-------
DC
O

o
^<
LL



^M
IK
N
^J
X

'c
'o
Q.
C
5
03
0
C
o
O)
G)
"co
CO
O
CO

•o
0>

"c
CO


CO
0)

o
CO
0)
D
   o
o
o
ss
Q)
o

oc
 CO
 c
 o
      c
      o
 o
 CO
c$
-------
zl
o
-\
<
cc
111


HI
O
111
1-
co
15
CO
0
O)
T5
J3
0)
4 ^k
CO
CO
0
o
o
Q.
"c
0
E
"co
0
^








CO
c
0
>
0
(/)
•
      CO

      "c
      CO
0
o
c
CO
c
0
a     °
E     ^
^     &
®     c
 CO
 0
 >

'co
£

 CL
 X
 0
                           O)
                           c
 o
ach
                     2
                    jt-
                    CL
        o
        5

        "co
        "0
-------
(/)
LU j=
>o
±+
— CO
H^

••^^
ffl
LU
O
Z

Z
—
5
e
N
<
X
c
o
E
c
0
c
0
-
E
0
1
I
_o
O
0
O












*O
0)
"c/5
o
o
0)
o
3
•o
0)
oc


UTC
•:= o
CO-—
5*2
CO
0 t
s °
£ Q.

.t± Q.O
tit
o o-o
1 1 1
O)

B_

o
CO
*5
c
CO
B
0)
"SJ
o
o
_£)
o
o
s
'•ZZ
owers
J
                                   11-9
-------
HI
111
en
m
<
Q
N
<

X
0)
T3
0
0
CD
(A
CD
Amount
(gal/yr)
O
a
o
«•
C/)
a
Z
c
en •
^ Proces
escripi
»_
«
c
$
O
0)
c
•o
~
CO
E
3
z







o
0
CM

Paint
Residue

o
CO —
i- C
Q.—
^0.

N
X


CO
CM
T™
r-








O
O
0
«
o
o
0

0
>*

o
CD



00

n





















rr
.




















in

                      11-10
-------
                     §03
                 J O . I ! -
                 X 2 •§ • ? *
                . O — i ^ ? i

                -lilMI
                ;;siii!i"
                                      r
                                      u
 111

a 55
uj
ec
o
UJ
5
* ^ »

ill
r S?
              UJ
              UJ
              a:

              UJ
to • |Noc

•ulltMul
                     0
                       —
                        •
                 a: ^

                 < o
                 S u!
                                 11
                       u
                       u
                       >
                                      3


                                      V^
              11-11
-------
                                  co
                                       co
DC
O
LL,
LL,
LU

LL
O

LU
O
<
          O
          LL
          DC
           o
CO
LU
H
_J
O
<
LL co
H DC
Z O
LU H
                   < LU<
                   LU ZLU
                   DC LUDC
                   HC5fc
                   MI   CO
                   H^LU

                             uj   o
                               O)
                LLJ
                (0
                                        O   Q
                                       CO
UJ
O)
                                            CM
                                              II
                                             UJ
                                             O
GC
UJ
                          11-12
-------
CO
o
Q.
o
CE
O
O
<
Q
LLJ
O
O
111
DC
           Q.
           LU
           LU
                  LU
                  (0
Q.
           O
O
                     CO
                     LLJ

HI
                     HI
                     O
                                       111
                               Q.
                               O
                                       111
                                LU
                                O
           O
           DC
           LLJ
           CO
           LU
           DC
                    11-13
-------
11-14
-------
Q
L
PAINTS
OPEN BURNING ASH
METAL PARTS RESIDUE
REATMENT PLANT SLUDGE
t$ FOR NEW ITEMS DISPOSAL • TCLP
t FOR WASTE TREATMENT- LAND BAN
                                            11-15
-------
DC
2
LU
OC
IT
0
Lil
DC
>
oc
<
o
z
<

o
LU
^

(/>
UJ
CO
<
I
0.
«—
^
<
cc
o
o
cc
Q.
Z
g
N
<
X
*
(/>
O
H
<
Q
Z
UJ
RECOMM
z
*!
N
<
X
*




UJ
2
H
O
f A
W/
s
o
o
*



o_
<
DC
H
NMENTAL
O
DC
>
LU
*
                             11-16
-------
12.1   WORKSHOP E: SPILL PREVENTION AND RESPONSE
12.2  ATTACHMENTS
           Newsweek Article - "The Military's Toxic Legacy"
           Spill Prevention, Control, and Countermeasure (SPCC) Information Guide
-------
12.1   WORKSHOP E: SPILL PREVENTION AND RESPONSE

Vincent F. Zenone. On-Scene  Coordinator, Hazardous Waste Management Division, EPA-
Region III.

       Mr. Zenone presented an overview of Spill Prevention Control and Countermeasure
(SPCC) regulations.  Regulations will become more stringent in accordance with the new Oil
Pollution Act.  Federal facilities are not exempt from the rules and regulations of the SPCC.
In fact, if the regulations are not followed, the facilities are likely to be in the public limelight.

       The Oil Pollution Act was previously called the Clean Water Act.  The SPCC deals
specifically with oil.  There are three basic concepts inherent to the SPCC.  The regulation that
promulgates a facility under operation developing an SPCC plan is 40 CFR 112 (EPA's Oil
Pollution Regulation).  The basic concepts are prevention, control,  and countermeasure.  A
number of facilities in Region  III tend to clump  these three concepts in  various manners.
Prevention is what a facility does to  prevent a spill from ever occurring in the first place.
Controls are engineering and operational procedures that would control a  spill if it occurred.
A spill is any unplanned discharged, emission,  or leak.  A discharge is a spill which threatens
or enters into surface waters of the United States or adjoining shore lines. Countermeasures are
what you do if the spill occurs on the facility and is contained by  the controls or escapes the
controls.

       Information guidelines has been put together for EPA Region in.  In Region III, virtually
every type of facility requires a SPCC Plan (40 CFR 112).  Criteria for 40 CFR 112 are as
follows:

             Above ground in a single tank in excess of 660 gallons.
             Above ground/aggregate storage in excess of 13,020 gallons.
             Underground storage in excess of 42,000 gallons.

       These three criteria can be intermixed in any manner. As soon as a facility meets the
minimal requirements, all the oil storage areas  need to be addressed in the SPCC Plan.

       The SPCC  Plan must be  developed by the owner/operator of the facility.  A certified
professional engineer must  certify the plan indicating that it was drawn up with engineering
practices in mind and is in conformance with regulations. The SPCC Plan should be a working
document.

       40 CFR 114 defines the civil penalties that EPA will access if a facility is in violation
of 40 CFR 112.  The U.S. Coast Guard mandates that the National Response Center be notified
whenever a spill event occurs at a facility.
                                         12-1
-------
       The SPCC will inspect private industry unannounced. They will inspect federal facilities
on an  announced basis. SPCC inspections are not time dependent,  for example,  spills and
discharges could happen at any time due to equipment failure.
George W. English. On-Scene Coordinator, Hazardous Waste Management Division,  EPA-
Region HI, Philadelphia, PA.

       Mr. English presented slides of  several superfund sites and discussed  proper spill
prevention and response activities.  The first site covered a city block and was a storage site of
11,000 drums of surfactants, oxidizers, propane, ether, acids, costics, thousands of lab jars, and
other hazardous substances.  The site took one year and 3 million dollars to clean up. The site
was  located in a heavily populated, industrial area near Delaware Avenue and 1-95 in central
Philadelphia.   Therefore,  an extensive air monitoring  program was put  in place. Extensive
precautions always need to be taken to prevent contamination (assure zero exposure) of any
worker cleaning up the site and precautions need to be taken for possible problems encountered
in clean up efforts such as faulty packaging, spontaneous fires, and  unknown chemicals.

       During clean up efforts an estimation of the likely harm to the community needs to  be
made.  This consists of coordinating and protecting the  community and viable resources  in the
area and of protecting yourself and others.

       The second example presented was a hazardous waste site consisting of 5 million burning
tires.  Each tire had the potential to release  up to 7 quarts of oil.   Therefore, there was the
possibility of groundwater contamination. To resolve this problem, a large pit was dug and a
pipe was installed where the oil could be collected via filter fence. Other problems encountered
were lack of water,  large amounts of soot in equipment, heat, and remaining steel belts.

       In the third example,  the hazardous problem was oil coming out of a sewer outlet in the
Schuylkill River. Coast Guard  approval and  contractor involvement was necessary.   Local
emergency planning commissions were also needed to track down the source of the spill.

       Mr. English emphasized  the need for  training  seminars and site  plans of all federal
facilities.   Trained personnel need to find parties responsible, and call  in experts for each
specific project when necessary.  First responders need  to be aware of the hazards so they can
properly assess the site. Damage needs to be assessed and an incident commander needs to be
designated.  For example, the fire chief is the commander in EPA Region HI.  For federal
facilities, this would be different. Informational input and safety recommendations must be  on
hand at each federal facility in the event of a hazardous occurrence.

       Who gets to clean it up?  Each time the EPA goes onto a site, they have the authority
to spend a certain amount of dollars to immediately initiate clean up.   Clean up contractors need
to be in place for each federal facility.  Emergency preparedness  is the key. If you have a
                                          12-2
-------
problem and you are not sure how to deal with it, call the EPA for evaluation of contingency
plans and training of first responders.

       Training consists of OSHA/EPA regulation education.

              1.     General hazardous awareness (4 hours)
              2.     Police (8 hours)
              3.     Operations level (16 hours)
              4.     Emergency Medical Staff (16 hours)
              5.     Response in a defensive fashion  (16 hour course)
              6.     First responder technician (24 hour course)
              7.     Specialist in incident command
                                         12-3
-------
  NATIONAL  AFFAIRS
 The  Military's
 Toxic   Legacy
 The cold war buildup fouled thousands of acres.
 Now the Pentagon faces a costly fight to clean up.
 BY BILL TURQUE
 AND JOHN MCCORMICK

 BHBo the victors in the cold war go the
  • spoils—and the spoilage. It's in
  H the form of fouled soil, contami-
  H nated drinking water and acres of
  Hi wilderness pocked with unexplod-
 ed bombs. The Pentagon's arsenal, assem-
 bled over 40 years to keep the lid on super-
 power conflict, has  left  deep scars on the
 home front While a generation of new
 laws and a growing environmental con-
 sciousness  are bringing private industry
 to heel, the Department of Defense a
 America's  moat pervasive and protected
 polluter.
  Now, as budget cuts draw down the mili-
 tary, the United States must confront a
 daunting post-cold-war cleanup. The mili-
 tary's 871  domestic installations, strung
 across 25 million acres of land, produce
 more tons  of hazardous waste each year
 than the top five U.S. chemical companies
 combined. Department of Defense reports
 document 8,000 sites that may require
 some form of environmental restoration, a
 task that could take 20 years and $20 bit-
 lion, or more. The issue will gain momen-
 tum early next year when the first of 86
 military bases, targeted for cost-cutting
 closures, begin to shut down. Contaminat-
 ed ground  water, unlined beds of toxic
 sludge and porous, carelessly constructed
 landfills make their conversion to civilian
 use problematic—and expensive. The coot
of their restoration could easily eclipse the
$5.6 billion in savings the closures were
expected to yield over the next two dec-
ades.  "Next to outright conflict itself."
says Rep.  Richard Ray, of the House
 Armed Services Committee, "this is prob-
ably the No. 1 priority the Defense  De-
partment has to face."
  The Pentagon is legally bound to clean
the bases before they are sold. But many
will be shut for years before they are put
 right. The  size of the  task, a plodding
bureaucracy and military reluctance to
commit its dwindling largesse to mopping
up, will add yean to the conversion. Some
communities fear a double economic hit:

20 NEWSWEEK : AUGUSTS. 1990
the loss of a military base and environmen-
tal barriers that couid keep the sites from
productive reuse. "That is not what people
had in mind when they gave up the proper-
ty for national security," says New Hamp-
shire Rep. Robert Smslh.
 The military's u»xic inventory is bound-
ed neither by geography nor size; it in-
cludes notorious big messes and nasty little
surprises. The Rocky Mountain Arsenal, a
27-scuar»~rr,u» complex in metropolitan
Denver, was a laboratory for some of the
Army's most deadly alchemy—the produc-
tion of nerve gas. Once an economic boon
and & source of local pride (ARSENAL MEANS
                                Hasty swvrisis: Collecting
                                     Capyri&ti 1990
                                     Newsweek, Inc.
                                     All Rights
                                     o ,,	•_». i
-------
                       IJi AHMYCOWSOf KWUNKKKd
sort on f he Vineyard (top), warning in Denver
 DEATH FOB FOBS, AID TO DCNVKK, CTOWed a
 1964 headline in the The Denver Post),
 the plant produced a soup of chemical by-
 products lea in vast holding ponds. Last
 year visitors to South Bench at Martha's
 Vineyard found military teams cautiously
 sifting through sand dunes to collect 1,500
 old ordnance shells. The Massachusetts re-
 treat was once a World War II practice
 bombing target Startled islanders who
 had hauled the stray rounds home as oddi-
 ties dragged them back for inspection by
 military munitions experts.
  Nowhere in this country is the Penta-
 gon's environmental nightmare more vivid
 than at the Army's Jefferson Proving
 Ground (JPG) in southern Indiana. Since
 1941 workers have test-fired 23 million ar-
 tillery, mortar and tank rounds across 90
 square  miles  of  forests  and  wildflower
 meadows. An estimated 1.4 million of those
 test rounds haven't exploded—yet. The re-
 sult  is a wasteland layered with  deadly
 debris. Shells protrude menacingly from
 the ground; others have burrowed as far as
 24 feet below. There are also armor-pierc-
 ing rounds made of radioactive uranium
 and munitions containing white phospho-
 rus,  which ignites on contact with air.
 "Poke your nose in the Army's business
 and  you might disappear,"  says Jane
 Hance, whose farmhouse windows rattle
 with the thunder of steady cannonades.
 "They don't even know what they've got
 over there."
  Now Jefferson is on the Pentagon's clo-
sure list, but extracting this ordnance will
 be no day at the beach. Shutting down the
 range will save the Pentagon about $7 mil-
 lion a year. Cleanup estimates run into the
billions. A study commissioned by Indiana
officials cays it would take $550 million just
 to minimally sweep the site for a wildlife
 preserve. Even if money were  no  object,
 DOD officials all but admit they could nev-
er extract nil the ordnance. Townspeople
 fear  a mothbnlled parcel that would be
forever treacherous.
                                     A Trail of Defense Pollution
                                         Generating hundreds of thousands of tons of hazardous
                                         waste yearly, the military is the nation's most pervasive
                                     and protected polluter. Some of the wont sites:
  More than safety is at stake. Good jobs
 like the 410 civilian positions at Jefferson
 are hard to come by in nearby Madison, a
 picturesque Ohio River town. Mayor Mor-
 ris  Wooden peppers Congress with mail-
 ings that detail the absurd cost-benefit of
 the closing, stamping the word STUPID in
 red across the top of each. "Grade-school
 math tells you the Army won't want to
 remove this unexploded ordnance." &ays>
 Wooden. "But we are determined not to iet
 them walk  away from the ground they
 seized 49 years ago."
  Dwate stsatoa: A curious double standard
 protects the Pentagon from vigorous envi-
 ronmental regulation. Ambiguities in fed-
 eral law have prevented some suite and
 local governments from levying civil fines
 against military facilities that violate haz-
 ardous-waste laws. Moreover, the Environ-
 mental Protection Agency does not file civ-
 il suits against other federal departments
 to enforce its regulations; the Justice De-
 partment, which would bring any action on
 EPA's behalf, says the Constitution pre-
 cludessuch suits. It insists that EPA rely on
 voluntary agreements that can take years
 to negotiate. The result is that cities and
 states,  which  must comply with federal
 standards at their own sewage-treatment
 plants, have limited recourse when Uncle
 Sam pollutes.  Two bills pending in Con-
 gress would strengthen EPA's hand and
 allow states to penalize federal polluters.
  The Pentagon is hardly alone among fed-
 eral agencies in slovenly environmental
 practice. The Department of Energy, the
 other custodian of the cold-war arsenal.
 faces a 30-year program to clear radioac-
 tive waste from its 17 plants and labora-
 tories. But while DOE's problems may be
 more notorious, the military's mess is more
 diffuse. Many of the hot sites are at large
bases, but others are wedged in asprawling
 infrastructure of obscure arsenals, depots
and plants. Ninety-two Pcntni;on facilities
 are on, or proposed for addition to.  EPA's
Superfund list. "These places produce ma-
          terials designed to kill people."
          says Mark Schmitt, a soil spe-
          cialist with the Minnesota Pol-
          lution Control Agency. "It's not
          surprising that their byprod-
          ucts are often toxic."
            The Pentagon says that after
          a slow start, it is beginning to
          make peace with the environ-
          ment "Westarted from further
          down the hill, but I look at the
          progress we've made over the
          last couple of years," says Da-
          vid Berteau, the Defense De-
          partment's  top environmental
          official. But EPA and congres-
          sional  regulators say  DOD's
          budget doesn't reflect the rhet-
          oric. The   White  House is
          proposing $817 million for envi
                          JAMHOnOK
                                                        12-5
                                                                                           NEWSWEEK : AUGUST 6. 1990 2'
-------
  NATIONAL
ronmentai restoration in 1991, up more
than 30 percent from this year but still lea
than .3 percent of the total Defense budget
(Congress is expected to add more). They
talk about the environment Cheney puts
out memos, but the reality is, are  they
budgeting  the money?" asks one House
committee staffer.
  Years of red tape and bureaucratic jaw-
boning often delay cleanups.  For  three
years  U.S. Rep. James Saxton has tried
         to get the Air Force to treat several acres
         of his New Jersey district that were con-
         taminated by plutonium in I960 when a
         Bomarc missile warhead caught fire. The
         military is willing, the task relatively in-
         expensive, but nothing has happened. "I
         think we've dealt with nine federal agen-
         cies to iron out details," he laments. "We
         get report after  report But nobody does
         anything."
          The military's penchant for secrecy and
                                       devotion to standardized procedure have
                                       slowed the growth of environmental con-
                                       sciousness. Some critics say the old cold-
                                       war attitude has improved, but that the
                                       Pentagon is still way behind the learning
                                       curve. "DOD installations are what the oil
                                       and chemical  industries were 15 years
                                       ago," says Shira Flax a toxics expert at the
                                       Sierra Club.
                                         Too often military intransigence poses
                                       the greatest ecological threat Riverside,
   In Tucson, 'We Were Victims of War'
       Mission Manor sprang up
       on Tucson's  south side
   after World War II, growing
   into a comfortable working-
   class community where His-
   panic  and  Anglo  families
   could buy their first homes.
   There were good jobs nearby:
   US. Air Force Plant 44 was
   thriving. Opened in 1961 and
   run for the government by
   Hughes Aircraft, the sprawl-
   ing  factory  in the  Sonoran
   Desert  turned out nearly
   600,000 missiles over the next
   40  years, including TOWs,
   Mavericks and Phoenixes.
    Built to destroy distant ene-
   mies, the weapons may also
   have been hazardous to Mis-
   sion Manor. Residents charge
   that Hughes dumped decades'
   worth of dangerous chemicals
   into the arroyos  and  ponds
   surrounding AFP 44, poison-
   ing the neighborhood's drink-
   ing water and producing high
   rates of cancer and other ill-
   ness. A  five-year-old  law-
   suit—amended  last Novem-
   ber to add new plaintiffs—is
   pending. "Even  though we
   didn't go to war, we were vic-
   tims of war." says Rose Marie
   Augustine, whose  husband
   has bladder cancer.
    Hughes officials refuse to
   discuss the suit In court docu-
   ments and congressional tes-
   timony the company denies
   causing any illness and says
   past  disposal  practices  fol-
   lowed regulations in force at
   the time.  It adds  that other
   companies in  the area also
   contributed to toxic-pollution
   problems. EPA reports depict
   a witches' brew of chemical
   waste at Hughes. Before it in-
   stalled a modern treatment
system in 1977, it discharged
15,000 gallons of chrome- and
cyanide-contaminated water
into the desert each week. It
also used the solvent trichlo-
roethyiene (TCE)—a suspect-
ed carcinogen. By 1981, the
damage was impossible to ig-
nore. A water sample at the
plant  revealed TCE at more
than 900 times the safe maxi-
mum.  Later that year the
city closed six wells with high
TCE levels.
  That caught Melinda Ber-
nal's attention. Former high-
school classmates in Mission
Manor, under 30 and in ro-
bust  health,  were   falling
desperately ill. City officials
insisted  that south  aiders
were not at risk from TCE.
                    But in 1986 The Arizona Dai-
                    ly Star confirmed the worst
                    the  neighborhood  had con-
                    sumed TCE-laced watar for
                    yean.  The   paper  found
                    five  types of cancsr on the
                    south side—including leuke-
                    mia and testicular tumors-—
                    at rates above national norms
                    for certain age groups. A Uni-
                    versity of Arizona  study of
                    1,200  children  treated for
                    heart disease  in Tucson be-
                    tween 1972 and 1986 found
                    elevated rates of congenital
                    defects in those with parents
                    exposed to the TCE-contami-
                    nated area.
                     If  ksa*  Official  response
                    was  timid  and indifferent
                    State officials challenged the
                    evidence, while  local politi-
-JJi *•-••- •„.
Stfj^-uw.- :.•;•' .« •
                           N
<£<
                         44
                                              '®§*
dans, reluctant to alienate a
big employer, made them-
selves invisible. Officials lec-
tured  residents  on  their
unhealthy lifestyles. "They
called us hysterical Hispanic   i
women," says Sally Rendon,
whose son had a five-pound
tumor removed from his leg.
Neighbors who also worked
at  AFP  44  feel  doubly
violated.  Marie  Sosa, who
scrubbed missiles by  hand
with TCE,  says  co-workers
were frequently overcome by
fumes. "You could smell the
chemicals," says Sosa, who
had breast cancer in 1984.
  Procedural wrangling has
slowed the cleanup. The Air
Force has pretty much fought
us every step of the way," says
Dan .Opalski, regional EPA
project  manager. In  1987,
Hughes  added a system to
pump and clean 26 billion gal-
lons of ground water near the
plant The $30 million project,
paid for by the Air Force, will
take at least a decade. Plans to
decontaminate Mission Man-
or are still in limbo.
  With  budgets declining,
AFP 44 faces an uncertain
future: the Phoenix and Mav-
erick are not in the 1991 Pen-
tagon budget The Air Force
wants to sell, but there's no
market for a missile factory
with toxic chemicals under-
fdbt Illness and poverty from
heavy medical bills have di-
minished Mission Manor. The
case may go to trial next year,
but no one has any illusions
about the law. "A lot of people
went into this knowing they
wouldn't be alive when it was
resolved," says Bernal. "But
they wouldn't stand by and
allow their community to be
poisoned."
                    i Tuan*
                                                     12-6
-------
 Calif., officials discovered toxic
 waste in wells near the perime-
 ter of Norton Air Force Base a
 decade  ago; the  installation
 sits atop the Bunker Hill aqui-
 fer, primary source of drinking
 water for the desert city  50
 miles east of Los Angeles. Con-
 cerned  that an  underground
 plume  of  trichlorocthylene
 (TCE>—an  industrial  solvent
 and  suspected  carcinogen—
 might pollute the  municipal
 water supply, the city  asked
 for quick action. The EPA add-
 ed Norton to its Superfund list
 in  1987, and city officials be-
 lieved the problem would  be
 resolved with dispatch.
  They  were wrong.  Instead,
 EPA  and Air Force  officials
 spent two years haggling over
 how to investigate the extent
 of the pollution. "It was just
 appalling," says  Riverside at-
 torney Roger  Luebs,  part  of
group  monitoring  the
                                   harder vt took, the
               wt fmf: Treating contaminated water in Minnesota
                             a citizens
                        dispute.  "EPA
 would send them letters saying the test
 you propose is  unsatisfactory. The Air
 Force would sit on it and then send back
 another letter.  Just back and  forth."
 Meanwhile, another problem cropped up:
 uranium in the well water. Some suspect a
 leak in the concrete tomb under the llth
 tee of the base golf course, where workers
 buried radium once used to illuminate air-
 craft cockpit dials.
   'tmt art tratt': Air Force officials say
 technical complexities and a sluggish EPA
 hindered the cleanup. Last summer the Air
 Force Anally agreed to install a $42 million
 "pump and treat" system by 1991 to inter-
 cept the plume and decontaminate the
 ground water—a process that could contin-
 ue for more than a decade. Norton will close
 in 1994, and the Air Force says it is commit-
 ted to completing the task.  But Riverside
 residents worry about what happens if the
 contamination proves more serious than
 first thought "What they think gets the job
 done may be a lot less than what's  really
 needed," says Luebs.
  Riverside is actually lucky. Because of
 Norton's Superfund status, it will get first
shot at the Pentagon's environmental mon-
ey. Only a handful of bases earmarked for
closure, however, will enjoy such priority.
The Pentagon says there are more serious
problemsatscoresofbases that will remain
open. Under its "worst first" system, those
facilities will get the lion's share of the
funding. But Congress, worried that slow
cleanups will threaten economic redevelop-
ment in their districts, wants the Pentagon
to move faster. California Rep. Vic Fazio is
sponsoring a bill that would add $82 million
to help bases earmarked for shuttering. The
measure is likely to be included in the
House version ofthe 1991 Pentagon budget
  Even bases with Superfund designation
will be shut long before they can be cleaned.
First on the closure list is Pease Air Force
Base near Portsmouth, N.H., north of Bos-
ton. State officials hope it can be converted
to light industry, a convention center and
a coastline wildlife refuge.  But it boasts
some 20 waste sites, including toxic sludge
dumps and a fire-training area that was
repeatedly drenched with jet fuel and set
ablaze. Pease will close next March; while
decontamination at the worst sites on the
base is underway, it will be 1994 before the
Air Force even has all the problems diag-
nosed. Some 500 of Pease's 4,254 acres will
probably be cordoned oft" for yean—a pros-
pect creating congressional headaches for
the  EPA. "Redeveloping Pease  is the
New Hampshire delegation's big project,"
says one agency official. "We're satisfying
them—for now."
  The tug of war  between environmental
and economic concerns may grow more
tense, partly because the term cleanup is a
misnomer. While the worst sites might
eventually be suitable for limited surface
uses, they will never be completely safe.
Even the military's success stories can
leave frightening legacies.
  Near homes at the fringe of the Twin
Cities Army Ammunition Plant (TCAAP)
north of Minneapolis-St Paul, brightly
colored well caps sprout from the ground,
marking the water-monitoring stations.
For decades plant workers hauled toxics
to sites bluntly marked  DUMP on Army
maps. The liquids sank through 150 feet of
sandy soil to the metropolitan area's main
system of ground-water aquifers. In 1981
the  state confronted the  Army with evi-
dence of poisoned municipal wells. The
Army reluctantly began a cleanup of the
soil and ground water that mil   '    •"'•
years, maybe longer.
  Neighbors have adjusted. Pubk  u.&^t
ings that once drew large, angry thrvm&i to
discuss the plant's hiotory of polluuca jicsw
draw only handfuls of enviromwpi*i gad-
flies. And state officials say they are satis-
fied with the Army's progress, although
other toxic sites at the plant are still being
identified. "The harder we look, the
we find," says Mark Schmitt, who ov«
the project for the  state. Yet  mth . ach
small improvement at the facility. M sur-
rounding suburb wants to appropriate  a
piece of the land for its own ua*.  Some
neighbors envision  a sports complex  of
baseball diamonds and soccer seidz But
the prospect of kids kicking up :. !«>8 vas
Schmitt queasy. "We're not intewated in
anything  that  would bring big c-^-nds
here," he says.
  The dimensions of the miii'«> n «•..*! vi-
ronmental quagmire keep wid?*., iu;  As its
budget shrinks, the Pentagon vwj w to add
4.5 million acres to bases in Weste.-1\ states,
arguing that the broader reach of Modem
weaponry like  the  F-4 bomb*- «i.*l the
Bradley Fighting Vehicle  r*-^...
space for testing and training.w i
acres was once enough for a Wo. •!.
style tank and infantry extrci.v
generals say they now need 8G,SAtG
ers and environmentalists— nevei
lies—have been fighting what Uu -
a massive land grab at a tim?  n
military should  be  scaling dt*v.,
what is happening now as a CPK  •
building," says Robert Fulke^ •••-..,
zens Alert, a Nevada watchdw
pansion, they fear, will do mun than in
crease the military's presence It^Mioper
new  frontiers  for what has !«osf txser.  i
reckless stewardship of the \&r&       I
                                                                                                                 inore
                                                                                                                 4/.XX)
                                                                                                                 «r II-
                                                                                                                <»*al-
                                                                                                                sew as
                                                                                                                .• Citi-
                                                                                                              (Hip. £x-
                                                      12-7
                                                                                       NEWSWEEK : AUGUS't
-------
UNITED STATES
ENVIRONMENTAL
PROTECTION AGENCY
                                        July 1990
                                          REGION III

