system subject to this part in which there is a release of the hazardous liquid or carbon dioxide transported resulting in any of the following:

(a) Explosion or fire not intentionally set by the operator. (b) Release of 5 gallons (19 liters) or more of hazardous liquid or carbon dioxide, except that no report is required for a release of less than 5 barrels (0.8 cubic meters) resulting from a pipeline maintenance activity if the release is: (1) Not otherwise reportable under this section; (2) Not one described in §195.52(a)(4); (3) Confined to company property or pipeline right-of-way; and (4) Cleaned up promptly.

(c) Death of any person; (d) Personal injury necessitating hospitalization; (e) Estimated property damage, including cost of clean-up and recovery, value of lost product, and damage to the property of the operator or others, or both, exceeding $50,000.

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EPA - 40 CFR Part 110, Discharge of Oil

Pursuant to 40 CFR Part 110, "Discharge of Oil", a spill of oil must be reported if it causes a film or sheen upon or discoloration of the surface of the water or adjoining shorelines or causes a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines.

This report must be made to the NRC (800-424-8802) immediately upon discovery of the incident.

6.2.2 State and Local Notifications

Pennsylvania DEP - Water Resources Regulations

Under the Pennsylvania Code, Title 25, Chapter 101, notification must be made to the Department of Environmental Protection (DEP) by telephone of any pollution (including oil or hazardous material of waters of the Commonwealth. In addition, the person responsible for the polluting discharge must notify any affected downstream users and take all steps necessary to prevent further injury. Within fifteen (15) days from the incident, the responsible party must remove from the ground and from affected waters, the polluting substance to the extent required by the Department.

Under Pennsylvania law, "Waters of the Commonwealth" includes "rivers, streams, creeks, rivulets, impoundment, ditches, water courses, storm sewers, lakes, dammed water, ponds, springs and all other bodies or channels of conveyance of surface and ground waters, or parts thereof, whether natural or artificial within or on the boundaries of this Commonwealth". Telephone notification must be directed during business hours to the Southeast Regional Office (covering the County of Delaware), (484) 250-5900 (24-hour).

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Pennsylvania DEP - Solid Waste Regulations

Although the quantity of hazardous waste generated at Marcus Hook is minimal, Pennsylvania hazardous material spill reporting requirements may still be applicable. Pursuant to Pennsylvania Code, Title 25, Chapter 75, Subchapter D, "Hazardous Waste", reportable quantities of hazardous wastes spilled or discharged are set forth. Spills and discharges which are in amounts less than the reportable quantity which do not result in discharge to surface or ground water, and which are managed according to an approved contingency plan need not be reported.

Conversely, any discharges or spills into surface or ground water must be reported regardless of quantity spilled or discharged.

In the event of a discharge or spill of a reportable quantity of hazardous waste or if there is a fire, explosion, emission or discharge of hazardous waste which could threaten human health or the environment, appropriate action must be taken to protect the public and the environment.

The DEP must be notified immediately by telephone as well as the NRC, with the following information:

1) name of person reporting the spill, 2) name and identification number of generator, 3) phone number where person reporting the spill can be reached 4) date, time, and location of the spill 5) brief description of the incident 6) for each waste spill provide the shipping name, hazard class and U.N. number 7) the extent of contamination of land, water, or air, if known 8) extent of injuries, if any.

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In addition, the generator must file a written report on any reportable hazardous waste spill with the DEP within 15 days of the incident. The report shall be entitled "Hazardous Waste Spill Report" and shall contain the following information:

1) name, address and I.D. code of the generator and the date, time and location of the incident, 2) a brief description of the cause of the incident, 3) description of the hazardous waste involved and quantity spilled, 4) a legible copy of the manifest document, if applicable, 5) a description of any contamination of land, water or air, 6) actions taken to prevent recurrence, 7) extent of injuries, if any.

Delaware DNREC - Discharge of a Pollutant

If a spill migrates over the PA/DE state line (southwestern property line) then the Delaware Department of Natural Resources and Environmental Control (DNREC) requires immediate notification of a spill to the Environmental Emergency Notification and Complaint Center, under 7 Delaware Code, Chapter 60, Environmental Protection Law. DNREC requires a detailed report within 30 days of a discharge in accordance with their regulation titled "Reporting of a Discharge of a Pollutant or an Air Contamination" effective April 1, 1991.

