1 October 2001ORARNG Pam 200-1

Annex Q

SPILL CONTINGENCY PLANNING AND REPORTING

1. Requirement Reference:ORARNG Pam 200-1, Chapter 11

ORARNGR 210-6

  1. Affected Units and Activities:
  1. The following facilities must have implemented a Spill Prevention Control and Countermeasure Plan or equivalent Integrated Contingency Plan in order to meet regulatory requirements described in Chapter 11 and this annex:

-AASF #1, Salem

-AASF #2 and Pendleton Armory

-COUTES

-Camp Rilea

-Camp Withycombe

-La Grande OMS

  1. All ORARNG facilities where mobile fuel-hauling equipment is parked must have a Spill Prevention Control and Countermeasure Plan for the mobile equipment. Affected facilities will change, depending upon applicable stationing plans. However, copies of the SPCCP must be kept with the equipment, as well as on file at the affected facility.
  1. All ORARNG facilities must have on file a completed Facility Spill Response Plan IAW ORARNGR 210-6, unless an Installation Spill Contingency Plan is prepared as part of an ICP for the facility.
  1. All ORARNG units must train personnel to respond to accidental spills or other discharges of regulated materials to the environment, whether the spills or discharges occur at an ORARNG facility, other training sites, or along a public roadway.
  1. Implementation:
  1. AGI-ENV will provide Integrated Contingency Plans (ICPs) to address regulatory requirements for SPCCPs for all facilities meeting regulatory criteria.
  1. AGI-ENV will provide required SPCCPs or applicable guidance for mobile fuel-hauling equipment. Until further notice, a copy of AGO Form SRG1/SRG2 and AGO Form 200-1-10, placed in the logbook of the applicable vehicle, suffices to meet regulatory requirements. Questions or requests for additional information should be addressed to the Spill Response POC identified in Chapter 11 of this pamphlet.
  1. Unless otherwise noted above, the Facility EPOC identified in ORARNGR 210-6 must assist AGI-ENV in completing a Facility Spill Response Plan for each ORARNG facility as soon as possible. These plans must be updated annually NLT 1 Feb of each calendar year.
  1. The Unit EPOC is responsible for spills resulting from unit actions. Spills must be cleaned up and residue appropriately disposed. If the spill occurs inside a building and no escape to the environment occurs, no other action is required. If a discharge to the environment occurs, from either a spill in a building or a spill outside, the spill must be reported to AGI-ENV and cleaned up, if within the capability of the unit, the facility, and the SMW. A spill of any size should be reported. For a spill of a "reportable quantity", the Unit EPOC must notify the Facility EPOC, notify AGI-ENV for reporting to the state and NGB, secure the area, complete a Spill Incident Report (AGO Form 200-1-9), and seek assistance from AGI-ENV.
  1. The SMW is responsible for spills resulting from his/her actions. The spills must be cleaned up and residue appropriately disposed. If the spill occurs inside a building and no escape to the environment occurs, no other action is required. If a discharge to the environment occurs, from either a spill in a building or a spill outside, the spill must be reported. A spill of any size should be reported to AGI-O. For a spill of a "reportable quantity", the SMW must also notify the Facility EPOC. AGI-O will coordinate with AGI-ENV for reporting to the state and NGB. The SMW must secure the area, complete a Spill Incident Report (AGO Form 200-1-9), and seek assistance from AGI-O.
  1. The Unit EPOC, Facility EPOC, or SMW must notify AGI-ENV of any spills discovered during normal operations left by someone else. AGI-ENV will provide guidance on cleanup.