                                         EMERGENCY
                                          RESPONSE
                                           TEAM  .
REGION III                  Western Response and Oil Enforcement Section (3HW32)
841 CHESTNUT BUILDING
PHILADELPHIA, PA 19107
          SPILL PREVENTION, CONTROL,
                        AND
                COUNTERMEASURE
                       (SPCC)
               INFORMATION GUIDE
                           12-8
-------
                        TABLE OP CONTENTS
The SPCC Plan

Key Points of Prevention Regulation

Questions Frequently Asked

Appendix A ... Certification Information

Appendix B ... Example SPCC Plan

Appendix C ... Dike Designs

Appendix D ... 40 CFR Part 110

           ... 40 CFR Part 112

           ... 40 CFR Part 114
                                                             Page

                                                                1

                                                                5

                                                                8
Appendix E

Appendix F
Appendix G  ... 33 CFR Part 153.201
                             FOREHARD
This document provides information to assist with the development
of Spill Prevention, Control, and Countermeasure Plans  (SPCC
Plans) as required under Title 40, Code of Federal Regulations,
Part 112 (40 CFR Part 112).  The information contained here has
been compiled from existing Regulations, EPA documents, and other
guidance documents.  This  document should not be relied upon as
the sole source in developing a site-specific SPCC Plan; however,
it is intended to be used  as * guide in explaining the SPCC
Regulations.  40 CFR 112,  which is included in Appendix E, is the
ultimate standard against  which SPCC Plans will be judged.  40
CFR 112 should be used as  the primary guide in developing SPCC
Plans.
                                12-9
-------
                          THE SPCC PLAN
BASIC CONCEPTS

     There is no rigid format for an SPCC Plan.  The guidelines
in the Code of Federal Regulations (40 CFR Part 112) state that
the SPCC Plan be a carefully thought out plan, prepared in
accordance with good engineering practices, and which has full
approval of management at a level which has the authority to
commit the necessary resources.

       The SPCC Plan should clearly address the facility's
operating procedures which have been installed to prevent the
occurrence of oil spills.

       The SPCC Plan should clearly address control measures
installed to prevent a spill from entering the navigable waters.

       The SPCC Plan should clearly address counter-measures - the
plan of action to contain, cleanup and mitigate the effects of an
oil spill which impacts navigable waters.

SPILL PREVENTION

       Operational errors and equipment failures are the primary
cause of spills; therefore, the SPCC Plan should contain measures
designed to avoid these errors and failures.

       Operational errors can be minimized through adequate
supervision of facility process, personnel training and operator
awareness of the imperative nature of spill prevention.

       Management must be committed to spill prevention and must
develop and enforce techniques for safe and efficient operation.

       Equipment failures can be minimized through proper  initial
selection, construction, maintenance of structural  integrity  and
function, and frequent inspections  (visual and mechanical).
Industry standards and sound engineering practices dictate the
proper course of action  in each of these areas.
                               12-10
-------
SPILL CONTROL

       In EPA Region III, we are generally concerned with spills
from facilities where positive containment devices and systems
are practical and effective.  Dikes, retaining walls, curbing,
spill diversion ponds, sumps, etc.  fall into the category of
positive containment.  Only where "impracticability" to provide
positive containment can be clearly demonstrated does the
facility have the option to take the "contingency" plan approach.
Impracticability to provide positive containment alludes mainly
to those cases where severe space limitations may preclude
installation of structures or equipment to prevent oil from
reaching water.  Justifying "impracticability" on the basis of
financial considerations is unacceptable because the required
commitment of manpower, equipment, and materials to expeditiously
control, remove, and dispose of spilled oil would not normally
offer any significant economic advantage over providing positive
containment.

SPILL COUNTERMEASURES

       Contingency plans are considered "reactive".  They
generally describe after-the-fact actions and can only be
expected to mitigate the effects of a spill after it occurs.
Therefore, spill prevention and spill control must be given first
priority consideration in the preparation of the SPCC Plan.

ELEMENTS OF SPCC PLAN

       While each SPCC Plan is unique, there are certain elements
which may be included almost without exception to make the SPCC
Plan comply with the provisions of the Regulation.  These
elements include, but nay not be limited to, the following:

   1.   Name of facility - This may or may not be the business
       name.

   2.   TV-PC of facility - This briefly describes the business
       activity.

   3.   Data of Initial Operation - The date that the facility
       began operation.

   4.   Location pf the facility - This nay be a word description,
       or city address which can be supported by area naps.

   5.   Name and Address of Owner - This is often an address
       renote fron the facility location.
                               12-11
-------
   6-  Designated Person Responsible for Oil Spill Prevention
       Each facility should have some person with overall oil
       spill responsibility.  This person should be thoroughly
       familiar with the Regulations and the facility's SPCC
       Plan.

   7.  Oil Spill History - This section can be either a reactive
       declaration, or a detailed history of significant spill
       events which occurred in the twelve-month period prior to
       the publication of the regulation (December 11, 1972 to
       December 11, 1973).  In the latter case, typical
       information would include:

          a.  Type and amount of oil spilled,
          b.  location, date and time of spill(s),
          c.  watercourse affected,
          d.  description of physical damage,
          e.  cost of damage,
          f.  cost of cleanup,
          g.  cause of spill, and
          h.  action taken to prevent recurrence.

   8.  Management Approval - This ia a signed statement of a
       person with the authority to commit management to
       implementation of the SPCC Plan.

   9.  Certification - This is a statement of SPCC Plan
       certification under the seal, signature, State and
       registration number of a registered Professional Engineer.
       The certifying engineer is not necessarily registered in
       the State in which the facility is located.

NOTE;  All of the aforementioned information (elements 1 through
       9) may be presented on a single page of an SPCC Plan  As
       an example, a sheet entitled "Certification Information"
       is included in this information guide as Appendix A.

  10.  Facility Analysis - A portion of the SPCC Plan should
       include a description of facility operation which would
       generally indicate the magnitude of spill potential.  For
       example/ the amount and type of storage, normal increments
       of transfer or pattern* of usage, distribution, processes,
       •te.  Zn this analysis the direction of flow of spilled
       oil should be indicated along with any  factors which are
       pertinent or influence spill potential.  It is appropriate
       to support this type of information by  charts, tables,
       plot plans, etc. to aid clarity or promote brevity.
                                12-12
-------
  11 •  Location  of  F^eiiitiy  - The geographical  location  is an
       integral  part of the  SPPC Plan.  Location and topographic
       maps can  be  critical  in determining the  adverse
       consequences of an oil spill,  sources for  such maps
       include:   (i) U.S. Geological Survey,  (2) State Highway
       Department,  (3) County Highway Engineer,  (4) Local Land
       Surveys,  and (5) City Engineer.

  12.  Facility  Inspection - An inspection report  covering the
       facility  in  terms of  equipment, containment, operation,
       drainage,  security, etc. may provide essential information
       necessary to formulate the SPCC Plan.  Such reports could
       reasonably be incorporated as part of the SPCC Plan.  This
       kind of report would  best serve in the more complex
       facilities and is not considered necessarily an element
       common to all SPCC Plans.

  13.  Review of the SPCC Plan - The SPCC Plan  must be reviewed
       by the owner/operator of the facility at least once every
       three years.  This review must be documented.

SPCC EXAMPLES

Several industrial  trade associations have developed suggested
SPCC Plan preparation guideline* for use by their  members.
Generally, these guidelines  were developed for  a particular
type of facility and have been very helpful.  However, care
should be exercised not to rely completely on any  stereotyped
format.  Each SPCC  Plan is unique to the facility  and requires
individual thought  processes and tailoring to spill potential
specific to the  facility.

       The American Petroleum Institute has prepared a bulletin
entitled "Suggested Procedure for Development of Spill Prevention
Control and Countermeasure Plans"  (API Bulletin D 16).  This
bulletin was designed primarily for oil production facilities and
may be used in addition to the Regulations and  other guidance
documents to develop an SPCC Plan that is specific to the
facility.

       An example SPCC Plan  for a modest-sized  oil storage
facility i« included in this information guide  as  Appendix "B".
                                12-13
-------
               KEY POINTS OF PREVENTION REGULATION


       The Environmental Protection Agency Oil Pollution
Prevention Regulation, published in the Federal Register
addresses non-transportation-related facilities and is further
identified as Title 40, Code of Federal Regulations, Part 112.
The main requirement of facilities subject to the Regulation is
the preparation and implementation of a plan to prevent any
discharge of oil into waters of the United States.  The plan is
referred to as a Spill Prevention, Control, and Countermeasure
Plan (SPCC Plan).

       The following discussion will summarize key elements of
the Regulation.


PURPOSE

       The purpose of the SPCC Regulation is to prevent
discharges of oil into waters of the United States.  The main
thrust of the Regulation is "prevention" as opposed to "after-
the-fact", or "reactive", measures commonly described in Spill
Contingency Plans.

APPLIES TO

       Owners or operators of facilities engaged in drilling,
producing, gathering, storing, processing, refining, transferring
or consuming oil and oil products, providing —

       The facility is non-transportation-related  (see definition
       of non-transportation Appendix E, pages 12 and 13),

       aboveground storage capacity of a single container is in
       excess of 660 gallons, or an aggregate storage capacity
       greater than 1,320 gallons, or providing that total below
       ground storage capacity is greater than 42,000 gallons,

                              - and -

       facilities, which*due to their location, could reasonably
       expect spilled oil to reach waters of the United States.
                               12-14
-------
Requires facilities which are subject to the Regulation to
prepare and  implement a Spill Prevention, Control, and
Countermeasure  (SPCC) Plan, prepared in accordance with
guidelines outlined in Section 112.7 of the Regulation.

WHO PREPARES THE SPCC PIAK?

       Owners — operating their own facilities, or
       Operators — of leased facilities, or
       Persons  in Charge — including departments, agencies, and
       instrumentalities of State or Federal Government.

GENERAL REQUIREMENTS OF THE SPCC PLAN

       1.  The  SPCC Plan shall be a carefully thought out plan,
prepared in  accordance with good engineering practices, and which
has the full approval of management at a level of authority to
commit the necessary resources (Section 112.7).

       2.  The  complete SPCC Plan shall follow the sequence
outlined (Section 112.7), and include a discussion of the
facility's site-specific conformance with the appropriate
guidelines listed.


SPECIFIC
       The SPCC Plan must be certified by a registered
professional engineer  (Section 112.3).

       A complete copy of the SPCC Plan shall be maintained at
the facility, if the facility is normally attended at least eight
hours per day, or at the nearest field office, if the facility is
not so attended.  The SPCC Plan is only submitted to EPA or state
Agencies under circumstances and conditions outlined in Sections
112.3 and 112.4.

       The SPCC Plan shall be made available to the EPA Regional
Administrator, or to his duly authorized representative, for on-
site review during normal working hours.
                               12-15
-------
       If a discharge occurs ~ in excess of 1,000 gallons in a
single event, or two discharges occur in "harmful quantities'
within any twelve-month period, the owner/operator must then
submit copies of the SPCC Plan to the Regional Administrator and
to the State Agency in charge of water pollution control
activities.  Other information must accompany the SPCC Plan as
outlined in Section 112.4.

       After review of the SPCC Plan submitted under these
circumstances, the Regional Administrator may require an
amendment to the SPCC Plan as deemed necessary to prevent any
future discharges.  Amendments must be certified per Section
112.5.
                                 12-16
-------
                               QUESTIONS  FREQUENTLY ASKED


Question - What  facilities  are subject to the  40 CTR Part  112  Regulation?

  Answer -     All Non-transportation-related  facilities which have:

           1.  Aboveground  oil storage capacity in excess  of 1,320 gallons or
               a single  container  (tank, drum, transformer, etc.) in excess of
               660 gallons.

           2.  Underground  oil storage capacity in excess  of 42,000 gallons.

           3.  Facilities which due to their location and  capacities in 1 and
               2 could reasonably be expected  to discharge oil into waters of
               the United States if a spill should occur.

           4.  The facility must address both  above  ground and underground
               storage capacities when subject to 40 CFR Part  112.

Question - What  is considered  a non-transportation-related facility?

  Answer -     All fixed facilities including  support equipment, but excluding
               interstate pipelines, railroad  tank cars en route, transport
               trucks en route and terminals associated with the transfer of
               bulk oil  to  or  from a water transportation  vessel  (see the
               definition of non-transportation in the Memorandum of
               Understanding at the end of the Regulation).

Question - Who determines if a facility is in  need of an 8PCC  Plan?

  Answer -     The owner/operator as required  by the Regulation  (Section
               112.3).

Question - What  determines  reasonabilit??

  Answer -     Location  of  the facility  in relation  to a stream, ditch, storm
               sewer, distance, volume of material,  drainage patterns, soil
               conditions,  etc. ignoring manmade structures that would inhibit
               the flow  of  oil.

Question - What  constitutes an 8PCC Plan?

  Answer -     A detailed,  site-specific written description of how a
               facility•• operation complies with the guidelines  suggested  in
               the Regulation  (Section 112.7).  The  SPCC Plan  must also be
               certified by a  registered Professional Engineer.

               A sketch  or  drawing of the site will  assist in  identification
               of the implementation.


                                      .12-17
-------
 •lestion - Who is required to prepare the 8PCC Plan?