The Environmental Emergency Notification and Complaint Center phone number is 1-800-662- 8802.

Lower Chichester Township

The Lower Chichester Township requires notification of a spill immediately and a final report within 30 days of the final remediation date. The spill notification may be via telephone or letter. Both the spill notification and the final report should contain the following:

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 specifics of the spill  impact on the surroundings  expected duration of the remediation  how the incident is or has been addressed

EMERGENCY NOTIFICATION LIST - GOVERNMENTAL AGENCIES

Federal National Response Center 1-(800)-424-8802 (this number notifies all federal agencies including E.P.A.) (24 hours)

US EPA (Region 3) (215) 814-5616 1650 Arch Street Philadelphia, PA 19103-2029

U.S. Coast Guard (215) 271-4800 One Washington Avenue Philadelphia, PA 19147

State - Pennsylvania Pennsylvania Department of Environmental Protection (DEP) Southeast Regional Office (484) 250-5900 Emergency Response 2 East Main Street Norristown PA 19401

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Harrisburg Office (717) 787-4343 909 Elmerton Avenue Harrisburg, PA 17110

Pennsylvania Emergency Management 1-(800) 372-7362 Agency (PEMA)

State - Delaware Delaware Department of Natural 1-(800)-662-8802 Resources and Environmental Control P.O. Box 1401 89 Kings Highway Dover, DE 19901

State - New Jersey New Jersey Department of (609) 292-1250 Environmental Protection (Site Remediation) Southern Regional Office One Port Center 2 Riverside Drive, Suite 201 Camden, NJ 08103 Environmental Emergency Hotline 1 (877) WARNDEP (24 hr.)

Gloucester County Emergency Response Center 1200 N. N. Delsea Drive Clayton, NJ 08312 Emergency Coordinator (856) 384-4630 Emergency Communication Center (856) 589-0911 (24 Hr.)

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Salem County Emergency Management 135 Cemetary Road Woodstown, NJ 08098 Deputy Emergency Coordinator (856) 769-2900 Emergency Number (856) 769-2959 (24 Hr.)

Local Delaware County Civil Defense (610) 565 8700

Linwood Fire Company (610) 485 6839 or 911

Lower Chichester Police Department (610) 485-2760 or 911

Marcus Hook Sunoco Fire Department (610) 859-1548

Lower Chichester Township (610)-485-1472 1410 Market Street Linwood, PA 19061

6.3 DOWNSTREAM WATER USERS ON THE DELAWARE RIVER

The following downstream water users are located south of the Marcus Hook facility. In the event of a spill entering the Delaware River, via Naamans Creek, the following downstream water users must be notified.

Downstream Water Users Ciba-Geigy 205 South James Street Newport, DE 19804 (302) 992-5730

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Connectiv Deepwater Station 373 North Broadway Pennsville, NJ 08070 (609) 678-1700

E. I. DuPont Chambers Works Rt. 130 & Canal Road Deepwater, NJ 08023 (856) 540-2012

Unigema 315 Cherry Lane New Castle, DE 19720 (302) 427-1400

PSE&G - Hope Creek P.O. Box 236, Mail Code N-21 Hancocks Bridge, NJ 08038 (856) 339-3027

PSE&G - Salem P.O. Box 236, Mail Code N-21 Hancocks Bridge, NJ 08038 (856) 339-5200

Citisteel USA 4001 Philadelphia Pike Claymont, DE 19703-2794 (302) 792-5444

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Connective Edgemoor Power 200 Hay Road Wilmington, DE 19099 (302)761-7103

General Chemical Corporation 6300 Philadelphia Pike Claymont, DE 19703 (302) 792-8500

SPI Polyols 321 Cherry Lane New Castle, DE 19720 (302) 576-8688

E.I. Dupont Edgemoor 4600 Hay Road Edgemoor, DE 19809 (302) 761-2298

Downstream Municipalities Carney's Point Township, NJ 303 Harding Highway Carney's Point, NJ 08069 (856) 299-4509

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Logan Township, NJ 125 Main Street Bridgeport, NJ 08014 (856)-467-2670

