TRAINING GUIDE
FOR
FORT RUCKER
INSTALLATION SPILL CONTINGENCY PLAN (ISCP)
AND
SPILL PREVENTION, CONTROL AND COUNTERMEASURES PLAN(SPCC)
TRAINING REQUIREMENTS.
At least once per year, all units or organizations, including contractors, that have a Site-Specific Section in the Fort Rucker SPCC Plan must provide initial or update training for all employees who handle or use hazardous materials, hazardous waste,and/or oil/fuel of any type in quantities equal to or greater than 1 quart at a time (this requirement does not include refueling a ground vehicle at a fuel pump). New employees must not be allowed to perform any operations involving hazardous materials, hazardous waste, or oil/fuel without direct supervision until they receive training. Training will, at a minimum, cover the following subjects: (1) ISCP requirements, (2) general requirements of the SPCC, and (3) site specific requirements of the SPCCapplicable to their assignments.
Training will be conducted by unit personnel,either by having trainees read this guide or by conducting classroom training following this guide. Training must be recorded using the Signature Page at the end of this training guide. Records of training (names and signatures of persons who attended, unit, and date of training) must be kept by the unit or contractor at a central location for three years and be available for inspection by regulators as required by 40 CFR 112.7(f). In addition, a copy of the training records must also be submitted by the unit or contractor to the DEL Environmental Office(Bldg 1121), or FAX to 255-2058to be kept on file for inspection by regulators.
ISCP TRAINING
The ISCP discusses responsibilities and procedures for response, clean-up, and reporting of oil and hazardous substance spills on Fort Rucker.
ISCP—ENVIRONMENTAL HARM.
The U.S. Environmental Protection Agency and the State of Alabama define a harmful quantity of oil released to the environment as any discharge that: “(1)Violates applicable water quality standards; or (2) Cause a film or sheen upon or discoloration of the surface of water or adjoining shorelines or cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines”. From this, it is apparent that even a teaspoon or less of oil entering any water, including standing or running rainwater, would be considered by the regulators as harmful. Therefore, it is not only important to prevent or clean up actual spills of any size, but it is also important to clean up splashes on the tops or sides of tanks or containers to protect surface waters from contamination through storm water.
ISCP—Initial Response to Fuel and Oil Spills
Defensive actions should begin as soon as possible to prevent or minimize impacts to public health, or to the environment. See ISCP Figure 1.1 for immediate reporting procedures for spills of petroleum products. The general actions listed below, in sequence, must be employed if they can be done safely. Personal safety should always be considered first. If in question, leave action to specially trained and equipped Hazardous Materials (HAZMAT) Response Team:
1.Control the source of the discharge; stop discharge if possible.
2.Eliminate sources of spark or flame.
3.Evacuate threatened individuals.
4.Prevent the discharge of fuel, oil or contaminated water into storm drains, sewer system, or surface waters.
5.Place physical barriers such as berms or dikes to control or stop the spread of the release.
6.Control water discharge, both upstream and downstream of the spill, to prevent spreading.
7.Fence or rope off the contaminated area.
ISCP—Spill Reporting.
Any person causing or discovering a spill or release of oil or hazardous substance must immediately report the incident to his/her supervisor. The supervisor will determine if the spill is minor and should be cleaned up without further notification, or if further notification is required (ISCP, Section 9.6.2). In case a supervisor cannot be quickly notified or in case of a major spill (a spill that threatens personnel safety or may reach surface waters, storm drains, or sanitary sewer drains), the Directorate for Public Safety,Fire and Emergency Services Division must be notified immediately at 911. (Spills that do not have to be reported are those inside buildings, inside secondary containment, or on pavement, if the spill does not have the potential to enter soil or water, and if the spill can be completely cleaned up by the unit without help. Any spill that reaches the soil must be reported to the DEL Environmental Office (255-2541)—the Environmental Office will ensure complete clean-up. Fire and Emergency Services must be called at 911 for any spill that reaches or is in any danger of reaching surface waters—this includes any spill that causes a sheen on any water, including standing or running rain water.)
The employee or supervisor reporting a spill to the Fire and Emergency Services Division at 911 should provide the following information to the extent possible:
(1)Location, time and type of incident (spill, fire, injury, etc.).
(2)Name and quantity of spilled material and the rate of release.
(3)Provide Material Safety Data Sheet for spilled material, if available.
(4)Direction of the spill, vapor, or smoke release.