  Answer -    The owner/operator is required to prepare a written SPCC Plan
              which must be certified by a Professional Engineer (Section
              112.3 and 112.7).

Question - Why does the SPCC Plan have to be certified?

  Answer -    To assure that good engineering practices are followed in
              preparing the SPCC Plan (Sections 112.3 and 112.7).

Question - What are the requirements for certification?

  Answer -    The engineer should be familiar with the provisions of 40 CFR
              Part 112, must have examined the facility, and be a registered
              professional engineer in at least one state.  It is not
              necessary to be registered in the state in which the facility
              is located.  The engineer's name, registration number and state
              of registration shall be included as part of the SPCC Plan
              (Section 112.3).
Question -
  Answer -
            When the SPCC Plan is completed and certified, is it sent to EPA
            for review?

              No, a certified copy of the SPCC Plan is required to be
              available at the facility for EPA on-site review, if the
              facility is attended at least eight hours a day.  If the
              facility is not attended, then the SPCC Plan shall be kept at
              the nearest company office.

Question -  Who reviews the SPCC Plan and how often is the SPCC Plan reviewed?

  Answer -    The owner/operator is required to review the SPCC Plan at least
              once every three years.  This review must be documented.

Question - when must an SPCC Plan be anended?

  Answer -    The owner/operator must amend the SPCC Plan whenever there is a
              change in the facility's design, construction, operation or
              maintenance which affects the facility's potential  for
              discharge into navigable waters of the United States or
              adjoining shorelines (Section 112.5).

              Amendments must be certified by a Professional Engineer  in
              accordance with Section 112.3.
                                   12-18
-------
Question - Whan * production  lease  consists of several operations, such a.
           walls/ oil/water separators,  collection systems, tank batteries,
           etc., does each operation require a separate SPCC Plan?

  Answer -    No, one SPCC Plan may include all operations within a single
              geographical area, however, each operation must be addressed in
              the SPCC Plan.

Question - Is every loss of oil or  oil product subject to a penalty?

  Answer -    A discharge is  defined in  the Clean Water Act (CWA) as
              including, but  not limited to, any spilling, leaking, pumping,
              pouring, emitting, emptying, or dumping that enters the waters
              of the U.S. or  on the adjoining shorelines in harmful
              quantities.

              (1)  If a spill occurs and enters the water, a penalty will be
              assessed.
              (2)  If a spill occurs and is prevented from entering the
              water, a penalty may  or may not be assessed.

Question - What is considered to be a baraful quantity?

  Answer -    A harmful quantity is defined in the Regulation as a discharge
              which affects the water quality standards, or causes a film or
              sheen upon or discoloration of the water or adjoining
              shorelines, or  cause  an emulsion or sludge to be deposited
              beneath the surface or the water or upon adjoining shorelines.

Question - What is considered navigable  waters?

  Answer -    The Clean Water Act (CWA)  defines navigable waters as the
              waters of the United  States.  The Coast Guard interpretation
              not only includes the traditional navigable waters, but all
              streams, creeks, lakes, and ponds connected to the tributary
              system in a river basin.

Question - Is one spillage of oil into a municipal storm sever a violation?

  Answer -    If oil reaches  "navigable  water" a violation has occurred and
              penalties will  result.  The facility spilling the oil must also
              have an SPCC Plan 'implemented.  A properly engineered and
              implemented SPCC Plan would prevent * .spill from occurring and
              entering navigable waters.


Question - What penalties are assessed?

  Answer -    Section 112.6 of 40 CFR authorizes the Regional Administrator
              to assess a civil penalty  up to $5,000 per day for each
              violation.  The guidance for determining penalties is addressed
              in 40 CFR Part  114.

                                    12-19
-------
 uestion - What should be reported to the National Response center  (NRC)
           1-800-424-8802 (toll free)?

  Answer -     Discharge of oil involving U.S. waters must be reported to the
               NRC by the person in charge of the vessel, facility  or vehicle
               from which the discharge occurs.  It is also desired that
               threats of discharges or releases be reported.  The  procedures
               for such notices are set forth in 33 CFR Part 153, 40 CFR Part
               110, 40 CFR Part 112 and the National Oil and Hazardous
               Substances Pollution Contingency Plan (NCP).

Question - Do tanks have to be tested?

  Answer -     Yes, the Regulation recommends periodic testing of tanks, tank
               supports and foundations (Section 112.7).

Question - Does a State Spill Plan meet the requirements of a Federal SPCC
           Flan?

  Answer -     Not necessarily; if the State Spill Plan is intended to be used
               as the Federal SPCC Plan, it must meet or exceed  all the
               requirements  under 40 CFR Part 112.  The State Spill Plan must
               express clearly that it addresses both the state  and Federal
               Regulations.

Question - Where can I get additional information?

   .nswer -     For additional information concerning SPCC regulations, contact
               the SPCC Coordinator by writing or telephone at the  following
               address:

                       U.S. Environmental Protection Agency
                       Region III
                       SPCC Coordinator- Vincent Zenone (3HW32)
                       841 Chestnut Building
                       Philadelphia, PA  19107
                       (215) 597-3038
                                      12-20
-------
 APPENDIX
     A
12-21
-------
    following is an example of a certification page for an SPCC Plan.

                         CERTIFICATION INFORMATION


              A. Name of Facility - Tex's Bulk Storage Terminal

              B. Type of Facility - Commercial (Storage and distribution)

              C. Date of Initial Operation - January 31, 1970

              D. Location of Facility - 100 Everspilload, Oily City, USA

              E. Name and Address of Owner - SJ Oi
                                             P.O.
                                             Crude
(Seal)
DATE:
              F. Designated Person

                      NAME

              G. Oil Spill History - Th
                 significant oil spill
                 to December 11, 1973.

              H. Management approva
                 management at a leve
                 necessary resou
               77000

            11 Prevention -
     has experienced no
   ng the twelve months prior
roval is extended by
 hority to commit the
                                          Mr. John Paul Jones

                                          President - SJ Oil Company
                                   hereby certify that I have examined the
                                  ng familiar with the provisions of 40 CFR
                                  that this SPCC Plan has been prepared in
                                 good engineering practices.
                 NAME:

                 SIGNATURE

                 REGISTRATION NO.:

                 STATE:
                                               Appendix A pg.  1 of 1
                                     12-22
-------
APPENDIX
    B
     12-23
-------
                      EXAMPLE
SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN
            TEX'S BULK STORAGE TERMINAL
                 100  Everspill Road
               Post Office  Box 311(K)
                Oily  City,  USA 12345
              Telephone  (123) 222-2*
                   SJ  Oil
                   P.O.
               Crude City
Box
  Compar
               Steve
CERTIFICATION:  I hereby c
being familiar with the pr
Plan has been prepared

Engineer:   Christoph

signature:

License Number:  98765

Date:  6/11/74
                           have examined the facility,  and
                           CFR Part 112, attest that this spec
                       "with good engineering practices.
                            State:   Of The Union
                                   (seal)
                                   Appendix B pg 1 of 7
                        12-24
-------
1.  NAME OF OWNERSHIP
        Name:  SJ Oil Company  - Tax's  Bulk  Storage Terminal
               100 Everspill Road
               Post Office  Box 311(K)
               Oily City, USA  12345
               Telephone:   (123) 222-2222
        Manager:
Steve Bob Doe
505 Oil Road
Oily City, USA 12345
Telephone:  (123) 222-3333
        Owner:
SJ Oil Company
P.O. Box 00002
Crude City, USA
                                   77000
        Other Personnel:
        Service Area:  North-West
2.  DESCRIPTION OT TACILI

   Tex1* Bulk Storage
   distribute* petrole,
   No. 2 fuel oil.
   adjacent highway dr
   facilities.
      Fixed Storage:
      Total:

      Vehicles:
        Secretary-Boo!
        Dispatcher
        Transport
        (3) Delive
                the SJ Oil Company handles, stores and
                Lin the form of motor gasoline, kerosene, and
                Lng drawing shows the property boundaries and
                las, onsite buildings, and oil-handling
    (2)   100,00"o gallon vertical tanks (premium gasoline)
    (2)   100,000 gallon vertical tanks (regular gasoline)
    (2)    20,000 gallon vertical tanks (No. 2 fuel oil)
    (1)    20,000 gallon vertical tank (kerosene)

    460,000 gallons

    (1)    Transport Truck
    (4)    Tankwagon Delivery Trucks
                                                Appendix B pg 2  of 7
                                       12-25
-------
     Appendix B pg 3 of 7
12-26
-------
3.  POTENTIAL 8PZLL VOLUMES AND RATES

    Potential Situation     Volume Release^

                               100,000 gallons
Complete failure of a
full tank

Partial failure of a
full tank

Tank overfill
    Failure of a pipe
    Leaking pipe or valve
    packing
    Truck loading area
                    1-99,000 gallons


                    1 to several gallons


                    Up to 20,000 gallon
                           Several ounces
                           several gallons
                           1 to sever
4.  SPILL PREVENTION AND CONTROL

   A.  STORAGE TANKS
       1)

       2)


       3)
        Each tank is UL-142

        Each tank is equipped
        capacity is suitsftle fol
        A dike surro
        been constru
        engineering
        area) is
        (100,000
        vertical
        (estimated
        2-inch water
                                          Rate of Spilling

                                             Instantaneous
                                                         Gradual to
                                                         instantaneous

                                                         Up to 1 gallon
                                                         per minute
                                                          Ions per
                                                          d
                                                to 1 gallon
                                              er minute
                                             Up to 1 gallon
                                             per minute
                                  (aboveground use).
                           a direct reading gauge.  Venting
                             fill and withdrawal rates.
       4)


       5)
                           installation.  Each dike wall has
                         Tgned to Local, State, and Federal
                        ,  The contained volume (height vs.
                        on the single largest tank within
                      allowance is made for all additional
                    tcement volumes below the dike height
                   Cquid level), and for precipitation.   A
                    Ls located at the lowest point within the
dike enclosure, 'and it connects to a normally closed gate-
valve outside the dike.  The gate valve is manually operated.
Rainwater contained within this dike is examined prior to
release to ensure that harmful quantities of oil are not
discharged.

After a fill pips is used, a bucket is placed under it to
catch any product that might drip from the pips.

There are no buried or partially buried tanks at this facility,
                                                Appendix B pg 4 of 7
                                       12-27
-------
       6)   Tanks are subject to periodic integrity testing and  inspection
            Tank supports, foundations, and piping are included  in these
            inspections, and proper records are kept.  The exterior of the
            tanks are examined frequently.

       7)   Materials stored on the site for spill countenneasures include
            bagged absorbent, sorbant pads and booms.  There  is  a sand-filled
            catchment basin for minor, routine spillage at loading pump
            intakes and at loading rack.  This catchment will contain greater
            than the largest compartment of the largest tank truck loaded or
            unloaded at this facility.  Sand will be replaced as needed, and
            any oil-contaminated sand is disposed of pcjbperly.

       8)   Failsafe Engineering

            a)  Tanks are equipped with high-level

            b)  Tanks are equipped with visual

B.  FACILITY TRANSFER OPERATIONS

        1)   Buried pipes are properly profee^edVagainst corrosion.  If a
             section of buried pipe is e)ip$s^d«qa«ision and contraction.
        4)  Aboveground pipelines an£(valves are examined periodically to
            assess, their coni

        5)   Warning signsf a»e ppaSy as needed to prevent vehicles  from
             damaging pidtlinesl
        6)  Curbings afc* i/ftalle4 at the vehicle loading racks.
5.  SPILL COUNTEHMlAflUWSS
    The front highway drainage ditch on the property's northern bovwtery
crosses the highway through a culvert headed eastward and eventually leads
to Carol Creek located approximately one half mile distant.   Emergency
containment action will constitute the erection of an earthen dam and
placement of absorbent materials at the entrance  to  the  culvert.   Sorbent boom
will be strategically placed on Carol Creek upstream from dead duck pond to
contain oil which will be recovered and disposed  of  properly.   Manpower
materials and equipment are committed to ensure this contingency  plan is
implemented in a manner that no oil reaches dead  duck pond  (an environmentally
sensitive ecosystem).

                                                Appendix B  pg 5 of 7


                                       12-28
-------
PAST SPILL EXPERIENCE

None

SECURITY
     a)  The bulk plant is surrounded by steel security fencing, and the
         gate is locked when the plant is unattended.
         All valves which will permit direct outward flow of a tank's
         contents and dike drain valves are locked, in the closed position
         and the electrical controls for the pumpy are locked in the off
         position when not in use.
         b)




         c)


         d)



8.   PERSONNEL

    All personnel have been instructed b
    the following spill prevention
         The loading and unloading connections
         when not in service.

         Two area lights are located in su'
         illuminate the office and stor
    a)


    b)

    c)


    d)
    f)
            No tanks or compartments
            reserves.
            No pump operations w
            Warning signs ar
            before vehicle d

            Training ha
            retrieval
            spill has

            Instructi
            the office
            Response Cent
                             es are capped
                          n so as to
                   management and rehearsed •
                 sure plans:

               filled without prior checking


             unless attended constantly.

        to check for line disconnections
      oil-spill prevention, containment,  and
   a "dry-run" drill for an on-site vehicular
  ed.

ne numbers have been publicized and posted at
 the report of a spill to the National
the State.
            Instructions and company regulations which relate to oil spill
            prevention and countermeasure procedures have been conspicuously
            posted.
                                            Appendix B pg 6 of 7
                                  12-29
-------
 .   EMERGENCY TELEPHONE NUMBERS

       A.  NOTIFICATION PROCEDURES

          1)  Steve Bob Doe, Facility Manager

          2)  National Response Center

          3)  The State

       B.   CLEANUP CONTRACTORS

          1)  E-Z Clean Environmental

          2)  0. K. Engineers, Inc.

       C.   SUPPLIES AND EQUIPMENT

          1)  Oily City Equipment Co.

          2)  Northwestern Sorbent Co.

10.  REVIEW DATES

     6/08/77   (signature)
     6/01/80   (signature)
     6/10/83   (signature)
     6/09/86   (signature)
 (123)  222-3333

 (800)  424-8802

 (123)  555-2221




 123)  222-3038

      222-2207




(123)  222-8372

(123)  222-9217
                                                Appendix B pg  7 of  7
                                     12-30
-------
APPENDIX
    C
  12-31
-------
     EXAMPLE OP DESIGN:  HORIZONTAL TANKS ONLY
                                                    45  FT.
                                30  FT.
                           NOT TO SCALE
calculations  for this example:

        a)  Minimum containment volume  is single largest tank within dike:
           15,000 gal X .1337 cu.ft. - 2,006 cu. ft.
                            gal

        b)  Available area:  30 ft. X 45 ft. • 1,350 sq. ft.

        c)  Average Dike height "h"
             "h" X 1,350 sq. ft.  - 2,006 cu. ft.
             "h" • 2,006 CU. ft.  - 1,350 sq. ft.
             "h" - 1.486 ft. (17.8 inches + freeboard)

                                         Appendix C pg 1 of 2
                                   12-32
-------
2.   EXAMPLE OF DESIGN:   HORIZONTAL AND VERTICAL TANKS
                        10, 000
                        GAL HORZ.
                   15,000  GAL HORZ.
                   15,000  GAL HORZ.
                                 (2)   20,  000
                                      GAL
                                                     30 FT.

                                 75 FT.
                              NOT  TO SCALE
Calculations for this example*

        a)  The minimum containment volume is that of the singly largest tank:
           20
b)

c)
              20,000 gallons X  .1337 cu.  ft. /gallon - 2,674 cu.  ft.

            Available dike area, this example:  30* X 75' • 2,250 sq. ft.

            Observe that some volume of the vertical tanks go below the dike
            wall height.  This  volume of the  second 20,000 gallon tank (and
            any  additional verticals) assumed  QO£ ruptured must be
            considered.

                                              Appendix C pg 2 of 2
                                    12-33
-------
APPENDIX



    D
 12-34
-------
                                                                    § 110.1
    PAftT 110—OISCXAIGI 0» OIL

See.
110.1  Definitions
110.2  Applicability.
110.3  DUcharte into  navifablc waters at
    such quantities M may be harmful
110.4  Dbcharre into  contiguous  cone at
    such quantities ai may be harmful.
110.3  Discharre beyond contiruous tone of
    such quantities a* may be harmful.
110.4  DUcharie prohibited.
110.7  Exception for vesatt entitle*.
110.8  Dispenama.
110.9  Demonstration projects.
; 10.10  .Votict.
110.11  Discharge at deepwaur ports.
  Atmiotrrr See*. 311  (6X3) and (bK4) and
SOKa). Federal  Water Pollution  Control
ACL M amended (33 UAC.  1331 (bX3> and
(bX4> and 13Sl(a>K ate !KmM3) of tat
Deepwaier Pen Act  of 1174 (33 U.3.C.
1917(mX3)K E.0.11738. U PR  21243.3 CPU
Paru im-im Come., p. 7ft.
  Soomcc S3 PR 10719. Apr. i. 1M7. unies*
otherwise noted.

1110.1  Dcflnitiom.
  As used in this part,  the following
terms shall  have the meaning indlcat-
ed below:
  -Act- means the Federal Water Pol-
lution Control Act. as  amended,  34
U.S.C. 1251  et aee> also  known as the
Clean Water Ace
  "Administrator" means the Adminis-
trator of the  Environmental  Protec-
tion Agency (EPAX
  •• Applicable water quality standards"
means State water  quality standards
adopted by the State pursuant to sec-
tion 303 of the Act or  promuliated by
EPA pursuant to that section:
  "Contiguous tone" meant the entire
zone established  or  to be  established
by  the United  States under article 24
 of  the  Convention on the Territorial
 Sea and the Contiguous Zone;
  "Deepwater port" means an offshore
 facility as defined In section (3X10) of
 the Deepwaier Port Act  of  1974  (33
 U.S.C. 1502(10)):
  "Discharge." when used  in  relation
 to section 311 of the  Act. includes,  but
 is not limited to. any spilling,  leaking.
 pumping, pouring, emitting, emptying.
 or  dumping, but  excludes  (A)  dis-
 charges tn compliance with a  permit
 under section 402 of the Act    dis-
 charges resulting from circumstances
 Identified and reviewed and made a
 part of the public record with respect
 to a permit  issued or modified under
 section  402 of the Act. and subject to a
 condition in such permit, and (C) con-
 tinuous  or  anticipated  intermittent
 discharges from a point source, identi-
 fied in a permit or permit application
 under section 402 of  the Act. that  are
 caused by events occurring within  the
 scope of relevant operating or  treat-
 ment systems:
  "MARPOL 73/78"  means the Inter-
 national Convention for the  Preven-
 tion of  Pollution from Ships. 1973. as
 modified by the Protocol of 1978 relat-
 ing thereto. Annex I. which regulates
 pollution from oil and which  entered
 into force on October 2.1983;
  "Navigable   waters"  means   the
 waters of the United States, including
 the territorial seas. The term includes:
  (a)  All  waters that are  currently
 used, were used In the past, or may be
susceptible to use in  interstate or for-
eign commerce.  Including all waters
 that are subject to the ebb and flow of
 the tide:
  (b)   Interstate   waters.   Including
 interstate wetlands;
  (c)  All other waters such as Ultra-
state lakes, riven,  streams (Including
 Intermittent  streams), mudflats, sand-
flats, and wetlands, the use. degrada-
 tion,  or destruction  of which would
affect or could affect Interstate or for-
 eign  commerce  lncUr"*$g any such
 waters:
  (1)  That are  or could be  used by
 interstate or foreign  travelers  for rec-
 reational or other purposes;
  (2) From which flan or shellfish  are
or could be  taken and sold In  inter-
 state or foreign commerce:
                                   12-35
                                              Appendix D pg 1  of 4
-------
 §110.2

  (3) That are used  or could be used
 for industrial purposes by industries in
 interstate commerce:
  (d) AJ1 impoundment! of waters oth-
 erwise  defined  u navigable waters
 under this section:
  («> Tributaries of  waters  identified
 in paragraphs (a) through (d) of this
 seetioa  including adjacent  wetland*;
 and
  (f ) Wetlands adjacent to waters Iden-
 tified In paragraphs (a) through (e) of
 this section;  Provided. That  watte
 treatment systems (other than cooling
 ponds  meeting  the  criteria of  this
 paragraph)  art  not  water* of  the
 United States:
  "NPDES" means National  Polluunt
 Discharge Elimination System:
  "Offshore facility"  means any facili-
 ty of any kind located in. on. or under
 any of the navigable waters of the
 United States, and any facility of any
 kind that is subject to the jurisdiction
 of the United States and Is located in.
 on, or under any other waters, other
 than a vessel or a public vessel:
  "Oil", when used in relation to see-
 lion 311 of the Act means oil of any
 kind or to any form. Including, but not
 tinted to. petroleum, fuel oil. sludge.
 oil  refuse, and oQ nixed with waste*
 other than dredged spoil "OH." when
 used In relation to section l*xmX3> of
 the Deepwaur Port  Act of  1W. hat
 the meaning provided in section 3(14)
 of the Deepwater Port Act of lf7«
  "Onshore faculty" neans any faefll*
 ty (Including. but not United to. motor
 vehicles and roUlnc stock) of any kind
 located to,  on. or under  any  land
 within the United States, other than
submerged land:
  -Person-  Include*  aa  individual.
 firm, corporation, association, and a
 partnership!
  -Public veaaer means a vessel owned
 or bareboat Chartered «nd operaud by
 the United Bute*, or by i State or po*
 Utfeal MMMstaa thereof, or by a for*
 •lea nation, except wliee men veseeJ to
          mean* an Iridescent appear*
ance on the surface of water:
  •SludsX* m«anc an atirscato of ofl
or ofl and other matter of any kind tat
any  fora  otter than dredged  spoO
having  •  combined specific gravity
equivalent to or greater than -water:
         40 CFI Ch. I (7-1-S7 Edition)

  "United States" means the States.
the  DUtrict of Columbia,  the  Com-
monwealth  of Puerto Rico. Guam.
American Sajnoa, the Virgin Islands.
and  the Trust Territory of the Pacific
Islands;
  "Vessel" means every description of
watercraft or other artificial eontrtv*
ance used, or capable of being used, as
a means of  transportation on water
other than a public vessel: and
  "Wetlands" means those areas  that
are inundated or  saturated by surface
or ground water at a frequency or du-
ration sufficient to support,  and  that
under normal circumstances do  sup-
port, a prevalence of vegetation typi-
cally adapted for  life in saturated soil
conditions. Wetlands generally Include
playa  lakes, swamps,  marshes, bogs
and similar areas such as sloughs, prai-
rie   potholes,  wet meadows, prairie
river overflows, mudflats, and natural
ponds.