Borough of Penns Grove Emergency Management Coordinator 1 State Street P.O.B. 527 Penns Grove, NJ 08069 (856) 299-6696

Oldmans Township 32 West Mill Street P.O. Box 416 Pedricktown, NJ 08067 (856) 299-4890

Pennsville Township, NJ 90 North Broadway Pennsville, NJ 08070 (856) 678-3089

Elsinboro Township 619 Salem-Fort Elfsborg Road Salem, NJ 08079 (856) 935-2200

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City of New Castle, DE 220 Delaware Street New Castle, DE 19720 (302) 322-9804

City of Wilmington Public Safety Building 300 North Walnut Street Wilmington, DE 19801 (302) 576-2100

Delaware City P.O. Box 4159 407 Clinton Street Delaware City, DE 19706 (302) 834-4573

Downstream County Governments Delaware County Emergency Services Department 360 North Middletown Road Lima, PA 19063 (610) 565-8700

New Castle County Office of Emergency Preparedness 87 Reads Way New Castle, DE 19720 (302) 738-3133

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New Castle County Communication Center 3601 North DuPont Highway New Castle, DE 19720 (302) 738-3133

Downstream Parks Along Delaware River Fort Mott State Park 454 Fort Mott Road Pennsville, NJ 08070 (Mr. Dean Cramer) (609) 935-3218

Fort Delaware State Park P.O. Box 170 Delaware City, DE 19706 (302) 834-7941 (800) 523-3336

Fox Point State Park, DE Bellevue State Park 800 Carr Road Wilmington, DE 19809 (302) 577-3390

Supawna Meadow Wildlife Refuge 197 Lighthouse Road Pennsville, NJ 08079 (609) 935-5307

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48 APPENDIX A

MSDS SHEET

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ZEP Inc. 11627 178th Street Edmonton, Alberta T5S 1N6 1-877-I-BUY-ZEP (428-9937) Material Safety Data Sheet www.zep.com

Section 1. Chemical Product and Company Identification Product name DYNA 143 Product use Parts Cleaner Product code 0366 Date of issue 11/08/10 Supersedes 02/08/08 Emergency Telephone Numbers For MSDS Information: Technical Services Group Telephone (780) 453-8100 (Business Hours 8:00am - 5:00pm)

For Medical or Transportation Emergency CANUTEC (24 Hours) (613) 996-6666 - Call Collect Prepared By Printing date: 09/11/10 Technical Services Group 11627 178th Street Edmonton, Alberta T5S 1N6

Section 2. Hazards Identification Emergency overview CAUTION ! COMBUSTIBLE LIQUID AND VAPOR. Combustible liquid. Keep away from heat, sparks and flame. Avoid breathing vapor or mist. Avoid contact with skin and clothing. Use only with adequate ventilation. NOTE: MSDS data pertains to the product as delivered in the original shipping container(s). Risk of adverse effects are lessened by following all prescribed safety precautions, including the use of proper personal protective equipment. Acute Effects Routes of Entry Eye contact, Skin, Inhalation. Eyes May cause eye irritation. Inflammation of the eye is characterized by redness, watering and itching. Skin May cause skin irritation. Skin inflammation is characterized by itching, scaling, or reddening. Inhalation Harmful by inhalation. Over-exposure by inhalation may cause respiratory irritation. Can cause central nervous system (CNS) depression. Pre-existing respiratory disorders may be aggravated by over-exposure to this product. Ingestion Aspiration hazard if swallowed. Can enter lungs and cause damage. Chronic effects Prolonged skin contact may cause dermatitis with drying and cracking of skin. Skin which is repeatedly defatted by contact with this product may be more susceptible to irritation, infection or dermititis. Additional Information: See Toxicological Information (Section 11)

Section 3. Composition/Information on Ingredients Name of Hazardous Ingredients CAS number % by Weight LIGHT ALIPHATIC NAPHTHA; solvent naphtha (petroleum), medium aliphatics 64742-88-7 60 - 100