(5)Fire and/or explosion possibility.
(6)Coverage area of spill and the intensity of any fire or explosion.
(7)The extent of injuries, if any.
The same day as the spill, the unit responsible for the spill must provide preliminary spill information to the Fort Rucker Environmental Office (to the extent that information is known) using the Form in Exhibit 1.1 of the ISCP. All information required by the form must be provided to the Environmental Office within 5 days of the spill. This information is necessary for the Fort Rucker Environmental Office to meet the regulatory requirement to notify regulatory agencies the day of the spill by telephone, and in writing with complete information within 5 days of the incident.
ISCP—PUBLIC SAFEY AND SPILL CONTAINMENT.
The DPS Fire and Emergency Services Division is responsible for Public Safety at a spill. The Fire Chief is in charge of all incidents until he or she has determined the incident hot zone is safe, and can be occupied by non-emergency responders and/or support personnel. Fire and Emergency Services is also initially responsible for containment of spills, until they determine that the site is safe and request additional support from the unit responsible or the DEL Environmental Office. The DEL Environmental Office may call in the DEL Support Services Contractor to assist in spill containment. The Support Services Contractor has a spill response trailer, as well as heavy earth moving equipment that can be used to contain spills.
The DPS Fire and Emergency Services Division is not responsible for spill clean-up. They may assist a unit in spill clean-up, at their own discretion; however, no unit should count on this service. If Fire and Emergency Services does assist in spill clean-up, the unit responsible for the spill is still responsible for collecting and disposing of any and all spill clean-up materials and/or wastes.
ISCP—SPILL CLEANUP.
When Fire and Emergency Services determines that public safety and health issues allow it, the Environmental Office will supervise spill clean-up to regulatory requirements. The unit responsible for a spill is ultimately responsible for spill clean-up. If the unit responsible can effectively complete the clean-up without help or with volunteer support from Fire and Emergency Services, they will be allowed to do so. However, at the request of the unit responsible for the spill or at the direction of the Environmental Office, the DEL Support Services Contractor may be called in to assist in the clean-up effort. The Support Services Contractor may use materials from stock in their spill response trailer and/or heavy earth moving equipment to contain or clean up a spill. The unit responsible for the spill will be expected to pay all costs of materials used for containment and cleanup, any heavy equipment costs, and waste disposal costs. A spill clean-up is not complete until the Environmental Office determines that the clean-up meets regulatory requirements.
ISCP—DISPOSAL OF SPILL CONTAMINATED MATERIALS.
Wastes and cleanup residue generated by small spill cleanup will normally be collected in drums and turned in to DRMO for disposal. The Environmental Office (ext 2541) can provide guidance in turning in any waste created by the clean-up operations. Larger quantities of cleanup materials and contaminated soil can be hauled to the Coffee County Landfill for disposal. Again, the Environmental Office (255-2541) should be consulted on the disposal arrangements, because the Coffee County Landfill limits the TPH of contaminated materials they will accept. In the past, the Environmental Office has made arrangements to send fuel-contaminated soil with a high TPH to an incinerator for treatment.
ISCP—SPECIFIC HAZARDOUS MATERIALS CLEAN-UP PROCEDURES.
The ISCP (Section 12) contains specific instructions for responding to and cleaning up hazardous materials, including: Mercury, PCBs, Flammable and Combustible Organic Liquids, Oxidizers and Organic Peroxides, Acids, and Bases.
SPCC TRAINING
SPCC—GENERAL REQUIREMENTS.
The SPCC Plan, Section 1.8.2, requires: (1) Secondary containment must be provided for bulk storage tanks. (2) Drainage from diked storage areas must be regulated by valves or other positive means to prevent spills or leakage. (3) Diked areas must be emptied of accumulated precipitation; however, the precipitation must be examined for the presence of petroleum products and if present, the petroleum must be removed before water is discharged. Records of all discharges of precipitation, showing that petroleum products were not present, must be kept for three years. This does not apply for double-walled tanks.
SPCC—SITE SPECIFIC SPCC PLANS.
SPCC, Section 4.1 through 4.55 are individual site-specific SPCC plans. These site specific SPCC plans are generally between three and 10 pages long, and consist of: (1) Storage, Drainage, and Spill Prediction and Containment; (2) Transfer Procedures; (3) Security; (4) Administration of the SPCC Plan; (5) Best Management Practices for Sanitary Sewer; (6)Storm Water Pollution Prevention Plan; (7) Recommendations; and (8) Site Drawings showing location of material storage and site drainage. For this training to be complete, all personnel must either receive classroom training on the site specific SPCC Plan for the area where he/she works or must read the site specific SPCC Plan for the area. People who work in more than one area covered by the SPCC Plan must receive site specific training for each area.