«II«J Applicability

  The regulations of this part apply to
the discharge of oO prohibited by see*
tion 311(bx3> of the Act. This Includes
certain discharges Into or upon the
navigable waters of the United States
or adjoining shorelines or into or upon
the waters of the contiguous tone, or
In connection with activities under the
Outer Continental Shelf Lands Act or
the  Deepwater Port Act of  1*74.  or
that may affect natural resources be*
longing to. appertaining to, or under
the  exclusive management authority
of the United States (Including re*
sources under the Magnueoa Fishery
Conservation and Management Aetx
The  regulations   of this  part  also
define the term "discharge- for  pur-
poses of section IKaX*) of the Deep*
water Port  Act of 1*74. as  pwided
under I lle.ll of this part.
HIM Discharge tote Mvtgafcie
  For purposes of seetioa SlUb) of the
Act. discharges of oO Into or open the
navigable waters of the United States
or adjoining shorelines to
ties that It has been determined: mas'
be  harmful to the  nubile health  or
welfare of the United States, except as
                                  12-36
                                      Appendix D  pg 2 of  4
-------
 Environmental Protection Agency

 provided in f 110.7 of this part. Include
 discharges of oil that:
   (a) Violate applicable water quality
 standards, or
   (t» Cause a film  or  sheen upon or
 discoloration of  the surface  of the
 water or adjominc shorelines or cause
 a sludee or emulsion to be deposited
 beneath  the surface of the water or
 upon adjominc shorelines.

 f 110.4  Dfscherf* into contiguous ton* of
    tuch quantities u may b« harmful.
   For purposes of section 311(b> of the
 Act. discharges  of oil Into or upon the
 waters of the contiguous zone in such
 quantities that It has been determined
 may  be harmful to the public health
 or welfare of the United States, except
 as provided  in  I 110.7.  Include  dis-
 charges of oil that:
   (a) Violate applicable water quality
 standards, or
   (b) Cause  a film or sheen upon or
 discoloration of the surface of  the
 water or adjoining shorelines or cause
 a sludge or  emulsion to  be deposited
 beneath  the surface of the water or
 upon adjoining shoreline*.

 11104  Discharge beread contiyuow see*
    of »uch e.uanUti«* as may be harmful
   For purposes of section 31Kb) of the
 Act. discharges of  oil Into or upon
 waters seaward of the contiguous son*
 in connection with activities under the
 Outer Continental Shelf Lands Act or
 the  Deepwater  Port Act of 1*74. or
 that may a/feet natural resources be-
 longing to. appertainlnc to. or under
 the  exclusive management authority
 of the United  State*  n~*i,uit*f r*.
 source* under the Kafnuaon Fishery
• Conservation and Management Act) la
 such quantities that tt bat been deter-
 mined nay be harmful to the publle
 health or welfare of the UnlUd State*.
 except at provided IB 1110.7. include
 dl*charg**ofoathae
  (a) Violate applkabl*  water quality
 standard*, or
  (b) Can**  a mm or aheen upon or
 discoloration of the furfact of  th*
 water or adjoining shoreline* or eaua*
 a sludge  or emulstoo to b* deposited
 beneath th* surface of th* waur or
 upon adjoining shoreline*.
                             § 110.10

 9 I10.S Discharge prohibited.
  As  provided In section 311(bX3> of
 the Act. no person shall discharge or
 cause or permit to  be discharged into
 or upon the navigable waters of the
 United States or adjoining shorelines
 or into or upon the waters of the con-
 tiguous zone or into or  upon waters
 seaward of the contiguous zone In con-
 nection  with  activities  under  the
 Outer Continental Shelf Lands Act or
 the Deep water Port  Act of  1974.  or
 that may affect natural resources be-
 longing to. appertaining  to, or  under
 the exclusive management authority
 of the  United State*  (including re-
 sources under the Magnuson Fishery
 Conservation and Management  Act)
 any oil in such  quantities as may  be
 harmful  as  determined  in  If 110.3.
 110.4. and 110.3. except  as the same
 may  be permitted  in the contiguous
 zone and seaward under MARPOL 73 /
 78.  Annex I. as provided In  33 CFR
 131.09.

 i I !«.? Exception for rcucl engines.
  For purpose* of section 31 Kb) of the
 Act. discharges of oil from a properly
 functioning  vessel   engin*  an not
deemed to bt harmful, but discharge*
 of such oQ accumulated  In a vessel's
 bilge* shall not be so exempt.
1 1104
  Addition of dlspenant* or emulslfl-
en to OH to be discharged that would
circumvent th* provision* of this part
(•prohibited.

HIM  Dew«MSratie« projects.
  Notwithstanding  any  other provi-
sion* of this earc.  the Administrator
may permit the discharge of ofl. under
section  311 of th* Act, tat connection
with research, demonstration projects,
or studies relating  to the prevention.
control, or abatement of ofl pollution.

illt.lt  Watts®.
  Any penoa la chars* of a vessel or
of  an  onihor* or  offahor*  facility
•hall, a* soon a* he or ah* ha* knowl-
edge of any discharge of ofl from such
vesaai or fadUty ta violation of I ilAJ.
            notify th* National  Re-
sponse Center (KRO (SOO-424-MOt ta
the  WashlngtOB,  DC  metropolitan
                                 12-37
                                         Appendix D pg  3 of 4
-------
§ no.n

area.  436-2675). If direct reporting to
the NRC la  not  practicable, report*
may be made to the Coast Guard or
EPA  predestinated On-Seene Coordi-
nator (OSO  for the geographic are*
where the discharge occurs. All  such
report! shall  be promptly relayed to
the NRC. If It Is not possible to notify
the NRC or  the  predesignated  DCS
immediately,  reports may be made Im-
mediately to  the nearest Coast Guard
unit,  provided that the person  In
charge of the vessel or onshore or off-
shore facility  notifies the NRC as soon
as possible. The reports shall be  mad*
in accordance with such  procedures a*
the Secretary of Transportation may
prescribe. The procedures for   such
notice are  set forth In  U.S. Coast
Guard regulations. 33 CFR Part 153.
Subpart B and in the National Oil and
Hazardous Substances Pollution  Con-
tingency  Plan. 40 CFR Part 300.  Sub-
pan E. (Approved by  the Office  of
Management  and  Budget under the
control number 2050-0046)

1110.11 Discharge at dctpwattr ports.
  (a) Except a* provided In paragraph
 of the Deepwater Port Act of
1974,  the urn "discharge" shall In-
clude  but not be limited to. any spill*
inc. leaking,  pumping, pouring,  emit*
tint, emptying, or dumping into tht
marine environment  of  quanUUe*  of
oilthac
  (1) Violate  applicable water quality
standards, or
  (3) Cause a fflm or sheea upon or
discoloration  of the surface of the)
water or  adjoining  shorelines or  causo
a studft  or emulsion to be deposited
beneath  the  surface  of  the waur or
upon adjoining shorelines.
  (b) Tor purposes  of section IftmXI)
of tht Deepwater Pen Act of 1974. the
Urn "discharge" excludes:
  (1) Discharges of oQ from a property
functioning vessel  testo*. (infludlng
an engine on * 0uabe vessel), but not
discharges of such oil accumulated to
a vessel's bOgee (unless In eompllane*
with MARPOL 7I/1& Annex XX and
  (2) Discharges of ofl permitted under
MARPOL nm. Annex L
                12-38
                       Appendix D pg 4 of 4
-------
APPENDIX
    B
 12-39
-------
         40 CFR Ch. I (7.M7 Edition)

     PART 112— OIL POLLUTION
            PREVENTION

See.
112.1  General applicability.
m.J  Definition*.
112.3  Requirement*  for  preparation  and
   implementation of Spill Prevention Con-
   trol and Countermeuure Plant.
112.4  Amendment of SPCC Plans by Re-
   f lonal Administrator.
112.J  Amendment at Spill Prevention Con-
   trol  and  Counurm«uur«   Plam  by
   owner* or operators.
112.8  Civil penaltlet for violation of oil pol-
   lution prevention refutation*,
112.7  Guideline* for Ut« preparation  and
   Implementation of a  Spill  Prevention
   Control and Countermeasure Plan.
   BETWCO TMt SCCHCTAKT or TMANSPORT*-
   TICK AKB TMC ADMrXISTBATO* O? TXI EN-
   VmONMCTTAl PSOTtCTIOM ACtXCT
  AtrrHomrr Sees.  llKjxixC). 31KJX2).
SOKa). Federal Water Pollution Cdntrol Act
(see.  2. Pub. L.  12-SOO. M Sut. IK ct aeq.
(33 U.S.C.  1231  et aeq.)K aee. 4(bi. Pub. L.
»2-500. M Sut  197: 5 V3.C. Reort. Plan ol
1170  No. ! (1170). J3  PR 1M23. 3 CFR lt«*-
1970  Compu  E.O. 117SS.  3«  FR  21243,  3
CFR.
  Sooxcr M FR 341U. Dee. 11. irrj. unl«M
othcnrtat noud.

I Mil  CeiMnJ •pplinbiiltv.
  (a) This put esublishct procedures.
method* and equipment and other re-
quirement*  for equipment to  prevent
the  discharge  of  oil from non-trans-
portatlon-relat«d  onshore  and  off*
shore faculties Into or upon the nart-
cable vattrs of UM United SUMS or
adjoininc shoreline*.
  (b) Except M provided la paragraph
(d) of this section, title pan applle* to
owners or operators of non-transport*-
Uon-related onshore  and  offshore fa-
cilities encaged In drflllnc. producing.
gathering, storing,  processing,  refla*
ing,  transferring,  distributing or coo*
suming ofl  and  ofl  products,  and
which, due to their location, could rea-
sonably be expected to discharge oO m
harmful quantities, as defined In Part
lie of this  chapter, into or upon th«
navigable waters ol the United States
or adjoining shoreline*.
  (0 At provided  to section  113 (M
Stat ITS) departmentt. agencies, and
tnstrumeaullUea of the Federal
                12-AO
                       Appendix E pg 1  of  13
-------
 Environmental Protection Agency

 eminent  are  subject to these  regula-
 tions  to   the same extent  u  any
 person, except  for  the provisions of
 IU2.6.
  (d) This part does not apply to:
  (1) Facilities,  equipment  or oper-
 ations which are not subject to the Ju-
 risdiction of  the Environment*! Pro-
 tection Agency, as follows:
  (t) Onshore  and  offshore facilities.
 which, due to their location, could not
 reasonably  be expected to discharge
 oil Into or upon the navigable waters
 of  the United  States  or adjoining
 shorelines.  This determination shall
 be  based  solely upon a consideration
 of the geographical, locational aspects
 of  the  facility (such as proximity to
 navigable waters or adjoining shore-
 lines, land contour,  drainage, etc.) and
 shall exclude  consideration  of man-
 made  features such as dikes, equip-
 ment or other structures  which may
 serve to restrain, hinder,  contain,  or
 otherwise prevent a discharge of oil
 from reaching navigable waters of the
 United States or adjoining shorelines:
 and
  (U) Equipment or operations  of ves-
 sels or transportation-related onshore
 and offshore facilities which are sub-
 ject to authority and  control  of the
 Department of Transportation, u de-
 fined in the Memorandum of Under-
 standing  between  the   Secretary  of
 Transportation and the Administrator
 of   the  Environmental  Protection
 Agency, dated November 24. If7l. 38
 FR 24000.
  (2) Those facilities which, although
 otherwise subject to the jurisdiction of
 the Environmental Protection Agency.
 meet both of the  following require*
 menu:
  (1) The  underground burled storage
capacity of the facility  to 42.000 gal*
 Ions or less of oU. and
  (11) The storage capacity, which to
 not buried, of the faculty to 1420 gal-
 lon* or less of ofl. provided no sing)*
 container  has a capacity in excess of
  (e) This part provides fur the prep*
ration and Implementation  of 8001
Prevention Control and Countermeae.
ure Plans prepared In accordance with
1112.1. designed to complement exist*
ing laws, regulations, rules, standard!*
policies and procedures pertaining to
                              § 112.2

safety standards,  fire prevention  and
pollution  prevention  rules,  so as to
form a comprehensive balanced Feder-
al/State spill prevention program to
minimize  the  potential  for oil  dis-
charges. Compliance  with  this  part
does not In any way relieve  the owner
or operator of an onshore  or  an  off-
shore facility  from compliance  with
other Federal. State or local  laws.

(31 FR 34 IBS. O«e. U. 1973. u *m«nded at
41 Fit 12637. Mar. 38 187«1

1112.2  Definition*.
  For the purposes of thU pare
  (a) "Oil" means oil of any  kind or in
any form. Including, but not limited to
petroleum, fuel oil. sludge,  oil refuse
and oil  mixed with wastes other than
dredged spoiL
  (b)  "Discharge" includes but is  not
limited to. any spilling. leaking, pump.
ing.  pouring,  emitting,  emptying  or
dumping.  For purposes of  this part,
the term "discharge" shall not include
any discharge of oil which  is author-
ized  by  a permit issued  pursuant to
section 13 of the River and Harbor Act
of ISM  (30 Stat. 1121. 33 U.3.C. 407).
or sections 402 or 40S of the FWPCA
Amendments of 1972 (86 SUt 118 et
seq.. 33 U.3.C. 1231 et seq.).
  (c) "Onshore facility" means any fa-
cility of any kind  located In.  on.  or
under any land within  the  United
States, other  than submerged lands.
which to not a transportation-related  I
faculty.
  (d) "Offshore faculty" means any fa-  I
cfllty of any kind  located In.  on,  or
under any of the navigable waters of
the  United  State*,  which  to  not a
transportation-related facility.
  (e) "Owner or operator" means any
person  owning or  operating an  on-
shore faculty  or an offshore faculty.
and to the case of any abandoned off-
shore faefllty. the person who owned
or operated such faculty Immediately
prior to such abandonment.
  (ft "Person" '-jgudts an Individual.  ,
flra. eorpMAttdA. amociatlon. and a  ;
partnership.
  (g) "Regional Administrator*, means
the Regional Administrator of the En-
vironmental Protection Agency, or his
rtetlgnee.  m  and for  the Region In
which the facttlty to located.
                                        Appendix  E pg 2  of  13
-------
 §112.3

    No SPCC Plan shaU be effective
to  satisfy the  requirements  of this
part unless It has been reviewed by a
Registered Professional  afeflneer and
certified to by such Professional End*
neer. By means of this certification
                                  12-42
                                    Appendix E pg  3 of 13
-------
 Environmental Protection Agoncy

 the engineer, having examined the fa-
 cility and being familiar with  the pro-
 visions of this pan. shall  attest that
 the SPCC Plan has been prepared in
 accordance  with  good  engineering
 practices.  Such certification  shall  In
 no way relieve the owner or operator
 of an onshore or offshore  faculty  of
 his duty  to prepare and fully Imple-
 ment  such Plan  in accordance with
 I 112.7. as required by paragraphs 
-------
«.nx4

  (5)  Maximum slorare or
capacity of the  facility and  normal
daily throughput:
  (6)  Description  of  the  facility.  In-
cluding maps, flow diagrams, and topo-
graphical maps:
  (7)  A complete  copy of  the SPCC
Plan with any amendments:
  (8) The causecs) of such spill, includ-
ing a  failure analysis of system or sub-
system In which the failure occurred:
  (9)  The  corrective  actions  and/or
countermeasures  taken. Including  an
adequate description of equipment  re-
pairs and/or replacements:
  (10)  Additional  preventive measures
taken or contemplated to minimize the
possibility of recurrence:
  (11)  Such other Information as  the
Regional Administrator may  reason-
ably require pertinent to the Plan or
spill event.
   of
into section, the Regional Administra-
tor may require the owner or operator
of such facility to amend  the SPCC
Plan tf he finds that the Plan do«a not
meet the requirements of this part or
that the amendment  of the  Plan to
necessary to prevent and to  contain
discharges of of) from web faculty.
  (t) When the Regional Adminttn*
tor proposes to require an amendment
            46 CFB Ch. i (7-1-67 Edition)

    to the SPCC Plan, he ihaJJ notify the
    facility operator by certified mail ad-
    dressed to. or by personal delivery to.
    the facility owner or operator, that he
    proposes to require an  amendment to
    the Plan, and shall specify the terms
    of such amendment.  It the  facility
    owner or operator is a corporation,  a
    copy of  such  notice  shall  also be
    mailed to the registered agent, if any.
    of such corporation in the State where
    such facility is located. Within 30 days
    from receipt of  such notice, the facili-
    ty owner or operator may submit writ-
    ten information, views, and arguments
    on the  amendment. After considering
    all relevant  material  presented,  the
    Regional  Administrator shall notify
    the facility owner or operator of any
    amendment required or shall rescind
    the notice. The amendment required
    by the Regional Administrator  shall
    become pan of  the Plan 30 days  after
    such notice,  unless the Regional Ad-
    ministrator,  for  good  cause,   shall
    specify  another effective date.  The
    owner or operator of the facility  shall
    implement  the  amendment  of  the
    Plan as soon as possible, but not later
    than six months after the amendment
    becomes pan of the Plan, unless the .
    Regional  Administrator specifies an-
    other date,
      (f) An owner or operator may appeal
    a decision made by the Regional Ad-
    ministrator requiring an amendment
    to an SPCC Plan. The appeal shall be
    made to  the  Administrator of  the
    United  States Environmental Protec-
    tion Agency and must be made In writ-
    ins within 30 days of  receipt of the
    notice from the Regional Administra-
    tor requiring the amendment. A com- ,
    plete copy of the appeal must be sent
    to the Regional Administrator at the
    time the  appeal Is mad*. The appeal
    shaU contain a clear and concise state-
    ment of the Issues and points of fact
    In the caw. It may also contain  addi-
    tional teforaation from the owner or
    operator, or from any  other person.
    >Th«  Administrator or als designee
    may request additional Information
    from the owner er operator, or  from
    any other person. The Administrator
    or his deslcne*  shall render a decision
    within M day* of receiving the appeal
    and shall notify the owner or operator
    of his dedsi®&»
12-44
   Appendix £ pg  5 of 13
-------
 Environmental Prelection Agency

 (38 PR 34163. Dec 11. 1973. M amended u
 41 PR 12651. Mar. t<. 19761

 III1S  Amendment  of  Spill  Prevention
    Control  and Countermeuure Plsni by
    ownen or operator*.