4. Requirement Summary:

  1. A facility meeting criteria specified in ORARNGR 210-6 must be covered by a Spill Prevention, Control and Countermeasure Plan (SPCC). These plans must be prepared under the guidance of, and signed by, a registered Professional Engineer. The plans must be updated at least every three years or when significant change to the facility occur. Plans will be prepared by AGI-ENV, usually under contract with an engineering firm. [Note: EPA allows an Integrated Contingency Plan in lieu of a SPCCP. ORARNG policy is to prepare an ICP in all cases.]
  1. A facility where mobile fuel-hauling equipment is parked must be covered by a Spill Prevention, Control and Contingency Plan (SPCC) prepared specifically for that purpose. These plans are unique in that they stay with the equipment, not the facility.
  1. All units and activities with the potential to spill a “reportable quantity” of a regulated material must be covered by a Facility Spill Contingency Plan (requirements are defined in ORARNGR 21-6). This includes all ORARNG facilities that are not covered by an ICP.
  1. A unit or activity that causes a discharge of a regulated material to the environment at any location, must respond and stop or clean up the spill (or seek assistance), and submit required reports. An SOP may be required to supplement other guidance, depending upon the unit mission and organic equipment.
  1. Spills of hazardous material or regulated substances above the “reportable quantity”, and for which assistance in cleaning up the spill is required, must be reported telephonically to higher headquarters within one hour of the incident, if possible. These spills must also be reported to AGI-ENV. In most cases, AGI-ENV must notify NGB and other federal or state agencies.
  1. A completed Spill Incident Report (AGO Form 200-1-9) must be submitted to AGI-ENV within 24 hours of the incident (may be faxed to 503-584-3584) or on the first working day after the event. The form describes the spill situation in detail, including measures taken to protect the environment and clean up contaminated areas. The information provided in the report is used by AGI-ENV to report to regulatory agencies, if a “reportable quantity” was discharged. However, regardless of the type or degree of spill cleanup performed by those causing or finding the incident, notification to AGI-ENV on AGO Form 200-1-9 must be made. The report will be used by AGI-ENV to document the spill, the agency response, and the disposal of contaminated material. Collected information will also be used in preparing future guidance on preventing or minimizing similar spills.

5. Submittal Requirements:

  1. For facilities requiring an ICP, reports or documentation required by the plan, and by the responsible party identified in the plan.
  1. For facilities not requiring an ICP, a Facility Spill Response Plan must be completed IAW guidance provided in ORARNGR 210-6. Once completed, the plans must be updated annually to ensure they remain current, with a copy furnished to AGI-ENV.
  1. If assistance is required, telephonic notification of spill events must be provided to AGI-ENV or the Staff Duty Officer as soon as possible after the occurrence or discovery. A memorandum for record should be prepared and submitted to AGI-ENV or attached to the Spill Incident Report.
  1. A completed Spill Incident Report (ORARNG Form 200-1-9) must be submitted to AGI-ENV, along with any other supporting information, within 24 hours of, or on the first working day after, a spill event.

6. Documentation Requirements:

  1. Unit EPOC, Facility EPOC, and SMW must maintain a copy of ORARNGR 210-6 (may be electronic).
  1. Unit EPOC and SMW must maintain copies of AGO Form 200-1-9, Spill Incident Report, completed for spill incidents in their areas of responsibility, at this annex. The Facility EPOC should have copies of all reports for all spills at the facility. AGO Form 200-1-9, found at the end of Chapter 11 of this pamphlet, supersedes Appendix J, ORARNGR 210-6 and all other similar forms previously developed for spill reporting requirements.
  1. Unit EPOC, Facility EPOC, and SMW must file the applicable facility ICP at this annex, since it contains emergency procedures for the facility.
  1. Unit EPOC for units with mobile fuel-hauling equipment must maintain a general SPCCP for each vehicle. Plans will be provided by AGI-ENV. Until otherwise directed, keep a copy of AGO Form SRG1/SRG2 and AGO Form 200-1-10 in the logbook of each vehicle to meet this requirement.
  1. Facility EPOC must file a completed Facility Spill Response Plan at this annex for facilities not covered by an ICP. Maintain until updated. Each Unit EPOC and the SMW must have a copy, and implement appropriate provisions, of the FSRP.
  1. Facility EPOC must complete and file a “Facility Coordination Checklist” (Appendix J of ORARNGR 210-6) at this annex. Copies should be provided to all tenant units for filing in their Environmental Compliance Notebooks at this annex.
  1. Unit EPOC must maintain a copy of the ORARNG Spill Response Guide (AGO Form SRG-1) and On-Scene Coordinator Responsibilities (AGO Form SRG-2) in the logbook of each ORARNG tactical vehicle and mobile piece of equipment. These forms are available from AGI-ENV in bulk. They are also available for reproduction at Chapter 11 of this pamphlet (double-sided copy on card stock, cut in half for two documents).
  1. For any spill in their area of responsibility, the Unit EPOC or SMW must file a completed AGO Form 200-1-9 at this annex. In addition, copies of all support information or correspondence on the incident should also be filed. Keep this record for at least three years. [Note: The Facility EPOC should have copies of all completed reports.]
  1. The Unit EPOC must maintain a copy of AGO Form 200-1-10, Spill Response Guide and On-Scene Coordinator Responsibilities, at this annex in order to properly respond to spills during convoy operations or during field training exercises.

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