SPCC—INSPECTIONS.
The SPCC Plan and Federal Regulations (40 CFR 112.7(e)) require that potential spill areas be inspected at scheduled intervals according to written procedures. Written procedures and records of inspections must be kept at the facility with the site-specific SPCC Plan for three years. The frequency and type of testing must take into account container size and design. Regularly means frequently enough to identify problems and correct them to prevent spills of hazardous waste, hazardous materials or petroleum products. The regulations do not specify a format for inspection records, but leave that to personnel working at the site to meet site-specific needs.
Inspection Checklists. Sample inspection checklists are at the end of this section. They include:
(1)INSPECTION CHECKLIST FOR HAZARDOUS MATERIAL (HAZMAT), HAZARDOUS WASTE (HW), OR PETROLEUM (POL) STORAGE AREAS
(2)INSPECTION CHECKLIST FOR PETROLEUM STORAGE TANKS
(3)INSPECTION CHECKLIST FOR WASHRACKS
These checklists suffice as written procedures and may be copied and used as they are, or they may be customized for individual sites, or some other checklist may be used; however, inspections must be conducted and some form of checklist must be used and kept on record for a minimum of three years.
Frequency of Inspections. Weekly visual inspections will be conducted by personnel assigned to the following areas: (1) storage of hazardous material (HAZMAT); (2) petroleum storage tanks; (3) washracks; and (4) diesel storage tanks for emergency generators.
Personnel of the DEL Support Services Contractor will conduct monthly visual inspections of the approximately 31 tanks (listed in SPCC Section 4.52) used for heating oil storage.
Personnel of the DEL Environmental Office will conduct monthly visual inspections of the used cooking oil containers (approximately 13 units listed in SPCC Section 4.54).
Monthly inspections may also be appropriate for some activities that have very limited quantities of petroleum products in storage, provided that there are very few findings at the facility (no more than one per year) during official quarterly compliance inspections by the Environmental Office.
Inspection Records. At a minimum, each facility covered by this SPCC plan must submit records of monthly inspections to the Environmental Office. They must also keep a copy on file at the site for a minimum of three years for inspection by regulators.
Environmental Office personnel will conduct quarterly inspections of all facilities, and records will be kept for three years.
INSPECTION CHECKLIST FOR: HAZARDOUS MATERIAL (HAZMAT), HAZARDOUS WASTE (HW), OR PETROLEUM (POL) STORAGE AREAS(For use of this form, see Installation SPCC Plan. The proponent is DEL.)
Container storage areas must be inspected weekly and logs must be kept showing dates and time of inspections, and inspection findings.
Location / Printed Name
Date / Signature
1. Containers (drums, cans, bottles, used oil bousers, etc.).
a. Are containers in good condition (no holes, rust, dents, leaks, etc.)? / Yes / No (explain)
b. Are containers kept closed except when adding or removing product? / Yes / No (explain)
c. Are all containers clearly labeled as to contents? / Yes / No (explain)
d. Are empty drums clearly marked "empty"? / Yes / No (explain)
e. Are containers compatible with materials stored? / Yes / No (explain)
f. Are containers handled to prevent spills/leaks? / Yes / No (explain)
g. Are all containers stored where spills or leaks cannot reach sewer drains or areas exposed to rainwater? / Yes / No (explain)
h. Are containers stored where rainwater cannot reach them for Stormwater Pollution Prevention? / Yes / No (explain)
i. Are spills cleaned up immediately and thoroughly for Stormwater Pollution Prevention? / Yes / No (explain)
2. Hazardous Wastes (IF HAZARDOUS WASTES ARE NOT STORED SKIP THIS SECTION)
a. Is HW stored over secondary containment unless dry solids? / Yes / No (explain)
b. Is HW stored so that rain cannot collect in secondary containment? / Yes / No (explain)
c. Is HW stored only in satellite storage area or 90-day storage areas approved by the Environmental Office? / Yes / No (explain)
d. Is HW labeled and stored properly?
(1) HW codes must be listed on HW label.
(2) 90 day site:
- Label must have accumulation date listed.
- 90-day limit has not been exceeded by any containers.