   If such tech*
 nology has been field-proven  at the
 time of the review.
  (c) No amendment to an SPCC Plan
 shall b* effective  to  satisfy the re-
 quirements  of this section  unless  It
 has  been certified  by  a Professional
 Engineer    in   accordanc*    with
for violation of OH
• til* CMI
         i or operators of faculties sub-
Jtot 10  I 111*  or  who  vlo»
lalo tho requirement* of this Part 119
by faOlag or refusing to comply with
any of the provision* of 11124.11114
or I112J shan be liable fora dvfl pen-
alty of not more than SS.OOO for each
day  such  violation  continue*. CIvO
penalties) shall bo Imposed  In accord-
ance with procedures set out In Part
114 of this Subchapur O.
                              § 11Z7

 
 (39 PR 31602. Aue, J9. 1»74)

 1112.7 Guidelines for the preparation and
    Implementation of a Spill Prevention
    Control tnd Counter-Mature Plan.
  The SPCC Plan shall be a carefully
 thought-out plan, prepared In accord-
 ance  with good engineering practices.
 and which has the  full  approval  of
 management at a level with authority
 to commit the necessary resources. If
 the plan  calls for  additional facilities
 or procedures, methods, or equipment
 not yet fully  operational, these items
 should be discussed In separate  para-
 graphs, and the details of Installation
 and operational start-up should be ex-
 plained   separately.   The  complete
 SPCC Plan shall follow the sequence
 outlined below,  and Include a discus-
 sion of the facility's conformance with
 the appropriate guidelines listed:
  (a) A facility which has expenenced
 one or more spill events within twelve j
 months prior  to the  effective date  of i
 this part should Include a written de-
 scription of each such spill, corrective
 action taken and plans for preventing
 recurrence.
  (b)  Where  experience  indicates  a
 reasonable  potential  for  equipment
 failure (such  as tank  overflow, rup-
 ture,  or leakage),  the plan should In-
 clude  a  prediction  of the  direction.
 rat* of flow, and total quantity of oil .
which could be discharged from the
 facility as a result of each major type
of failure.
  (c) Appropriate containment and/or
 diversionary structure*  or equipment
 to prevent discharged ofl from reach*
 ing a navigable water course should be
 provided. On* of tho following preveo* ,
 liv* systems or Its equivalent should ;
b* used as a •»«••«•••"••?                 '
  (1) Onshore  facilitloc
  (U Olka*, berms or retaining  wail*
sufficiently teponrtou*   to contain
spfOedoO:
  (U)Curblnc
  (lit)  Culvertlnc.  gutters  or other
drainage systems; .
  
 Weir*, boom* or other barriers:
  (v) SpUl diversion poodK
  (vt) Retention ponds
  (vil) Sorbent material*.
  (3) Offshore facilltlec
                                   12-45
                                         Appendix E  pg  6 of 13
-------
§11X7

  (I) Curbing, drip pans:
  (11) Sumps and collection systems.
  (d) When It Is determined that the
Installation of structures or equipment
listed  in  I 112.7(O  to  prevent dis-
charged  oil from reaching the naviga-
ble waters Is not practicable from any
onshore  or offshore facility, the owner
or  operator  should  clearly  demon-
strate  such Impracticability and pro-
vide the  following:
  (1) A  strong  oil spill  contingency
plan following the provision of 40 CFR
Part 1M.
  (2) A written  commitment of man-
power, equipment  and materials re-
quired to expeditiously  control and
remove any  harmful quantity of oil
discharged.
  (e) In  addition to the minima] pre-
vention   standards   listed   under
i 112.7(c). sections of  the Plan should
include a complete discussion of con-
formanee with the following  applica-
ble guidelines, other effective spill pre-
vention  and  containment procedures
(or. If more stringent,  with State rules.
regulations and guidelines):
  (I) facility drainage (oiunoreX* (ex-
cluding   production  /acilittat).  (1)
Drainage from  diked  storage  areas
should be restrained by valves or other
positive  means to  prevent a  spOl or
other excessive leakage  of on Into the
drainage  system or  Inplant effluent
treatment system, except where plan
systems  are  designed to handle  such
leakage.  Diked areas  may be emptied
by pumps or ejectors: however, these
should be manually activated  and the
condition of  the  accumulation should
be examined  before starting to be sure
no  ofl win  be  discharged Into the
water.
  (11) Flapper-type drain valves should
not  be  used to  drain  diked  areas.
Valves used for the drainage of diked
areas should, as far as practical, be of
manual, open-and-cleeed design. When
plant  drainage  drains directly Into
water courses and not into wastewater
treatment  plants,   retained   storm

In paragraphs (eXlXlil) (B).  (O and
-------
 Environmental Protection
 not cause i harmful discharge as de-
 fined in 40 CFR Part 110.
  
 fectlve  Internal heating coils, the fol-
 lowing  factors should be considered
 and applied, as appropriate.
  (A) The sts*m return  or exhaust
 linos from Internal heating coOs which
 discharge into an open  water course
should bo monitored for  contamina-
 tion, or  passed  through a settling
 tank, skimmer, or other separation or
 retention systeoa.
   Tte* feasibility of Installing an
    . .ml heaUnt system should also be
  (vlll) New and eld tank !nstanai__
should, as far as practical, be fsD-eale
engineered or updated Into a fan-safe
engineered Installation to avoid spOJs.
Consideration should be given to pro*
                              §1117

 vidmg one or more of the following de-
 vices:
  (A) High liquid level alarms with an
 audible or visual signal at a constantly
 manned operation or surveillance sta-
 tion:  in smaller plants an audible air
 vent may suffice.
  (B) Considering size and complexity
 of the facility, high liquid level pump
 cutoff devices set to stop flow at a pre-
 determined tank content level
  (C)  Direct  audible or code  signal
 communication  between   the  tank
 gauger and the pumping station.
  (D) A fast response system for deter-
 mining the  liquid level  of  each bulk
 storage tank such as digital comput-
 ers, telepulse. or direct  vision gauges
 or their equivalent.
  (E)  Liquid   level  sensing  devices
 should be regularly tested  to  Insure
 proper operation.
  (Ix)  Plant effluents which are dis-
 charged  Into navigable  waters should
 have  disposal facilities  observed fre-
 quently  enough  to  detect  possible
 system upsets that could cause an oil
 spill event.
  (x) Visible oil leaks which result In a
loss of oil from tank seams, gasket*.
 rivets  and bolts sufficiently large to
cause the accumulation of on in diked
 areas should be promptly corrected.
  (xi)  Mobile  or portable oil storage
 tanks  (onshore) should be  positioned
or located so as to prevent spilled oil
 from reaching navigable waters. A sec-
ondary means of containment, such a*
dikes or catchment basins, should be
furnished for the  largest single com-
 partment or  tank.  These faculties
should be located  where  they  will
 not be subject to periodic flooding or
 washout.
  (9)   /acuity  tmiuyvr  oswmMou
          anel to-pfSMf process  (on-
        (excfuettitf  •foetecMow  /scttf-
 desk  (1)  Buried pipinc  Installations
should have a protective wrapping and
coating and should be  fiihodirally
 protected if soQ conditions warrant If
 a section of bulled line to exposed ...
 any reason. It should be carefully ex-
 amined for deterioration. If corrosion
 damage to found, additional examlna-
 Uon and corrective action should be
 taken  as Indicated by the  magnitude
 of the damage. An  alternative would
                                  12-47
                                      Appendix E  pg  8 of 13
-------
 be the more frequent use of exposed
 pipe corridors or galleries.
  (II) When a pipeline is not In service.
 or  in standby service for  an extended
 time  the terminal  connection at  the
 transfer point should  be capped  or
 blank-flanged,  and  marked  as   to
 origin.
  (ill) Pipe supports should be proper-
 ly  designed to minimize abrasion and
 corrosion and allow for expansion and
 contraction.
  (iv) All aboveground valves and pipe-
 lines should be subjected to regular
 examinations  by operating  personnel
 at which time the general condition of
 items, such as flange joints,  expansion
 joints, valve glands  and bodies, catch
 pans,  pipeline supports, locking  of
 valves,  and metal  surfaces should  be
 assessed. In addition, periodic pressure
 testing may be warranted for piping In
 areas where facility drainage is such
 that  a failure might  lead  to a spill
 event.
  (v)  Vehicular traffic granted entry
 Into the facility should be warned ver-
 bally or by appropriate  signs to  be
 sure that the vehicle, because of  Its
 size, wfll not endanger above ground
 piping.
  (4) facility tank car and tank (rack
 loading/unloading nek (onshore).  (I)
Tank car and tank truck loading/un-
 loading procedures  should  meet the
minimum requirements and regulation
established  by  the  Department  of
Transportation.
  (11)  Where rack area drainage doe*
not flow Into a catchment basin  or
treatment facility designed  to handle
spills, a quick drainage system should
be used for tank truck loading and un-
loading   anas,  Th*   containment
system should be designed to hold at
least maximum capacity of any single
compartment  of a  tank car or tank
truck loaded or unloaded in the plant.
  (HI) An Interlocked warning light or
physical barrier system,  o
signs, should be provided I
•mlMjtt^ areas to prevent  vehicular
departure before complete disconnect
of flexible or fixed transfer Unas.
  (Iv) Prior to fOUng and departure of
any tank ear or tank truck, the lower-
most dram and aD outlet* of such ve-
hicle* should be closely examined for
leakage, and If necessary,  tightened,
              40 CFI Ch. I (7-1 -17 Edition)

     adjusted, or replaced to prevent liquid
     leakage while in transit.
       (S)  OH production  facilities  (on-
     jAore>—<|) Definition. An onshore pro-
     duction facility may  include all wells.
     flowlines. separation equipment stor-
     age, facilities, gathering lines, and aux-
     iliary      non-transportation-related
     equipment  and  facilities In a single
     geographical oil  or gas field operated
     by a single operator.
       (II) Oil  production facility (otuJiore)
     drainage. (A)  At tank batteries  and
     central treating stations where an ac-
     cidental discharge of oil would  have a
     reasonable possibility of reaching navi-
     gable waters, the dikes or  equivalent
     required  under  | UM(cXl)   should
     have drains closed and sealed at all
     times except when rainwater is being
     drained. Prior to drainage, the diked
     area should be Inspected as provided
     in paragraphs t'«t ofl should
     be visually etamlned by a competent
     person  for  condition  and  need  for
           Such evtminstlon should In-
     clude the foundation and supports of
     tank* that are above the surface of
     the ground
12-48
      Appendix  E pg  9 of 13
-------
 Environmental Protection Agoncy

  (D) New and old unk bactery instal-
 lations should, as far as practical, be
 fail-safe engineered or updated into a
 (ail-safe engineered insuilation to pre-
 vent spills.  Consideration should  be
 given to one or more of  the following:
  (1) Adequate unk capacity to assure
 that a unk will  not  overfill should a
 pumper/gauger be delayed in making
 his regular rounds.
  (2)  Overflow  equalizing  lines  be-
 tween  Unks so  that a  full tank  can
 overflow to an adjacent tank.
  (J) Adequate vacuum  protection to
 prevent Unk collapse during a pipeline
 run.
  (*) High level sensors to  generate
 and transmit an alarm  signal  to  the
 computer where facilities are a part of
 a computer production control system.
  (iv> Facility tnruftr operations, oil
 production facility (out/lore). (A) All
 above   ground valves and   pipelines
 should be  examined periodically on a
 scheduled  basis for general condition
 of items such  as flange joints, valve
 glands  and bodies, drip pans, pipeline
 supports,  pumping  well polish   rod
 stuffing boxes,  bleeder and  gauge
 valves.
  (B) Salt water (oU field brine) dis-
 posal   facilities  should   to  exalned
 often,  particularly following a sudden
 change in atmospheric temperature to
 detect  possible  system  upsets that
 could cause an oil discharge.
  (C) Production  faculties should have
 a program of flowline maintenance to
 prevent spills from  this source. The
 program should  Include periodic  ex-
 aminations, corrosion protection, flow-
 line    replacement,   and  adequate
 records, as appropriate,  for the Indi-
 vidual facility.
  (6) OU drUHn0 «*d vorkover Jocttt-
 titt  (oiutofv). (1) Mobile drilling  or
 workover equipment  should to posi-
 tioned  or  located so as to prevent
 spilled  oO  from  reaching  navigable
 watem.
  (U)  Depending fx t^e   location.
 catchment toatu or diversion struc-
 tures may to necessary to Intercept
 and contain spffls of fuel, crude ofl. or
oUy drilling fluids.
  (Ill) Before drilling below any easing
string or during  workover operations,
a blowout prevention (BOP) assembly
and well control system should to In-
                                 §112.7

    stalled that is  capable of controlling
    any well head pressure that is expect-
    ed to be encountered while that BOP
    assembly  Is on the  welL Casing and
    BOP Installations should be in accord-
    ance with State regulatory agency re-
    quirements.
      (7) Oil dnUtny. production, or vark-
    ovtr facilitiet (o/TMort). (I) Definition:
    "An  oil  drilling,  production or wor-
    kover facility (offshore)" may Include
    all drilling  or workover equipment.
    wells, flowllnes. gathering lines, plat-
    forms, and  auxiliary  nontranspona-
    tlon-related  equipment and  facilities
    in a single geographical oil or gas field
    operated by a single operator.
      (11)  Oil drainage  collection  equip-
    ment  should be used  to prevent and
    control   small  oil  spillage  around
    pumps, glands,  valves,  flanges, expan-
    sion joints, hoses,  drain lines, separa-
    tors,  treaters. tanks,  and allied equip-
    ment. Drains on the  facility should be
    controlled and directed toward a cen-
    tral collection sump  or equivalent col-
    lection system  sufficient to prevent
    discharges of  oU  Into the  navigable
    waters of the  United  States. Where
    drains and sumps  art  not practicable
    oil contained In collection equipment
    should to removed as  often as neces-
    sary to prevent overflow.
      (Ill) For faculties employing a sump
    system,  sump  and drains should to
    adequately steed and a spare pump or
    equivalent method should to available
    to remove liquid from the sump and
    assure that oU does not escape. A regu-
    lar scheduled preventive maintenance
    Inspection and testing program should
    to employed to assure reliable oper-
    ation of the liquid removal system and
    pump  start-up device.  Redundant
    automatic sump pumps and control de-
    vices may to required  on
     (hr) In areas where separators sad
    treaters  are  equipped  with  dump
    valves whose  predominant mode  of
    faflure to In the closed  position and
    pollution risk  to  high, the  facility
    should to specially equipped to pre-
    vent the escape of ofl. This could  to
    accomplished by extending the flare  I
    line to a diked area If the separator to  '
    near shore,  equipping It with a high  ;
    liquid level sensor that wffl automati-
    cally  shut-in wells producing to the
12-49
       Appendix E pg  10 of 13
-------
 separator,  parallel redundant  dump
 valves, or other feasible alternatives to
 prevent oil discharges.
  (v)  Atmospheric storage or  surge
 tanks should  be  equipped with  high
 liquid level sensing devices or other ac-
 ceptable alternatives to prevent oil dis-
 charges.
  (vl)   Pressure   tanks  should  be
 equipped with high and low pressure
 sensing devices to activate an alarm
 and/or  control the flow or other ac-
 ceptable alternatives to prevent oil dis-
 charges.
  (vii) Tanks should be equipped with
 suitable corrosion protection.
  (vlll)  A  written procedure  for In-
 specting and testing pollution preven-
 tion equipment and systems should be
 prepared and maintained at the facili-
 ty. Such procedures should be includ-
 ed as pan of the SPCC Plan.
  (Ix) Testing and inspection of the
 pollution prevention  equipment and
 systems at the facility should be con-
 ducted by the owner or operator on  a
 scheduled  periodic basis commensu-
 rate with the complexity, conditions
 and circumstances of  the facility or
 other appropriate regulations.
  (x)  Surface  and  subsurface  well
 shut-In valves and devices In use at the
 facility   should  be  sufficiently do-
 scribed to determine method of activa-
 tion or control. tg~ pressure differen-
 tial, change In fluid or flow conditions.
 combination  of pressure  and  flow.
 manual  or remote  control  mecha-
 nisms. Detailed records for each wen.
 whOe not necessarily pan of the plan
 should be kept by the owner or opera-
 tor.
  (xl) Before drming below any casing
string, and during workover operation*
 a blowout  preventer (BOP) assembly
 and weU control system ahould be in-
stalled that to capable of controUtng
 any well-head pressure that to expect-
ed to be encountered whfle that BOP
 •••mnlT to on the wett Casing and
 BOP taatanattom should be In accord-
    i with State regulatory agency re-

 'OoD   extraordinary  won  control
 measures ahould  bo provided  should
 emergency condtUom. Including fir*.
 loss of control and other abnormal
 conditions, occur. The degree of con-
 trol system redundancy ahould vary
           40 CFt Ch. I (7-M7 Edition)

   with hazard  exposure  and probable
   consequences of failure. It is recom-
  , mended that surface  shut-In systems
   have redundant or "fail close" valving.
   Subsurface safety  valves may not  be
   needed In producing wells that will not
   flow but  should be  installed  as re-
   quired by applicable State regulations.
    (xiii)  In  order  that there will be no
   misunderstanding of Joint  and  sepa-
   rate duties and obligations to perform
   work In  a safe  and  pollution  free
   manner, written instructions should be
   prepared by the owner or operator for
   contractors  and  subcontractors   to
   follow whenever contract activities in-
   clude servicing a well or systems ap-
   purtenant  to a well or pressure  vessel.
   Such  Instructions  and  procedures
   should be  maintained at the offshore
   production facility. Under certain cir-
   cumstances and  conditions such  con-
   tractor activities may require the pres-
   ence at  the  facility of an  authonxed
   representative of the owner or  opera-
   tor who would intervene when  neces-
   sary to prevent a spill event.
    (xiv) All manifolds (headers) should
   be equipped with check valves on indi-
   vidual flowlinea.
    (xv> If the shut-in weD pressure is
   greater than the working pressure  of
   the flowline and manifold valves up  to
   and Including the header valves associ-
   ated with that Individual flowline. the
   flowline should  be equipped with a
   high pressure sensing device and shut-
   in valve at the wellhead unless provid-
   ed with a pressure relief system to pre-
   vent over pressuring.
    
-------
 Environment*! Protection Agoncy

 in accordance with written procedures
 developed Tor the facility by the owner
 or operator. These written procedures
 and a record of the Inspections, signed
 by the appropriate supervisor or In-
 spector, should be made pan of the
 SPCC  Plan  and  maintained  for  a
 period of three yean.
   (9) Security (excluding oil  produc-
 tion facilities. (1) All plants handling.
 processing, and storing  oil  should bt
 fully   fenced,  and  entrance  taut
 should be locked and/or guarded when
 the plant Is not In production or is un-
 attended.
   (li) The master flow and drain valves
 and any other valves that will permit
 direct outward flow of the tank's con-
 tent to the surface should be securely
 locked  In the closed position when la
 non-operating or non-standby status.
   (Ill) The starter control on all oil
 pumps should be  locked in  the  "off-
 position or located at a site accessible
 only to authorized personnel  when the
 pump* are in a non-operating  or non-
 standby status.
   (iv) The  loading/unloading connec-
 tions of ofl pipelines should be secure-
 ly capped or blank-flanged  when not
 In service or standby service for an ex-
 tended time.  Thia security  practice
 should  also apply to pipelines that an
 emptied of  liquid content  either by
 draining or by inert gas pressure.
   (v> Facility lighting should be com-
 mensurate with the type and location
 of the  faculty. Consideration should
 be given to: (A) Discovery of spttte oc-
 curring during hours of darkness, both
 by operating personnel. U present, and
 by non-operating personnel (the gen-
 eral public, local police,  etc.) and (B)
 prevention of spins occurring through
 §*f f of vandalluav
  (10) Personnel  {retain*  end rvUZ
 pnroenMo*  •roctshirm (I) Owners or
 operators art responsible for property
 inatrucUng their personnel m the op-
 eration and maintenance of equipment
 to prevent  the dischargee of ofl and
 applicable poOuUon ear UM. tana, rulee
 and regulatlonc.
  (U) dch ippUccMo faculty should
 have a dciignitcd person who to ac-
countable for oO spm prevention and
who report! to line management.
  till)  Ownen or  operators  should
schedule and conduct spill prevention
                    Pi. Ill Appendix

 briefings for their operating personnel
 at intervals frequent enough to assure
 adequate understanding of the SPCC
 Plan for that facility.  Such briefings
 should highlight and  describe known
 spill events or failures, malfunctioning
 components,  and  recently developed
 precautionary measures.
          —MmoKAHVUM  or   UNBKB-
  STANDING Brrwmt THE SSCXXTAAY or
  TftAMSFOETATIOH AKD TH*  ADKimS-
  TJUTOH or not ExvatomoarTAi. Pio-
  ncnoN ActHcr

         section ii—osmrmom

  The  Environmental  Protection Aeeney
and  the  Department of  Transportation
acrot that for the purposes of Executive
Order 11341. the Una:
  (1)  "Mon-trmnsporuUon-reUted  onshore
and offshort faculties" means:
  (A) Fixed onshore and offshore oil veil
drilling  facilities Induding all equipment
and appurtenances related thereto used  In
drilling operations for exploratory or devel-
opment  wells, but excluding any terminal
facility, unit or process tategrally ssaortstid
with the handling or transferring of oil  In .
bulk to or from a veaeeL
  (8) Mobile onshore and offshore en well
drilling platforms, barges, trucks, or other
mobile facilities Including aO equipment and
appurtenance* related  thereto  whoa such
noolle facilities are fixed m poettlea for the
purpose of drilling operation* for explorato-
ry or development wells, but excluding soy
terminal facility, unit or process tategrally
amoclatid with the handling or tranaferring
of oil in bulk to or from a vissel.
  1C) Fixed onshore and offshore oO pro-
duction structure, platforms, derricks, and
USB taehidtng all equipment and appurte-
nances related thereto, as wen as completed
wells and the wellhead aeparaton. oO eepa-
raieta, and storage faculties wed In the pro-
faculty, unit or pretest integrally i	
wtth too handling or transferring of oO to
baft to or from a i
  (0)
            went and
                               its the
preductto* of efl when stun sseafle fadUUes
are fixed to poetUoa Her tke purpose of eO
production operational bet  oxchtdtag any
temlnal tacOlty. unH or process tategrally
associated with the handling or transf erring
of oil to bulk to or from a i
                                   12-51
                                           Appendix E  pg  12  of  13
-------
 §113.1