Section 4. First Aid Measures Eye Contact Immediately flush eyes with plenty of water, occasionally lifting the upper and lower eyelids. Check for and remove any contact lenses. Continue to rinse for at least 10 minutes. Get medical attention if irritation occurs. Skin Contact Flush affected skin with plenty of water. Remove contaminated clothing and shoes. Get medical attention if symptoms occur. Wash clothing before reuse. Clean shoes thoroughly before reuse. Inhalation Move exposed person to fresh air. If not breathing, if breathing is irregular or if respiratory arrest occurs, provide artificial respiration or oxygen by trained personnel. Get medical attention if adverse health effects persist or are severe. Ingestion If material has been swallowed and the exposed person is conscious, give small quantities of water to drink. Never give anything by mouth to an unconscious person. Do not induce vomiting unless directed to do so by medical personnel. If vomiting occurs, the head should be kept low so that vomit does not enter the lungs. Get immediate medical attention.

Page: 1/3 Product code 0366 Material Safety Data Sheet Product Name DYNA 143

Section 5. Fire Fighting Measures Flash Point Closed cup: 62°C (143.6°F) [Pensky-Martens.] Flammable Limits Lower: 1% Upper: 7% Flammability Combustible liquid. Auto-ignition Temperature

Fire-Fighting Procedures Use dry chemical, CO2, water spray (fog) or foam. Fire-fighters should wear appropriate protective equipment and self-contained breathing apparatus (SCBA) with a full face-piece operated in positive pressure mode. Fire hazard Combustible liquid. In a fire or if heated, a pressure increase will occur and the container may burst, with the risk of a subsequent explosion. The vapor/gas is heavier than air and will spread along the ground. Vapors may accumulate in low or confined areas or travel a considerable distance to a source of ignition and flash back.

Products of Combustion May emit toxic fumes under fire conditions. carbon oxides (CO, CO2) Explosion hazard Not available.

Section 6. Accidental Release Measures

Spill Clean up Stop leak if without risk. Move containers from spill area. Dilute with water and mop up if water-soluble or absorb with an inert dry material and place in an appropriate waste disposal container. Use spark-proof tools and explosion-proof equipment. Dispose of via a licensed waste disposal contractor.

Section 7. Handling and Storage

Handling Put on appropriate personal protective equipment (see section 8). Do not breathe vapor or mist. Do not ingest. Avoid contact with eyes, skin and clothing. Use only with adequate ventilation. Wear appropriate respirator when ventilation is inadequate. Store and use away from heat, sparks, open flame or any other ignition source. Use explosion-proof electrical (ventilating, lighting and material handling) equipment. Use non-sparking tools. Take precautionary measures against electrostatic discharges. Do not reuse container. Wash thoroughly after handling. Storage Do not store above the following temperature:49°C (120°F). Store in a segregated and approved area. Store in original container protected from direct sunlight in a dry, cool and well-ventilated area, away from incompatible materials (see section 10) and food and drink. Eliminate all ignition sources. Separate from oxidizing materials. Keep container tightly closed and sealed until ready for use. Do not store in unlabeled containers. Keep out of the reach of children.

Section 8. Exposure Controls/Personal Protection

Product name Exposure limits Light Aliphatic Naphtha ACGIH TLV (United States). TWA: 100 ppm 8 hour(s). Supplier Suggested TLV (United States). TWA: 100 ppm 8 hour(s). Personal Protective Equipment (PPE) Eyes Recommended: Splash goggles. Hands and Recommended: Neoprene gloves. Nitrile gloves. Rubber gloves. Body Respiratory Use with adequate ventilation. Provide exhaust ventilation or other engineering controls to keep the airborne concentrations of vapors below their respective occupational exposure limits. Wear appropriate respirator when ventilation is inadequate. Approved/certified respirator with organic vapor cartridge.

Section 9. Physical and Chemical Properties

Physical State Liquid. Color Colorless. pH Not available. Odor Mild. Boiling Point 187°C (368.6°F) Vapor Pressure < 1.0 @ 20°C Specific Gravity 0.79 Vapor Density 5.3 [Air = 1] Solubility Insoluble in the following materials: cold water. Evaporation Rate 0.14 (Butyl acetate. = 1) Freezing Point VOC (Consumer) 100% (789 g/L; 6.58 lbs/gal)

Page: 2/3 Product code 0366 Material Safety Data Sheet Product Name DYNA 143

Section 10. Stability and Reactivity

Stability and Reactivity The product is stable. Incompatibility Reactive or incompatible with the following materials: oxidizing materials.Keep away from heat, sparks and flame. Hazardous Polymerization Will not occur. Hazardous Decomposition Products Under normal conditions of storage and use, hazardous decomposition products should not be produced.