(3) Satellite accumulation site:
- Label does not have accumulation date unless full and ready to turn in (55-gal or more).
- 3-day limit for storage over 55-gal has not been exceeded.
- 55-gal limit has not been exceeded. / Yes / No (explain)
3. Secondary containment for POL, HW or HAZMAT:
a. Is secondary containment free of spilled or leaked materials? / Yes / No (explain)
b. If present in secondary containment, were spilled or leaked materials removed and properly disposed of? / Yes / No (explain)
c. If rainwater collects in secondary containment, is it inspected for contamination and properly discharged? / Yes / No (explain)
d. Is secondary containment valve kept closed except to remove material or rainwater? / Yes / No (explain)
USAAVNC(DEL) Fm 781-1-R, 15 Sep 97
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INSPECTION CHECKLIST FOR PETROLEUM STORAGE TANKS(For use of this form, see Installation SPCC Plan. The proponent is DEL.)
Tanks must be inspected weekly and logs must be kept showing dates and time of inspections, and inspection findings.
Location / Printed Name
Date / Signature
1. Tanks.
a. Are tanks and piping in good condition
(no holes, rust, dents, leaks, etc.)? / Yes / No (explain)
b. Are tanks and valves kept closed except
when adding or removing product? / Yes / No (explain)
c. Are all tanks clearly labeled as to
contents? / Yes / No (explain)
d. Are spills cleaned up immediately and
thoroughly for Stormwater Pollution
Prevention? / Yes / No (explain)
2. Double-Walled Tanks.
a. Was secondary containment checked and
found to be free of liquid (sight glass
or other method)? / Yes / No (explain)
b. Is valve for secondary containment drain
kept closed? / Yes / No (explain)
3. Secondary Containment (not double-walled).
a. Is secondary containment free of spilled or
leaked materials? / Yes / No (explain)
b. If present in secondary containment, were
spilled or leaked materials removed and
properly disposed of? / Yes / No (explain) / No materials present.
c. If rainwater collects in secondary
containment, is it inspected for
contamination and properly discharged at
least weekly? / Yes / No (explain) / No rainwater present.
d. Is secondary containment valve kept closed
except to remove material or rainwater? / Yes / No (explain)
USAAVNC(DEL) Fm 781-R, 15 Sep 97
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INSPECTION CHECKLIST FOR WASHRACKS(For use of this form, see Installation SPCC Plan. The proponent is DEL.)
Washracks must be inspected weekly, and records must be maintained on-site for 3 years.
Location / Printed Name
Date / Signature
1. Containers (drums, cans, used oil bousers, detergent storage units, etc.) stored within the washrack drainage area.
a. Are all containers in good condition (no holes, rust, dents, leaks, etc.)? / Yes / No (explain)
b. Are all containers kept closed except when adding or removing substance? (Bungs in drums must be more than "finger tight.") / Yes / No (explain)
c. Are all containers clearly labeled as to contents? / Yes / No (explain)
d. Are all 55-gallon drums that are empty, clearly marked "empty"? / Yes / No (explain)
e. Are all containers handled properly to prevent spills/leaks? / Yes / No (explain)
f. Are all containers compatible with materials stored? / Yes / No (explain)
2. Are all hazardous wastes in washrack drainage area stored in areas approved by the Environmental Office for 90-day or Satellite Storage? / Yes / No (explain)
3. Secondary containment for materials/wastes stored in washrack drainage area.
a. Is secondary containment free of spilled or leaked materials? / Yes / No (explain)
b. If present, were spilled materials removed, containerized, and turned in as waste to DRMO? / Yes / No (explain)
c. Is contaminated rainwater removed from secondary containment? / Yes / No (explain)
d. Is secondary containment valve kept closed except to remove material or rainwater? / Yes / No (explain)
4. Is there any indication that maintenance is being performed on the washrack, such as aircraft hardware (O-rings, etc.) left lying around, or oil or other petroleum products on the washrack surface or in the drain? / Yes (explain) / No
5. Are sand traps clean and functional? / Yes / No (explain)
6. Oil/Water separator
a. Does oil need to be removed from separator? (If yes, call 255-2988). / Yes (explain)/ No
b. If washrack is not covered, is valve positioned to discharge to storm drain when not washing aircraft? / Yes / No (explain)
c. Is valve positioned to discharge to oil/water separator when washing aircraft? / Yes / No (explain)
USAAVNC(DPW) Fm 781-2R, 15 Sep 97