  (E)  Oil  refining  facilities  including  all
 equipment and ippurtenances related there-
 to as well as m-plant processing uniu. stor-
 M«  uniu.  piping,  drainage  systems  and
 waste  treatment units used in the refining
 of oil. but excluding any terminal facility.
 unit or  process  Intetrally associated  with
 the handling or transferring of oil In bulk to
 or from a vessel
   Industrial. commerctsJ. agricultural or
 public facilities which use and store oil. but
 excluding  any  termmaJ  facility,  unit  or
 process integrally associated  with  the  han- .
 dllng or transferring of oil  in  bulk to or
 from a vessel.
  (H) Wast* treatment facilities Including
 In-plant  pipelines, effluent discharge lines.
 and  storage  tanks, but  excluding wasu
 treatment  facilities located on vessels and
 terminal storage tanks  and appurtenances
 for the  reception of oily ballast  water or
 tank washings from vessels and associated
systems used for off-loading vessels.
  (1) Loading rack*, transfer host*, loading
arms and other equipment which art appur-
tenant to a nontransporution-relaud facili-
 ty or terminal facility and which are used to
 transfer oil In  bulk to or from highway vehi-
cle* or railroad ears.
  (J)  Highway vehicles  and  railroad  can
which  are used for the  transport of ofl ex-
clusively within the confines of a nontrans-
porution-related facility and which ant not
intended to transport oil  in  Interstate  er
ifltTVUfttt COttflMFQwl*
   Pipeline systems which an  need for
the transport  of ofl exclusively within the
confines of i  nontraMporuuoo-relaud fa-
culty or terminal facility and which an oat
Intended to transport oO  la  Interstate or
tntrasute commerce, but excluding pipeline
systems  ated u transfer ofl IB bulk to or
frOSB a VeOML
  tl> -Transportation-relate*
and]
              and offshore terminal f acft>
              transfer hoses, Inertlng arns
     8taoT equipment and  appurtenanoss)
     for IBO purpttio of  nandllnsT or tmisv
f errtai ofl IB bulk to or from a vessel u vtn
as gton«s Uak» and appurtenances for the
reception of oOy ballast water or tank vtsh-
Ing* from  vessels, but  excluding terminal
waste  treatment  fsfflltles and terminal ofl
storage facilities.
                                                      40 Ctt Ch. I (7-1-47 Edition)

                                               Transfer  hoses, loading  arms  and
                                            other equipment  appurtenant  to  a  non-
                                            transportailon-related  facility which Is used
                                            to transfer oil In bulk to or from a vessel.
                                               Interstate  and Intrasute onshore and
                                            offshore  pipeline systems  including pumps
                                            and  appurtenances related thereto  as well
                                            as in-line or breakout storage tanks needed
                                            for the continuous operation of a pipeline
                                            system, and pipelines from onshore and off-
                                            shore oil production  facilities, but excludinc
                                            onshore and offshore piping from wellheads
                                            to oil separators and  pipelines which are
                                            used  for the  transport of oil  exclusively
                                            within the confines of  a noniransporuilon-
                                            related  facility  or  terminal facility and
                                            which are not intended to transport oil In
                                            Interstate  or  Intrasute  commerce or  to
                                            transfer oil In bulk to or from a vessel.
                                               Highway  vehicles and  railroad can
                                            which are used  for  the transport of oil la
                                            Interstate  or Intrasute commerce and the
                                            equipment and appurtenances related there-
                                            to, and equipment used for the fueling of lo-
                                            comotive  uniu. as well as the nghu-of-way
                                            on which they operate. Excluded are high-
                                            way  vehicles and railroad  cars and motive
                                            power used exclusively within the confines
                                            of a nontransporution-related  facility  or
                                            terminal facility and which are not Intended
                                            for use in Inurstate or  Intrastau commerce,
                                       12-52
                                             Appendix  E  P8  13  of  13
-------
APPENDIX
    F
     12-53
-------
                                              40 CFR Ck. I (7-1-47
PART   114— CIVIL   PENALTIES  FOR
  VIOLATION  OF   Oil  POLLUTION
  PREVENTION REGULATIONS

NoH-T&AXSrOITATIO* ROjkTTB OftSMOU AW
          OrrsMoas PACIUTISB

Set
114.1
no
no
114.4
114.}
1H.6
114.1
114.1
114.10
114.11
General applicability.
Violation.
Determination of penalty.
Nolle* of Violation.
Request (or hearing.
Presiding Officer.
ConaoUdaUon.
Prcheartnc conference.
Conduct of hearing.
 Decision.
 Appeal to Administrator.
  Atmioamr Sea. 31UJ). JOKa). Pub. L.
9J-500. M Stat MS. US (SI OAC. IJ2HJ).
1381(a».

  Sounec J9 PR 31*02. Aug. M. If 14. unleai
otherwise noted.
    Now-TiujigrorTATioii
  ONSHOU AMP OrrsMOU P*ciura

1114.1  General applicability.
  Ownen or operator! of faculties sub-
ject to 11124 (a), (b) or (e) of this sub-
chapter who violate tht rtquirtmeou
of Part 112 of thta Subehapur D by
falling or refusing to comply with any
of the provisions of 11124. 113.4. or
112.5 of *hta cubchapter tK*n be liable
for a eivQ  penalty  of  not more  than
$5.000 for each day meh vtolatloa co»
Unuea. CtvO penalttea shall be i
and compromised m
thta part. Mo penalty ahaQ be i
until th« own** or operator  h*ji *»«
been flten notice and an opportunity
for hoarlnf In aecordanot with thta
part.
I11U
           tf  opessc..,
      be liable for a cM penalty for

of Pan 112 Ol U
Ing but not Umlted to failure tee
  (a)  Prepare  a Spffl Prevention
tool and Cov            	
In accordance with 11134 of thto
chapter.
  (b) Rave a SPCC plan certified by a
Recistered Professional  Engineer u
required by 1112.3 of thi* subchatUn
  (c) Implement the  SPCC pUn u Re-
quired by  1112.3 of this subchapun
  (d) Submit Information after a n>U
u required by 1112.4 of thta tubchap-
ten
    Amend  plan  at required  by
1112.4 of thta gubehapter.
  (f)  Implement  amendment u re-
quired by  1112.4 of thta tubcnapter.
  (f) Amend plan after change In facu-
lty desicn  u required by f 112.6 of thta
subchapun
    Amend plan  after re lew M re-
quired by  11124: or
  (j) Have amendment certified ai re-
quired by 11124  of thta tubchapter
and implemented.

I114J  DeUrnttMtloa e/ penalty.
  (a)  In determining the amount of
the penalty to be assessed the follow-
Ing factors shall be considered:
  (1) Gravity of the violation: and
  (3) Demonstrated good faith efforts
to achieve rapid compliance after noti-
fication of a vtolatlea.
  (b) The  amount  of the dvO penalty
to be assessed may be settled by com-
promise at any state of the  proceed-
ings.                           jw_
  (c> Civo  penalties may be assessed by
the  Regional  Administrator  where
there to no request for a bearing pur-
suant to 11144.

III44  NetineffVteeatiea.
  The Notice of Violation shall be sent
to the person charged with a  violation
and shall specify the
  (a) Pate of te«uanogj
  (b) Nature of violation. Including the
law or regulation  that he to charged
wlthviolatmc
  (e) Amount of the msjdmum penal-
ty:
  (d) Amount  of  the proposed  dvfl
                                 (e) The right to prsssnt written ex-
                                planations. Information or any materi-
                                atomaiOTw to the chars* or mmtt»>
                                gation of the penalty: or bearing  on
                                the parson's efforts to achieve eomptt-
                                •not after noUftaation of the violation:
                                 12-54
-------
 Environmental Protection Agency

  (f)  Manner of the payment of any
 money  which  may be  paid to the
 United States:
   The procedures for requesting a
 hearing including the right to be rep-
 resented by counsel.

 II14J Request for hearing.
  Within thirty (30) days of  the date
 of receipt of a Notice of Violation, the
 person named in the Notice may re-
 quest a hearing by submitting a writ-
 ten request signed by or on behalf of
 such  person by a duly authorized offi-
 cer,   director,  agent, or  attorney-in-
 tact,  to the Regional Administrator.
  (a)  Requests for hearings shall:
  (1)  State the name and address of
 the person requesting the hearing:
  (2)  Enclose a copy of the Notice of
 Violation: and
  (3)  State  with  particularity  the
 issues to be raised  by such person at
 the hearing,
  (b)  After a request  for  hearing
 which complies with the requirement*
 of paragraph (A) of this  section has
 been  filed, a hearing shall be sched-
 uled for the earliest practicable date.
  (c)  Extension* of UM time for the
 commencement of the hearing may be
 granted for good cause shown.

 Ill 4.1 FrtMClng Officer.
  The hearing shall be conducted by
 the Presiding  Officer. The Regional
 Administrator  may designate any at*
 torney In the  Environmental Protec-
 tion Agency to act as the Presiding Of-
 fleer.  No person shall serve as a Pre-
siding Officer when he hat any prior
connection with  UM case Indudlnc
without limitation UM performance of
Investigative or prosecuting functions
or any other such fuactiontwThe Pre-
siding Officer appointed shall  hav«
 UM Ml authority to conduct UM hoar-
 tag* decide Issues ***** to assess .a dvft
 penalty u appropriate.
• iuf
 The  Presiding Officer may. to  his
discretion, order consolidation of any
hearings held under this part and aris-
ing within one Region whenever he do-
»AM«ln*a *!••*  nttnmnllAmtittn •ffl AXBA.
                             § 114.9

tor may. in his discretion, order con-
solidation.  and designate one Region
to be responsible  for the  conduct of
any  hearings held  under  this  pan
which arise in different Regions when-
ever he determines that  consolidation
will expedite or simplify  the consider-
ation of the Issues presented. Consoli-
dation shall not affect the right of any
person to raise Issues that could have
been raised If consolidation had  not
occurred.  At the  conclusion of  the
hearing  the  Presiding  Officer shall
render a separate  decision for each
separate civil penalty case.

IIUJ  PrchMring conference.
  The Presiding Officer may hold one
or more prehearing conferences and
may issue  a hearing agenda which
may include, without limitation, deci-
sions with regard to any or all the fol-
lowing:
  (a) Stipulations and admissions:
  (b) Disputed Issues of fact;
  (c>  Hearing  procedures  Including
submission of oral or written testimo-
ny and the time allotted for oral argu-
ments: and
  (d) Any other matter which may ex- :
pedlte the hearing or aid In disposition '
of any Issues raised therein.

III4J  Conduct ef keariftg.              I
  The hearing shall be held In the gen- •
era! location of the facility where the
alleged violation occurred or as agreed ,
to by EPA  and the person charged. ;
The Presiding Officer shall have the
duty to conduct a fair and Impartial
hearing, to take action to avoid unnec-
essary delay m UM disposition of pro-
ceedings. and to maintain order. The
person charged with UM violation may
offer relevant facts, statements, expla-
nations, and other Item* which such
person feels should be considered m,
defense to the «* art**, bearing; on UM
termlncs thatot	
diu  or  simplify UM consideration of
the Issues presented. The Admlnistra-
       i efforts id achieve onmpHanm
after notifkatioB of UM  violation or
which may bear upon UM penalty to
be ass sens. The KPA or other appro-.
priate Agency  personnel shall have
the opportunity to offer  fact*. slat>~
meats, explai
Including testimony of other
ate Agencies personnel  la  order for
the Presiding Officer to be fully m-
                                  12-55
-------
§114.10

formed.  In  the  event  the  matter
cannot be  resolved by settlement the
person  charged  with  the  violation
shall be informed in writing, of the de-
cision  of the  Presiding  Officer and
shall be advised of his right to appeal.

91U.10  Decision.
  Within  thirty  (30)  days after the
conclusion of the hearings, the Presid-
ing Officer shall Issue findings with re-
spect to  the matter, including, where
appropriate to the amount of the civil
penalty.  In assessing the  civil penalty
the  Presiding  Officer shall  consider
the factors set forth in 1114.3. A copy
of  the  Presiding  Officer's  decision
shall be sent to the person charged in
the Notice of Violation.  The decision
of the Presiding Officer  shall become
the final decision of the Environmen-
tal Protection Agency unless within
fifteen (IS) days  from the date of re-
ceipt of such decision, the person as-
sessed  the penalty appeals  the  deci-
sion to the  Administrator, or unless
the  Administrator  shall  have stayed
the effectiveness of the decision pend-
ing review.

1114.11  App*&l to Administrator.
  (a) The person assessed a penalty IB
the Presiding Officer's determination
shall have the right to appeal an ad-
verse decision to the  Administrator
upon filing a written Notice of Appeal
in the form required by paragraph (b)
of this section within fifteen (IS) days
of the  d&te the receipt of the Presid-
ing Officer's decision.
  (b) The Netie* of Appeal shall:
  (l) State the name  and address of
the person f ilLrig the Notice of Appeal:
  (2) Contain a concise  statement of
the facts on which the person reUsc
  (3) Contain a eondM  statement of
the legal basis on which the person
relies; and
  (4) Contain a eofids* statement att>
ting forth the action «*&%> tas person
proposed that UM Artmiiilstrsuir take.
  (c) The Administrator may dtlcfsJ*
this authority to act m a sjtan cat*.
  (d)  The   Administrator,   aftar  a
Notice of Appeal in proper form has
been filed, shall render a decision with
respect to the appeal promptly. la ren-
dering his decision, the Administrator
may adopt, modify, or set aside the do-
         40 CFR Ch. I (7-1-47 Edition)

cision of the Presiding Officer  in any
respect  and shall include in his deci-
sion a concise statement of  the basis
therefore. The decision of the Admin-
istrator on  appeal  shall be effective
when rendered.
                                  12-56
-------
APPENDIX
    O
  12-57
-------
 Coast Guard, Del

  Subport B—Nolle* of the Discharge
   of OR or o Hazardous Sob»toneo

 I1U.M1  Purpose.
  The purpose at this subpart Is  to
 present* the manner  in which the
 notice required In section 311(bX3> of
 the  Act  U to be riven and to list the
 government  officials  to receive that
 notice.

 11S&M3  Procedure for the notice of at*
    charge.
  Any person in charge of a vessel  or
 of  an onshore or  offshore facility
 shall, as  soon as they have knowledge
 of any discharge of oil or a hazardous
 substance from such vessel or facility
 in violation of section 311(bX3) of the
 Act. immediately notify the National
 Response Center  (NRC). UA. Coast
 Guard.  2100  Second  Street.  SW*
 Washington. DC 20593. toil  free tele-
 phone number 800-424-S8Q2  (la Wash-
 ington. D.C metropolitan area, 42ft-
 2«7S).  If direct reporting to the NRC
 It not practicable,  report*  may  be
 made to  the Coast Guard or EPA pre-
 destinated OSC  for  the geographic
 ares, when the discharge occurs. AH
 such reports shall be promptly relayed
 to the NRC.  If It to not possible  to
 notify the NRC or the prertetlgntted
 OSC  immediately, report!   may  be
 made  immediately  to  the  nearest
 Coast  Guard  unit, provided  that the
 person la charge of the vessel or on-
 shore or offshore  faefllty notifies the
 NRC as soon as possible.
  Note geographical JurMlctiea of
Quart and CPA OWs are specified fa the
applicable lUfJeml Ceatinceacy Plan. Re-
gional ConUageacr Plain are available aft
Coast Quart Otttrtet Offleoi and «PA Re-
•tonal Offices as todtaat** to Table X Ad-
                         i for those of-
(Ices are listed fa Table L
(COO M-OffT. II n, STMe. May 1C. 1*M1
Act
 f-£;
I1IUM
  BeeOoa JllfbXS) of  the
Mrtbes) Uut any person w»
notify the appropriate ateaer of th*
TTnlted ftritfi OovenuBcnt tanmedlate>>
ty of » dlscharg* SB, upon eonvtetioo,
subject  to a fine of not more than
$10.000.  or to Imprisonment of not
more than one year, or both,
                                      § 153 JOS

           TABLE i.—AOOMESSCS ANO TCLEPHONC Nuu-
             BCRS or COAST GUAMO OISTNICT OFFICCS
             ANO EPA REGONAI. Omen
             IV.

             v_

             VI.
                   COIOJOI-J41X
                 til
                  1200 C»
                   Mtei.
              11*


              U*

              is*

              MO1


              1TK
       491 Ol«Hra 8V.
       VAS>0»-MM.
      .  KM* tan. tt
S.W. «• AM. Mont. «.
331SS.
                                      Hi »a -nil
                                            tan
           {COO M-Off. It Fit ntee. May l«, t»Ml
                                  12-58
-------
0153JOI

TA«U Z—STAMOAAO  AoMiMisnunvt  R«-
  own* or STATIS AND Co**csroMOi*a
  COAST GIMNO OKTNICTS AMD EPA RCOIOMS
                33 Cfll Ch. I (7-1-4* CdltlM)
TA«U  2.—STAMOAMO
  QiOKt of  STATCS  AND
  COAiT  GUAMO OtSTHICTS
  OKXS—Continued
                                       R|.
                                       ma
                                   EPA Re-
1«
          WM
          Ti«lT«H«nr«Ml
                                     COM
                                    11M
                                    tin
                                    tin

                                    11*
                                    11*
       rCOD M-MT. IIFR J7H4. May 1C 1MC1
   12-59
           Appendix G pg 2 of 2
-------
13.1  WORKSHOP F: UNDERGROUND STORAGE TANK (UST) COMPLIANCE
13.2  ATTACHMENTS
           "Facing the Unexpected; Cleanup of Underground Storage Tank Releases Using
           Pump and Treat Methods"

           Musts for USTs
-------
13.1  WORKSHOP F:  UNDERGROUND STORAGE TANK (UST) COMPLIANCE

Wayne Naylor. Chief UST/LUST Section EPA, Region III.

      Mr.  Naylor presented the requirements of the Underground Storage Tank Program
(UST). Program goals include preventing leaks in underground tanks, locating existing leaks,
cleaning up releases and building additional programs at the state  level. The federal UST
program regulates all petroleum and hazardous waste tanks that are underground. Farm and
residential heating oil tanks less than 1,100  gallons are excluded from the regulations.  The
following attainments present important points of the UST program as defined in the code of
federal regulations section 280.
                                       13-1
-------
m
        6<
               a
              o><

S
WD
.S
1


•
•
•
•o

4>
a.
X
v
5


*
u
V
•o
5
«*.
0
a.
3
s
CQ

M
c:
^
"S
f*.^
G6
en
•0
O
J=
•4^
a>
5?
•«^
a
5
•o
e
03

                                    13-2
-------
  = ^6

 -.a £ = a
        a 5 S « c

        K\n
         '3 Q

         II

         ?*.
         s *
        tiK-
IS1* i
|f2*l
l«*i
IP 11
iSlii
ii* H
!> * a|

  HI

  II!
         •a «

         •il
           I
 i

 llll
            I

              I
              1
                i  H
                » o. Bi
f
                 ^

                 11
                 lifiii
              MlHtM
              ill if i i  ,
                       fit
                      t
               lilt
              i  low
              •  B p < — r4 «^
            f^

            *
                             5 5 55
        i;
        r
        s^
        3
        I
           rl  ^^1 l !  rfl !
           Jl  ||1 i l« ff

       m Iht   j!
       lillil iliilHI I11"
                       i 1
                                         Si
                      J

                      i
              I
              I
                   {
    !i

11! Ii
                1
   u^    i  Lftl

   ll  I j   lijph \\

    IP 1   !i ifijl
  frJiSil JsnillHsg   !
  |C-<
-------
                 United States
                 Environmental Protection
                 Agency
            Office of
            Underground Storage Tanks
            Washington, D.C. 20460
EPA/530/UST-88/008
September 1988
oEPA
Musts  for  USTs

                                   - , ^ I^j*T'"^--^5SU;TM-psy T^ ^-=4^-!-lJgSagip^'1r.:^>'

                              13-4
-------
  Musts  for USTs

   A Summary of the New
Regulations for Underground
   Storage Tank Systems
U.S. Environmental Protection Agency
Office of Underground Storage Tanks
        September 1988
            13-5
-------
             Acknowledgement

The text of this booklet was prepared by Jay Evans for
    EPA's Office of Underground Storage Tanks.
                     13-6
-------
                      TABLE OF CONTENTS
What Are These Regulations About?*.
What Do New Petroleum USTs Need?-
What About Existing Petroleum USTs?	13


How Do You Correct Problems Caused By Leaks?		 19


How Do You Close USTs?		 23


What About Reporting And Recordkeeping?	___ 25


For Chemical USTs Only	- 27


Technical Questions & Answers	 31


Videos, Brochures, and Handbooks on USTs	 37


Industry Codes And Standards	 39
*The financial responsibility requirements are not summarized in this booklet  A complete explanation of
your financial responsibility requirements will appear in the Federal Register and in an EPA brochure later
in 1988.
                                       13-7
-------
                                                                                  PAGE I
     WHAT ARE  THESE REGULATIONS  ABOUT?