Section 11. Toxicological Information

Carcinogenicity No known significant effects or critical hazards. Ingredients: Not listed as carcinogen by OSHA, NTP or IARC. Acute Toxicity

Section 12. Ecological Information

Environmental Effects No known significant effects or critical hazards. Aquatic Ecotoxicity

Not available.

Section 13. Disposal Considerations

Waste Information Waste must be disposed of in accordance with applicable regulations. Consult your local or regional authorities for additional information. Waste Stream

Section 14. Transport Information

Regulatory information UN number Proper shipping name Classes PG* Label Additional information

TDG Classification Not regulated. - - - -

IMDG Class Not available. Not available. Not available. - -

NOTE: DOT classification applies to most package sizes. For specific container size classifications or for size exceptions, refer to the Bill of Lading with your shipment. Limited Quantity: Small quantities of controlled goods are not regulated as Dangerous Goods according to TDG regulations. PG* : Packing group

Section 15. Regulatory Information Canada WHMIS (Canada) Class B-3: Combustible liquid with a flash point between 37.8°C (100°F) and 93.3°C (200°F). This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations and the MSDS contains all the information required by the Controlled Products Regulations.

Section 16. Other Information

To the best of our knowledge, the information contained herein is accurate. However, neither the above named supplier nor any of its subsidiaries assumes any liability whatsoever for the accuracy or completeness of the information contained herein. Final determination of suitability of any material is the sole responsibility of the user. All materials may present unknown hazards and should be used with caution. Although certain hazards are described herein, we cannot guarantee that these are the only hazards that exist.

APPENDIX B

LEAK DETECTION CHECKLIST

F:\Projects\1992\92054-Marcus Hook Pump Station\Sec Files\2014\PPC-SPR and SPCC\10-8-14-Marcus Hook PPC SPR and SPCC.docx

MARCUS HOOK PUMP STATION LEAK DETECTION CHECKLIST

This form will be used by the Station Operator during the weekly facility inspection. This inspection is to identify any terminal component which could leak (i.e., heaters, piping, pumps, sumps, transformers, valves, tanks, etc.).

DATE__ OPERATOR

REMARKS Inlet Strainer Area Connections for leaks

Booster Pump Area Drip Cans Seals, Lines Note Any Other Leakage:

Booster Relief/Bypass All Piping

V-4 Holding Tank Area All Piping Tank Level

Effluent Tank Area All Piping Tank Level

Meter Run Area All piping, Sump Level Sump Piping

Circulating Pump Area All piping Drip Cans

Propane Tanks V-1, V-2 All Piping

T-1 Area Inspect Dike Area Manways/Cleanouts All Piping Tank Level

Appendix B.docx Revised 8/2009 kw REMARKS

Fuel Oil Pump Pad Area All Piping Drip Buckets Truck Fill Line

Heater Pad Area All Piping Sump Level Sump Piping

Mainline Pump Area Sump Level P-4, P-5, P-6, P-7 Seal Lines All Piping

PCV Area Flanges Connections Fittings

Launcher Area Flanges Connections Fittings Drip Buckets

Natural Gas Supply Area All Piping

Drainage Channels

Control Basin Sluice Gates

Solvent Storage Container

Test Eye Wash:

Fence check:

Facility Fugitive Emission:

OTHER COMMENTS OR REMARKS:

APPENDIX C

STORM WATER DISCHARGE INSPECTION REPORT

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MARCUS HOOK PUMP STATION STORM WATER DISCHARGE INSPECTION REPORT

Name: ______

Date:______

Condition of Storm Water ______Discharge Structure: ______

______

Observations of Sediment ______Present at the Discharge ______Structure: ______

Substances Present in the ______Sediment: ______

______Condition of Drainage ______Channels: ______

______

Condition of Collection ______Pads: ______Condition of Sumps: ______

______

F:\Projects\1992\92054-Marcus Hook Pump Station\Sec Files\2014\PPC-SPR and SPCC\Appendix C.doc MARCUS HOOK PUMP STATION STORM WATER DISCHARGE INSPECTION REPORT