The U.S. Environmental Protection Agency (EPA) has written regulations for many of the nation's
underground storage tank systems. This booklet briefly describes the new technical requirements for
these systems, which include tanks and piping.  You can find the complete regulations in the Federal
Register.   Properly managed, underground storage tank systems ~ often called USTs - will not
threaten our health or our environment.
Why Has EPA Written These
New Regulations?

Several million underground storage tank sys-
tems in the United Stated contain petroleum or
hazardous chemicals. Tens of thousands of
these USTs, including their piping, are cur-
rently leaking. Many more are expected to leak
in the future. Leaking USTs can cause fires or
explosions that threaten human safety.  In addi-
tion, leaking USTs can contaminate nearby
ground water.  Because many of us depend on
ground water for the water we drink. Federal
legislation seeks to safeguard our nation's
ground-water resources.

Congress responded in 1984 to the problem of
leaking USTs by adding Subtitle I to the Re-
source Conservation and Recovery Act
(RCRA).  Subtitle I requires EPA to develop
regulations to protect  human health and the
environment from leaking USTs.
What Are The Goals Of The
UST  Regulations?

EPA has developed the  UST regulations to
make sure the following goals are reached:

   • To prevent leaks and  spills.

   • To find leaks and spills.

   * To correct the problems created by
      leaks and spills.

   • To make sure that owners and opera-
      tors of USTs can pay for correcting
      the  problems created  if their USTs
      leak.

   • To make sure each State has a regu-
      latory program for USTs that is as
      strict as or stricter than the Federal
      regulations.
                                       Of THE U.S.
                                     POPULATION  USES
                                    GROUND WATER AS A
                                    SOURCE OF DRINKING
                                         WATER
                                         13-8
-------
PAGE 2
                  WHY WORRY ABOUT LEAKS AND  SPILLS?
• Because your tank or Us piping may leak.  As
   many as 25 percent of all underground storage
   tanks (USTs) may now be leaking. Many more
   will leak in the near future, possibly  including
   yours.  Your tank or its piping might be leaking
   right now.  If a tank system is past its prime
   (over 10 years
   old), especially if
   it's not protected
   against corrosion,
   the potential for
   leaking  increases
   dramatically.
   Newer  tank
   systems
   (especially  the
   piping) can also
   leak, and spills can
   happen anytime.
   Don't let your
   profits drain away.
• Because it's in your best interest.
  Leaking UST sites can be very costly to
  clean up.  Imagine how much money
  you'd lose if your tank could not be used
  for weeks during lengthy cleanups or if
  local residents sued you for property
                        damages. The
                        costs can run into
                        the  thousands,
                        /perhaps as much
                        as $100,000 and
    	/ /              more.  Detect and
                        clean up spills or
                        leaks - before
                        they hurt you
                        financially.
• Because it's the law.  But it's the law for good
  reason.  Much of our country depends on
  ground water for drinking water, and leaked or
  spilled petroleum can contaminate  this  vital
  resource.  Explosions are another potential
  hazard.  Many  State and local governments,
  therefore, already require specific steps to
  prevent, detect, or clean up leaks and spills.
  Others will soon have  similar requirements.
  Check with your local  and State governments
  to learn what requirements apply to you.
• Because it's for the good of the
  community and the environment.  Leaks
  and  spills can have serious consequences.
  Petroleum can  contaminate soil, drinking
  water supplies, and air.  Petroleum and its
  resulting vapors can also accumulate in
  nearby confined spaces, such as septic
  tanks, sewers, and the basements of
  homes.  These  vapors are poisonous and
  can cause a fire or explosion.
                                            13-9 '
-------
                                                                                        PAGE 3
How Will  These Regulations
Affect  You?

The regulations describe the steps you -- the
tank owner or operator -- need to take to help
protect our health and environment  These
steps will also  help you avoid the high cost of
cleaning up the environment and defending
yourself in legal actions that can result if your
tank or its piping leaks.

You should note the following major points of
the UST regulations:

   •  If you install an UST after December
       1988, it must meet the requirements
       for new USTs concerning correct instal-
       lation, spill  and overfill  prevention,
       corrosion  protection, and leak
       detection  (see pages 7-11).

   •  If you have  an UST that was installed
       before December 1988, it must meet
       two major requirements  -

        1)  Requirements for corrosion protec-
           tion and spill and overfill preven-
           tion (see page  13).

       2)  Leak detection requirements (see
           pages  14-15).

   •  You must take corrective action in re-
       sponse  to  leaks (see pages 19-20).

   • You must follow closure requirements
       for tanks you temporarily or perma-
       nently close (see pages 23-24).

   4  You are financially  responsible for the
       cost of cleaning up a leak and compen-
       sating other people for bodily injury
       and property damage caused by your
       leaking UST.

Although these points are discussed in the fol-
lowing sections, additional  information  appears
in the "Technical Questions & Answers" sec-
tion starting on page 31.
What's  Your "Financial
Responsibility" For  Petroleum
Leaks?

A complete explanation of your financial re-
sponsibility requirements will appear in the
Federal Register and  in an EPA brochure later
in  1988.

In  general, owners or  operators of petroleum
USTs must be able to demonstrate their ability
to pay for damage that could be caused if their
tanks leaked.  These payments would need to
cover the costs of cleaning up a site (see page
20) and compensating other people for bodily
injury and property damage.


Who  Is  "The Regulatory
Authority"?

This booklet describes EPA's basic require-
ments for USTs, but your State or local regula-
tory authority may have requirements that are
somewhat different or more strict You will
need to identify  your  regulatory authority and
its specific requirements for your USTs.  If you
are not sure who your regulatory authority is,
call your local fire marshall for help.
                                              13-10
-------
PAGE 4
  What's An  "UST"?

  An UST is any tank, including underground
  piping connected  to the tank, that has at least
  10 percent of its volume underground.  The
  regulations apply  only to USTs storing  either
  petroleum or certain hazardous chemicals.

  The "For Chemical USTs Only"  section starting
  on page 27 identifies hazardous chemicals and
  special requirements for chemical USTs.  Gen-
  erally, the requirements for both petroleum and
  chemical USTs are very similar.

  Some kinds of tanks are not covered by these
  regulations:

      •  Farm and  residential tanks holding
         1,100 gallons or less of motor fuel used
         for noncommercial  purposes.

      •  Tanks storing heating oil used on the
         premises where it is stored.

      •  Tanks on or above the floor of under-
         ground areas, such as basements or
         tunnels.
    •  Septic tanks and systems for collecting
       storm water and wastewater.

    *  Flow-through process tanks.

    *  Tanks holding 110 gallons  or less.

    •  Emergency  spill and overfill tanks.

Other storage areas that might be considered
"tanks" are also excluded, such as surface im-
poundments and pits.  Some "tanks," such as
field-constructed  tanks, have been deferred
from most of the regulations.  The regulations
published in the Federal Register fully iden-
tify various tank  types and which  requirements
apply to them.
                     Excluded
                   by Congress
                                Excluded
                                by EPA
                                                                                   Petroleum
                                                                             Chemical
                                                                     Deferred
                                        UST Program Scope
                                                13-11
-------
              WHY DO USTs CAUSE PROBLEMS?
                                                                                   PAGES
No Corrosion Protection

Most of the UST systems
already in the ground have tanks
and piping made of bare steel.
When unprotected steel is buried
in the ground, it can be eaten
away by corrosion.  The UST
regulations require  corrosion
protection for all USTs. The
"Technical Questions &
Answers" section explains how
corrosion works and ways to de-
feat it (see pages 31  and 32).
Spills and Overfills

In addition to leaks from tanks and
piping, spills and overfills cause
many UST releases.  When more
petroleum is delivered into the tank
than it can hold, an overfill happens.
When the delivery truck's  hose  is
disconnected incorrectly, a spill
results.  The "Technical Questions
& Answers" section identifies ways
to combat spills  and  overfills (see
page 33).
Installation  Mistakes

Tanks and piping also leak if they
are not put in the ground properly.
For example, if poorly selected or
compacted backfill material is used
when covering the UST, or if pipe
fittings are inadequately attached to
the UST, then leaking can result
You can avoid mistakes made
during  installation by  using an
installer who carefully follows
approved installation  procedures.
The "Technical Questions &
Answers" section identifies ap-
proved installation procedures (see
page 33).
Piping Failure

EPA studies show that most leaks
result from piping failure.  Piping is
smaller and  less sturdy than tanks.
It is assembled in the  field with nu-
merous connections and usually in-
stalled near  the ground's surface.
As  a result,  piping suffers much
more  than tanks from  the effects of
installation  mistakes,  excessive
surface loads,  the stress  of
underground movement, and corro-
sion.  Using a skilled  installer is
even more critical to the proper
installation of piping.  It is impor-
tant to remember that the regula-
tions apply to the entire UST system
- both tanks and piping.
                                     13-12
-------
                                                                                PAGE?
       WHAT DO  NEW PETROLEUM USTs NEED?
You must meet four requirements when you in-
stall a new UST system:

   • You must certify that the tank and pip-
      ing are installed properly according to
      industry codes.

   • You must equip the UST with devices
      that prevent spills and overfills.  Also,
      you must  follow correct tank
      filling practices.

   • You must protect the tank and piping
      from corrosion.

   • You must equip both the tank and pip-
      ing with  leak detection.

The following sections provide basic informa-
tion on these requirements.  Also, see the
"Technical Questions & Answers" section
starting on page 31 for more information.
El
   Properly
   Installed
       Spill And
        Overfill
      Protection
            Protected
               From
            Corrosion
               ^Equipped
                     With
                     Leak
                  Detection
   REMEMBER...

   New UST systems are those that are installed
   after December 1988.

   Those USTs installed between May 1985. and
   December 1988 most meet two minimum re-
   quirements:

     • The UST must prevent releases due to
       corrosion or structural failure.

     • The stored contents must be compat-
       ible with the tank's interior wall.

   After December 1988, these older USTs must
   meet the requirements for existing USTs (see
   pages 13-17).
                                        13-13
-------
PAGES
   Installing UST  Systems The Right
   Way

   First, install USTs correctly by using qualified
   installers who follow industry codes.  Faulty
   installation is a significant cause of UST fail-
   ures, particularly piping failures.  (See pages
   33, 37 and 39 for information on correct instal-
   lation practices and industry codes.)  You must
       make sure that the contents you store are
             with the UST system.
  Srtund, you will also need to certify on a noti-
  fication form (see page 25) that you have used
  a qualified installer who can assure you that
  your UST has been installed correctly.
Preventing  Spills And Overfills

Because  human error causes most spills and
overfills, these mistakes can be avoided by fol-
lowing the correct Lank filling  practices re-
quired by the  UST regulations.  If you and your
distributor  follow these practices, nearly all
spills and overfills can be prevented from hap-
pening.  Also, the UST regulations require the
use of mechanical devices, such as spill catch-
ment basins and overfill  alarms,  to prevent
these releases  from narrnhf, the  environment.
(Correct  tank  filling pr •• •   •.; and preventive
devices arc identified c'i page 33.)
                                                13-14
-------
                                                                                              PAGE 9
Protecting Tanks And Piping From
Corrosion

Tanks and piping must be protected or they will
be eaten away by corrosion:
     • Steel tanks and piping can be coated
       with a corrosion-resistant coating and
       "cathodically" protected.  (Caihodic
       protection uses either  sacrificial anodes
       or impressed current, methods described
       on page 31.)
Tanks and piping can be protected by
other methods approved by the regula-
tory authority.
        Tanks and piping can be made totally of
        a noncorrodible material, such as fiber-
        glass-reinforced plastic.  (Metal  piping
        connected to  noncorrodible tanks still
        requires corrosion protection.)
Steel tanks (but not piping) can be pro-
tected using a method in which a thick
layer of noncorrodible material is
bonded to the tank.
                                                  13-15
-------
PAGE 10
   Detecting Leaks  From  Tanks

   You must check your tanks at least once a
   month to see if they are leaking.

   You must use one (or a combination) of the
   following monthly monitoring methods:
      • Automatic  tank gauging.

      + Monitoring for vapors in the soil.

      • Interstitial  monitoring.

      • Monitoring for liquids on the
         ground  water.

      * Other approved methods.
                         For Young Tanks...
                         An Alternate Leak Detection Method

                         You have one additional leak detection choice,
                         but only for 10 years after you install your
                         UST. Instead of using one of the monthly
                         monitoring methods noted  above, you  can
                         check for leaks by combining monthly inven-
                         tory control with tank tightness testing every 5
                         years.  After 10 years, you must use one of the
                         monthly  monitoring methods listed above.
   Information on these leak detection  methods
   appears in  the "Technical Questions  & An-
   swers" section on pages 34-35. (Special re-
   quirements for USTs containing hazardous
   chemicals are described in the "For Chemical
   USTs Only" section on pages 27-30. These
   USTs must use secondary containment and
   interstitial  monitoring.)
Vapor—I
Monitor
       Interstitial.
       Monitor
VT
2    1\
                                                                Tank Test
                                                              'Spill Device
                                             . In Tank
                                              Monitor
h
                                                     Monitoring
                                                       Well  -1
                                                                             Barrier w/
                                                                             Monitor
                                    Leak Detection Alternatives
                                              13-16
-------
                                                                                             PAGE 11
Detecting Leaks From Piping

Because most leaks come from piping, your
piping must have leak detection.

If your piping is pressurized,  you must meet
the  following requirements:
       The piping must have devices  to auto-
       matically shut off or restrict flow or
       have an alarm that indicates a  leak.

       You must either conduct an annual
       tightness test of the piping or use one of
       the following monthly methods noted
       above for tanks: vapor  monitoring,
       ground-water monitoring, interstitial
       monitoring, or other approved  monthly
       methods.
If your UST has suction piping, your leak de-
tection requirements will  depend on  which type
of suction piping you  have:

    *  The most commonly used suction piping
       requires cither monthly monitoring
       (using one of the four monthly methods
       noted above  for use on pressurized pip-
       ing) or tightness testing of the piping
       every 3  years.

    *  Another kind of suction piping is safer
       and does not require leak detection.
       This safer method has two main  charac-
       teristics:

       --  Below-grade piping is sloped so that
          the piping's contents will  drain back
          into the storage tank if the suction  is
          released.

      --  Only one check valve is included in
          each  suction line and is located di-
          rectly below the  suction pump.
                                                                                 Vent Pipes
                   Tank Truck
        Delivery Hose
                                                                                Line Leak
                                                                                Detectors
      Product Dispensers
                                           Product Delivery Line
                                    A Typical Tank Facility
                                                13-17
-------
                                                                               PAGE 13
    WHAT  ABOUT  EXISTING PETROLEUM  USTs?
Existing UST systems are those installed be-
fore December 1988.  In addition to immedi-
ately starting tank filling procedures that will
prevent spills and overfills, you will need to
meet the following requirements for corrosion
protection, spill and overfill prevention, and
leak detection.  (The chart on pages 16-17 dis-
plays these requirements and when  you must
meet them.)
Deadline For Corrosion  Protection
And For Devices To Prevent Spills
And Overfills

By December 1998 (10 years after the UST
regulations become effective),  USTs that were
installed before December 1988 must have:
                                                Corrosion protection for steel tanks
                                                and piping (see page 9).
                                              • Devices that prevent spills and
                                                overfills (see page 8).
                                            Although the regulatory deadline is in 1998,
                                            you should make these improvements as soon
                                            as possible to reduce the chance that you will
                                            be liable for damages caused by releases from
                                            substandard  USTs.
                                                         CAUTION/:
                                                            U
                                                        PASS
                                         13-18
-------
PAGE 14
  Deadlines And Choices  For Leak
  Detection
  Deadlines...

  Leak detection requirements are being  phased
  in for existing USTs depending on their age:
     If the tank was
     installed...
It must have leak
detection  by
December  or...
     before 1965 or unknown	 1989
     1965-1969	.	 1990
     1970-1974	 1991
     1975-1979	 1992
     1980-Dec.l988	 1993
  This schedule will make sure that the older
  USTs, which are more likely to leak, have leak
  detection first
                         Choices For Existing Tanks...

                         You have three basic choices for making sure
                         your tanks are checked at least monthly  to see
                         if they are leaking:
You can use any of the monthly
monitoring methods listed for new tanks
on page  10.

If your UST has corrosion protection or
internal  tank lining and devices that
prevent  spills and overfills, you can
combine monthly inventory control
with tank tightness testing every 5
years.  This choice, however, can only
be used  for 10 years after adding
corrosion protection or internally  lining
the tank  (or  until  December  1998,
whichever date  is later).  After 10 years,
you must use one of the monthly
monitoring methods on page 10.

If your UST does noi have corrosion
protection or internal tank lining and
devices  that  prevent spills and overfills,
you can combine monthly inventory
control  with annual tank tightness
testing.   Please note, however, that this
method  is allowed only until December
1998. After that,  your UST -- now
equipped with corrosion protection or  an
internal  tank lining, and devices that
prevent spills and overfills --  must use
one of the first  two leak detection choices
noted above.
                                        13-19
-------
Some Choices May Be Better...

You have a leak detection advantage if your
UST has been "upgraded" with corrosion pro-
tection and devices to prevent spills and over-
fills.  For 10 years after "upgrading," you can
use a leak detection method that will be less
costly and easier to apply than most other leak
detection  methods.  This method requires  you
to cqnduct monthly inventory control and  to
have tank tightness tests performed every  5
years (see page 14). By contrast, USTs that
have not  been "upgraded" must have tank
tightness  tests every year.
Choices For Existing Piping...

You have two basic choices of leak detection
for piping depending on the type of piping you
use:

   * By December 1990, existing
     pressurized piping must meet the leak
     detection requirements for new
     pressurized piping (see page  11).

   • Existing suction piping must meet the
     requirements for new suction piping
     (see page 11) at the same time the tank
     meets the leak detection schedule
     given above.
                                                       REMEMBER...

                                                       No matter which leak detection methods you
                                                       use for tanks and piping, they must be work-
                                                       ing by the deadlines described  above. If not,
                                                       you must close your UST or replace it with a
                                                       new UST.
                                                    The chart on pages  16-17 displays all
                                                    these leak  detection requirements and
                                                    the ones for corrosion  protection  and
                                                    spill  and overfill prevention.
                                                13-20
-------
PAGE 16
 WHAT DO YOU  HAVE TO DO?   Minimum Requirements

 You must have Leak Detection, Corrosion Protection, and Spill/Overfill Prevention.
 For WHEN you have to add these to your tank system, see the chart on the right.  	^-
LEAK DETECTION
NEW TANKS
2 Choices
EXISTING TANKS
3 Choices
The chart at the bottom of
the next page displays
these choices.
NEW & EXISTING
PRESSURIZED PIPING
Choice of one from each set
NEW & EXISTING
SUCTION PIPING
3 Choices
CORROSION PROTEC
NEW TANKS
3 Choices
EXISTING TANKS
4 Choices
NEW PIPING
2 Choices
EXISTING PIPING
2 Choices
• Monthly Monitoring*
• Monthly Inventory Control and Tank Tightness Testing Every 5 Years
(You can only use this choice for 10 years after installation.)
• Monthly Monitoring*
• Monthly Inventory Control and Annual Tank Tightness Testing
(This choice can only be used until December 1998.)
t Monthly Inventory Control and Tank Tightness Testing Every 5 Years
(This choice can only be used for 10 years after adding corrosion protection and
spill/overfill prevention or until December 1998, whichever date is later.)
• Automatic Flow Restrictor • Annual Line Testing
• Automatic Shutotf Device -and- • Monthly Monitoring*
• Continuous Alarm System (except automatic tenk 9au9ins)
• Monthly Monitoring*
(except automatic tank gauging)
• Line Testing Every 3 Years
• No Requirements
(if the system has the characteristics described on page 1 1 )
TISNKI ' •' '•••••• .j." ..• • • 	 ;• 	 '.. ..•;
TION 	 ."•: 	 ....;::......,......,.,,,...., . . . ^ ^ •
• Coated and Cathodically Protected Steel
• Fiberglass
• Steel Tank clad with Fiberglass
• Same Options as for New Tanks
• Add Cathodic Protection System
• Interior Lining
• Interior Lining and Cathodic Protection
• Coated and Cathodically Protected Steel
• Fiberglass
• Same Options as for New Piping
• Cathodically Protected Steel
SPILL /OVERFILL PREVENTION ?
ALL TANKS
• Catchment Basins -and- • Automatic Shutotf Devices -or-
• Overfill Alarms -or-
• Ball Float Valves
* Monthly Monitoring includes: Automatic Tank Gauging Ground-Water Monitoring
Vapor Monitoring Other Approved Methods
Interstitial Monitoring
                                     13-21
-------
                                                                                      PAGE 17
WHEN  DO  YOU  HAVE  TO ACT?     Important Deadlines
                        For WHAT you have to do, see the chart on the left.
TYPE OF
TANK & PIPING
New Tanks and Piping*
Existing Tanks**
Installed:
Before 1965 or unknown
1965-1969
1970 - 1974
1975 - 1979
1980 -December 1988
Existing Piping**
Pressurized
Suction
LEAK -
DETECTION
At installation
By No Later Than:
December 1989
December 1990
December 1991
December 1992
December 1993
December 1990
Same as existing
tanks
CORROSION
PROTECTION
At installation
^
t
> December 1998
December 1998
December 1998
SPILL /OVERFILL
PREVBmONJ:^^;
At installation
^
> December 1998
*
Does not apply
Does not apply
* New tanks and piping are those installed after December 1988
** Existing tanks and piping are those installed before December 1988
IF YOU CHOOSE TANK TIGHTNESS TESTING AT EXISTING USTs ...
   If you donl use monthly monitoring at existing USTs, you must use a combination of periodic tank
   tightness tests and monthly inventory control. This combined method can only be used for a few
   years, as the chart below displays.
     Was the UST 'upgraded',
     which means does it have
     corrosion protection and
      spill/overfill prevention
           devices?
          NO
YES  :
Was it 'upgraded'
     before
December 1988?
             NO
      Do monthly inventory
    control and a tank tightness
     test every vear until 1998;
      then 'upgrade'.  For
     •upgraded* USTs, use the
         box on the right.
         Do monthly inventory
       control and a tank tightness
        test every 5 years for 10
        years after 'upgrading';
       then do monthly monitoring.
YES
   Do monthly inventory
control and a tank tightness
  test every 5 years until
  1998; then do monthly
      monitoring.
                                          13-22
-------
                                                                                        PAGE 19
            HOW  DO YOU CORRECT  PROBLEMS
                           CAUSED  BY LEAKS?
What Do You Do When You Suspect
Your Petroleum UST Is Leaking?