Condition of Erosion Control ______Measures: ______

______

______Condition of Other Related ______Drainage Features: ______

______

______Condition of Spill Response ______Equipment Located at the ______Facility: ______

______

Actions Taken or to be ______Taken to Correct ______Deficiencies Noted Above: ______

______

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APPENDIX D

T-1 A BOVE GROUND STORAGE TANK VISUAL INSPECTION FORM

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MARCUS HOOK PUMP STATION

T-1 ABOVE GROUND STORAGE TANK VISUAL INSPECTION

The following inspection will be conducted at least every 72 hours when the tank is in service:

1) A check for any potentially hazardous conditions, evidence of a spill, overflow or leakage. 2) A check of the containment area for accumulation of water. 3) A check of the containment drain valves to make sure they are secured in a closed position when not in use.

Please note any discrepancies or concerns below. If there are no issues indicate OK below. Sign and date this form and return it to the Operations Supervisor.

------Signature Date

APPENDIX E

WEEKLY T-1 TANK INSPECTION FORM

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MHPS

Tank Inspection Log

TANK INSPECTION LOG INSPECTOR TANK NO. DATE COMMENTS

T-1 See attached sheets

Items to be inspected:

Tanks Foundations Piping

Items to be noted:

Drip marks Discoloration Puddles containing stored material Corrosion Localized dead vegetation Cracks Settling Gaps between tank and foundation Damage caused by vegetation roots Bowing of pipe between supports Droplets of stored material Seepage on valves or seals

Marcus Hook Weekly Tank Inspection Form 6/09 td/kw

Place Completed form in SPPC binder

APPENDIX F

MONTHLY MAINTENANCE OPERATION CHECKLIST FOR ABOVEGROUND STORAGE TANKS

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MONTHLY MAINTENANCE OPERATION CHECKLIST FOR ABOVEGROUND STORAGE TANKS PPLIEC Marcus Hook T-1

ITEM SYMBOL REFERENCE

I. Visual Check for Deterioration Condition of tank exterior S U Condition of aboveground piping S U Condition of foundations and supports S U Condition of containment structures S U

II. Containment Areas Level of standing water in containment S U Drain Valves secured in a closed position Y N Debris or fire hazard in containment Y N

III. Leak Detection System Leak detection system monitored Y N Regulated Substance in containment area Y N Evidence of release from tank Y N Evidence of release from ancillary equipment including piping Y N

IV. Ancillary Equipment Overfill prevention device functioning properly (if installed) Y N Valves functioning properly Y N Vents clear of restrictions Y N Gauge or monitoring device functioning properly (if installed) Y N

V. Safety Precautions Safety equipment in place and operative Y N Fire extinguishers in place Y N Safety precautions posted Y N Tank system secured to prevent vandalism and unauthorized use Y N

Facility I.D.# 23-40759 Inspection Completed By: Date:

Comments:

Symbols S - Satisfactory U - Unsatisfactory Y - Yes N - No

PPLIEC Marcus Hook Tank T-1 168,000 Gallons Tank ID 540526

INSTRUCTIONS FOR SAMPLE MONTHLY MAINTENANCE OPERATION CHECKLIST

PPLIEC Personnel should complete the checklist by circling S/U or Y/N as indicated for each item. Unsatisfactory (U) conditions are those conditions that may cause potential leaks, spills or environmental degradation if allowed to remain uncorrected, for example areas on tank exteriors which are unprotected or containment structures and foundations which are crumbling, rusting and remain in general disrepair. No (N) should be circled if conditions for those items indicated are not met; for example vents blocked by an obstruction or unsecured drain valve. A specific reference number (1,2,3 etc) for the situation that is unsatisfactory or does not meet the conditions indicated should be made in the “Reference” column. Comments should then be made for each reference number in the “Comments” section. An example would be circling “U” for the item “vent clear of restrictions”, writing a number “1” in the “Reference” column and then writing “1) vent obstructed by bird nest” in the “Comment Section”. Individuals completing the inspection should include their name and the date the inspection was completed.

Upon completed checklists should be kept at the facility for 12 months and a copy sent to the Operations Supervisor for his review.

ATTACHMENT E

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