Various warning signals indicate that your UST
may be leaking and creating problems for the
environment and your business.  You can avoid
most of these problems by paying careful atten-
tion to these warning signals and by taking the
appropriate actions.

Warnings From Equipment

You should suspect a leak when you discover
the following warning  signals from  equipment:

    •  Unusual operating conditions (such  as
       erratic behavior of the dispensing
       pump).

    •  Results from leak detection  monitoring
       and testing that indicate a leak.

You need to confirm quickly whether these sus-
pected leaks are real. What at first appears to be
a leak may be the result of faulty equipment that
is part of your UST system or its leak detection.
Double check this equipment carefully for fail-
ures.  You may simply need to repair or replace
equipment that is not working.

If repair or replacement of faulty equipment
does not solve the problem, then you must report
this finding to the regulatory authority and  con-
duct tightness tests of the entire UST system. If
these tests indicate a leak, you need to report to
the regulatory authority and  follow the actions
for a confirmed leak (see page 20).
Warnings In The Environment

You should also suspect a leak if evidence of
leaked petroleum appears at or near your site.
For example, neighbors might tell you they
have smelled petroleum vapors in their base-
ments or tasted petroleum in their drinking
water.  You might even discover evidence of
environmental damage as you investigate  the
suspected equipment failures discussed above.

Whenever evidence of environmental damage
is discovered, you must take the following ac-
tions:

   + Report this discovery immediately to
      the regulatory authority.

   • Conduct  tightness tests of the entire
      UST  system.

   • Investigate the UST site for additional
      information on the extent and nature of
      the environmental  damage.

The results of these system tests and site checks
will help answer the crucial question:  "Is my
UST leaking?"  If the answer is yes, then you
will need to follow the actions for responding
to confirmed leaks (see page 20).
                                              13-23
-------
PAGE 20
   What Do You Do When Your
   Petroleum UST  Leaks?
   Your response to confirmed leaks and spills
   (including  overfills) comes in two stages:
   short-term and long-term.
   Short-Term  Actions

      4  Take immediate action to stop and
          contain the leak or spill.
      * Tell the regulatory authority within 24
         hours that there is a leak or spill. How-
         ever, petroleum spills and overfills  of
         less than 25 gallons do not have to be
         reported if you immediately  contain and
         clean up these releases.

      • Make sure the  leak or spill poses no im-
         mediate  hazard to human health and
         safety by removing  explosive vapors
         and fire hazards.  Your fire department
         should be able to help or advise you
         with this task.  You must also make sure
         you handle contaminated soil properly
         so that it poses no hazard (for example,
         from vapors or direct contact).
    *  Find out how far the petroleum has
       moved and begin to recover the leaked
       petroleum  (such as product floating on
       the  water  table).

    +  Report your progress and any informa-
       tion you have collected to the regulatory
       authority no later than 20 days after you
       have confirmed a leak or spill.

    *  Investigate to determine if the leak has
       damaged or might damage the environ-
       ment.  You must report to the regulatory
       authority what you have learned from  a
       full  investigation of your site within 45
       days of confirming a leak or spill.  At
       the same time, you must also submit a
       report explaining how you plan  to re-
       move the leaked petroleum, if you  have
       found contaminated  ground water.  Ad-
       ditional site studies  may be required if
       necessary.

These actions are fully explained in the UST
regulations  and in a brochure (see page 38).

Some leaks and spills will  require additional,
long-term attention to correct the  problem.
Long-Term  Actions

Based on the information you have provided,
the regulatory authority  will decide if you must
take further  action at your site. You may need
to take two  more actions:

    4  Develop and submit a Corrective Action
       Plan that shows how you will meet
       requirements established for your site
       by the regulatory authority.

    *  Make sure you meet the requirements
       approved by the  regulatory authority for
       your site.
                                                 13-24
-------
                                                                                             PAGE 21
Can Leaking Tanks Be Repaired?

You can repair a leaking tank if the person who
does the repair carefully follows standard in-
dustry  codes that establish the correct way  to
conduct repairs.  (See page 39 for repair
codes.)

Within 30 days of the repair, you must prove
that the tank repair has worked by doing one of
the following:

    *  Having the  tank inspected  internally or
       tightness tested following standard
       industry  codes.

    •  Using one of the monthly leak detection
       monitoring methods (except for  the
       method combining inventory control
       and  tank tightness testing).

    *  Using other methods approved by the
       regulatory authority.
Can Leaking Piping Be Repaired?

Damaged  metal piping cannot  be repaired
and must be replaced.  Loose fittings can sim-
ply be tightened, however,  if that solves the
problem.
Within 6 months of repair, USTs with cathodic
protection must be tested to show that the
cathodic  protection is working  properly.

You must keep records for each repair as long
as you keep the  UST in service.
Piping made of fiberglass-reinforced plastic,
however, can be repaired, but only in accor-
dance with the manufacturer's instructions or
national codes of practice.  Within 30 days of
the repair, piping must be tested in the same
ways  noted above for testing tank repairs  (ex-
cept for internal inspection).
                                              13-25
-------
                                                                                        PAGE 23
                    HOW DO  YOU CLOSE USTs?
You can close your UST permanently or tem-
porarily.
Closing  Permanently

If your tank is not protected from corrosion and
it remains closed for more  than  12 months or
you decide to close it'permanently, you must
follow  requirements  for permanent closure:
       You must notify the regulatory authority
       30 days before you  close your UST.

       You must determine if leaks from your
       tank have damaged  the surrounding
       environment.  If there is damage, then
       you will have to take the corrective ac-
       tions described on page 20.

       You can either remove the UST from
       the ground or leave  it in the ground.  In
       both cases, the tank must be emptied
       and cleaned by removing all liquids,
       dangerous vapor levels, and accumu-
       lated sludge.  These potentially very
       hazardous actions need to be carried out
       carefully by  following standard  safety
       practices. (See pages 37 and 39 for
       sources of information on good  closure
       practices.) If you leave the UST in the
       ground, you must also fill it with a
       harmless, chemically  inactive solid,  like
       sand.  The regulatory authority will help
       you decide how best to close your UST
       so that it meets all  local requirements
       for closure.
Three Exceptions To Permanent
Closure

The requirements for permanent closure may
not apply to your UST if it meets one of the
following conditions:

    * If your UST  meets the requirements for
      a new  or upgraded UST, then it  can re-
      main  "temporarily"  closed  indefinitely
      as long as it  meets the requirements
      below  for a temporarily closed UST.

    * The regulatory authority can grant an
      extension beyond the  12-month  limit on
      temporary closure for USTs unprotected
      from  corrosion.

    * You can  change the contents of your
      UST to an unregul-ted substance, such
      as water.  Before you make this change,
      you must notify the regulatory author-
      ity, clean and empty the UST, and deter-
      mine if any damage to the environment
      was caused while the  UST held  regu-
      lated substances.  If there is damage,
      then you must take the corrective ac-
      tions described on page 20.
                                            13-26
-------
PAGE 24
  Closing  Temporarily

  Tanks not used for 3 to 12 months must follow
  requirements for temporary closure:
      * If your UST has corrosion protection
         and leak detection, you must continue to
         operate  these protective systems.  If a
         leak is found, you will have to respond
         just as you would for a leak from an
         active UST, as described on page 20.
         (If your UST is empty, however, you do
         not need to maintain leak detection.)

      • You must cap all lines, except  the vent-
         line, attached to your UST.
                                               13-27
-------
                                                                           PAGE 25
             WHAT  ABOUT REPORTING  AND
                       RECORDKEEPING?
What Do You Need To Report?

In general, you will only need to report to the
regulatory authority at the  beginning and end of
your UST  system's operating life:
   * When you install an UST, you have to
     fill out a notification form available
     from your State. This form provides
     information about your UST, including
     a certification of correct installation.
     (You should have already used this
     form to identify your existing USTs. If
     you haven't done that yet, be sure you
     do so now.)

   • You must report suspected releases to
     the regulatory authority (see page 19).
                     * You must report confirmed releases to
                       your regulatory authority.  You must
                       also report follow-up actions you plan or
                       have taken to correct the damage caused
                       by your UST (see page 20).

                     * You must notify the regulatory authority
                       30 days before you permanently close
                       your UST (see page 23).

                  You need to check with your regulatory author-
                  ity about the particular reporting requirements
                  in your area, including any additional or more
                  stringent requirements than those noted above.
                          REPORTING
  INSTALLATION
SUSPECTED
 RELEASE
CORRECTIVE       CLOSURE
   ACTION
                                   13-28
-------
PAGE 26
  What  Records Must  You Keep?

  You will have to keep records that can be pro-
  vided to an inspector during an on-site visit that
  prove your facility meets certain requirements.
  These records must be kept long enough to
  show your facility's recent compliance status in
  four major areas:
You should check with your regulatory author-
ity about the particular recordkeeping require-
ments in your area.  Generally, you should
follow  this useful rule of thumb for recordkeep-
ing:  When in doubt, keep it.
          You will have to keep records of leak
          detection performance and upkeep:

          — The last year's monitoring results,
             and the most recent tightness
             test.

          -- Copies of performance claims
             provided by leak detection
             manufacturers.

          — Records of recent  maintenance,
             repair,  and calibration of leak
             detection  equipment  installed
             on-site.
                              PETAILED
                              RECOPPS
          You will have to keep records showing
          that the last two inspections of your
          corrosion protection system were
          carried out by properly trained
          professionals.
          You must keep records showing that a
          repaired or upgraded UST system
          was  properly repaired or upgraded.
          For at least 3 years after closing an
          UST, you must keep records of the site
          assessment results required for
          permanent closure.  (These results
          show what impact your UST has had
          on the  surrounding area.)
                                                13-29
-------
                                                                                              PAGE 27
                     FOR  CHEMICAL  USTs ONLY
What Chemicals  Are Included In The
UST  Regulations?

Several hundred chemicals were designated  as
"hazardous" in Section 101(14) of the Com-
prehensive Environmental Response, Compen-
sation, and Liability Act of 1980, better known
as CERCLA or "Superfund."

The UST regulations apply to the same hazard-
ous chemicals  identified by CERCLA, except
for those listed as hazardous wastes. These
hazardous wastes  are  already regulated under
Subtitle C of the Resource Conservation and
Recovery Act and are not covered by the UST
regulations.   (See  40 CFR Parts 260-270 for the
hazardous waste regulations.)

Information on the CERCLA hazardous chemi-
cals is available from  EPA through the RCRA/
CERCLA Hotline at  l-(800)^24-9346 or (202)
382-3000.

The following  pages describe requirements  for
USTs that contain hazardous  chemicals ~ more
simply referred to as chemical  USTs.
   HAZARDOUS SUBSTANCE LIST
         (Partial Listing Only)
   REMEMBER...
   New UST systems are those that are installed
   after December 1988.

   Those USTs installed between May 1985 and
   December 1988 must meet two  minimum re-
   quirements:

      * The UST must prevent releases due to
        corrosion or structural failure.

      • The stored contents must  be compat-
        ible with the tank's interior wall.

   After December 1988, these older USTs must
   meet the requirements for existing  chemical
   USTs (see page 29).
  HAZARDOUS SUBSTANCE
Acouphlhcne
Acenaphthylene
Aceuldehyde
AceuJdehyde, chloro-
Acetaldehyde, tricloro-
Chromic nilfate
Choromium
CHROMIUM AND COMPOUNDS
Chromatis chloride
Chrytene
Cobaltoui bromide
Cobaltaus fotmite
Cobaltous tulfunate
Copper
    rcyinide
    3T
Famphur
Feme ammonium citrate
Feme ammonium oxalate
Feme chloride
Feme dextran
Feme fluoride
Feme nitrate
Feme nilfale
Keithane
Kepone
Luiocvpine
LEAD AND COMPOUNDS
Lead
Lead acetate
Leadarsenate
Lad chloride
Lead fluoborate
Lead iodide
Zinc nitrate
Zinc phcnoniUbnate
Zinc phosphide
Zinc silicoflouridc
Zinc ulfale
Zirconium nitrate
Zirconium sulfate
Zirconium tetnchlondc
                               CASRN*
  83329
  208968
  75070
  107200
  75876
10101538
 7440473

10049055
  218019
 7789437
  544183
14017415
 7440508
  544923


  52857
 1185575
 2944674
 7705080
 9004664
 7783508
10421484
10028225

   ^
  115322
  143500
  303344

 7439921
  301042
 7784409
 7758954
13814965
10101630
 7779886
  127882
 1314847
16871719
 7733020
13746899
14644612
10026116
•Chemical Abnncts Service Registry Number
                                           13-30
-------
PAGE 28
   What  Requirements Apply To New
   Chemical USTs?

   New chemical USTs have to meet the same
   requirements described earlier for  new petro-
   leum  USTs concerning correct installation,
   corrosion protection, spill and overfill  preven-
   tion, corrective action, and  closure.

   However, they must have secondary  contain-
   ment and interstitial monitoring as described
   below.

   Secondary  Containment

   All new chemical USTs must have "secondary
   containment."  A single-walled tank is the first
   or "primary" containment.  Using only pri-
   mary  containment, a leak can escape into the
   environment.  But by enclosing an UST within
   a second wall, leaks can be  contained and  de-
   tected quickly before harming the environment.

   There are several ways to construct secondary
   containment:

     • Placing one tank inside another tank  or
       one pipe inside another pipe  (making
       them  double-walled  systems).

     • Placing the UST system inside a
       concrete vault.

     • Lining the excavation zone around the
       UST system with a liner that cannot be
       penetrated by  the chemical.
Interstitial Monitoring

The chemical UST must have a leak detection
system that can indicate the presence of a leak
in the confined space between the first and the
second wall.  Several devices are available to
monitor this confined "interstitial" space.
("Interstitial"  simply means "between the
walls.")  The  UST regulations describe these
various methods and  the requirements for their
proper use.
You can apply for an exception, called a vari-
ance, from the requirement for secondary con-
tainment and interstitial monitoring.  Getting  a
variance will require a  lot of work.  You will
have to convince your  regulatory authority that
your alternative leak detection method will
work effectively  by providing detailed studies
of your site, proposed leak detection method,
and available methods  for corrective action.
Also, some States may not allow variances.
                                               13-31
-------
                                                                                          PAGE 29
 What  About  Existing Chemical USTs?

 Existing UST systems arc those installed before
 December 1988.  In addition to immediately
 starting tank filling procedures that  prevent
 spills and overfills, you will need  to meet the
 following requirements for existing  USTs.
                         There is a special deadline for pressurized
                         piping in December 1990.  At that time, exist-
                         ing pressurized piping must meet the require-
                         ments for new pressurized piping (described  on
                         page  11).
Protection From Corrosion And
Prevention Of Spills And Overfills

By December 1998 (10 years after the UST
regulations become effective), you must im-
prove your USTs installed before December
1988:

   • By adding corrosion protection to steel
     tanks and piping.

   • By using devices that prevent spills and
     overfills.

Although the regulatory deadline is in 1998,
you  should make these improvements as  soon
as you can to reduce the chance  that you will
be liable for  damages caused by  your sub-
standard  UST.
Leak Detection

Leak detection requirements are being phased
in for existing USTs depending on their age:
   If the tank was
   installed...
It must have leak
detection  by
December of...
   before 1965 or unknown	  1989
   1965-1969	  1990
   1970-1974	  1991
   1975-1979	  1992
   1980-Dec.l988	  1993
Choosing Leak Detection Methods
For Existing Chemical USTs

You  can meet the leak detection requirements
in one of the following three ways:

   * After December 1998, your UST must
     meet the same requirements for
     secondary containment and interstitial
     monitoring that apply  to new
     chemical USTs.

   * After December 1988, a variance can be
     granted if you  meet the same
     requirements described above for getting
     a variance for a  new chemical UST.

   • Until December  1998, you can use any of
     the leak detection methods, other than
     interstitial monitoring, described  on page
     14 but only if the method  you choose can
     effectively detect releases  of the
     hazardous chemical stored  in the UST.
     (Variances are not required in these
     cases before December 1998.)

     After December 1998, you must either
     use secondary  containment and
     interstitial monitoring or get a variance.
This schedule will make sure that the older
USTs, which are more likely to leak, have leak
detection first
                             NOTE..

                             No mailer which leak detection methods you
                             use for tanks and piping, they must be work-
                             ing by the deadlines described above. If not,
                             you must close your UST or replace it with a
                             new UST.
                                               13-32
-------
PAGE 30
   What Do You Do If You Have A
   Hazardous  Chemical Leak  Or Spill?

   You must follow the same short-term and long-
   term actions described earlier  for petroleum
   leaks and spills - except for two  modified
   short-term  actions.

   First, you  must  immediately report hazardous
   chemical spills or overfills that meet or exceed
   their "reportable quantities" to the National
   Response Center at l-(800)-424-8802 or (202)
   267-2675.

   Second, you must also report hazardous chemi-
   cal spills or overfills that meet or exceed their
   "reportable quantities"  to  the regulatory  au-
   thority within  24 hours.  However, if these
   spills or overfills are smaller than their "re-
   portable quantities" and are immediately con-
   tained and cleaned up, they do not need to be
   reported.

   You can get information on the "reportable
   quantities" by calling the  RCRA/CERCLA
   Hotline l-(800)-424-9346 or (202) 382-3000.
                                                  13-33
-------
                                                                                       PAGE 31
           TECHNICAL  QUESTIONS &  ANSWERS
Q.  How does "corrosion" cause USTs to
leak? How can USTs be protected from cor-
rosion?

A.  Unprotected steel USTs are frequently dam-
aged by corrosion.  When this happens, the
metal UST  system and its underground sur-
roundings act like a battery.  Pan of the UST
can become negatively charged and  another
pan positively charged.  Moisture in the soil
provides  the connecting link that finally turns
these UST  "batteries" on. Then, the negatively
charged pan of the UST system ~ where the
current exits from the tank or its piping ~
begins to deteriorate.  As electric current passes
through  this pan, the hard metal begins to turn
into soft ore,  holes form, and leaks begin.

Steel tanks  and piping can be protected by coat-
ing them with a corrosion-resistant coating and
by using "cathodic" protection. Cathodic
protection reverses the electric current that
causes corrosion and comes in two forms:

   • "Sacrificial anodes" can be attached to
     the UST. Sacrificial anodes are pieces of
     metal  more electrically active than the
     steel UST.  Because these anodes are
     more  active, the electric  current will exit
     from them rather than the UST. Thus, the
     UST is the  "cathode" and is protected
     from corrosion while the attached
     "anode" is sacrificed.

   • An "impressed  current" protection
     system introduces an electric current into
     the ground through* a series of anodes that
     are not attached to  the UST.  Because the
     electric  current flowing  from these anodes
     to the tank system is greater than the
     corrosive current attempting  to flow from
     it, the UST is protected from corrosion.
In addition, steel USTs can also  be protected
from corrosion if they are bonded  to a thick
layer of noncorrodible material, such as
fiberglass-reinforced plastic.   Cathodic protec-
tion is not needed with this method of corrosion
protection.  Also, the corrosion problem can be
totally avoided by using tanks and piping made
completely of noncorrodible  material, such as
fiberglass.

For more information on how corrosion works
and how USTs can be protected from corrosion,
contact the National Association of  Corrosion
Engineers or other corrosion professionals.  See
page 39 for industry codes on corrosion protec-
tion.
                                          13-34
-------
PAGE 32
   Q.  How can existing  USTs (those installed
   before December 1988) be "upgraded" to
   meet the corrosion  protection  requirements
   by December  1998?

   A.  When you add corrosion protection to exist-
   ing  UST systems, you  have several choices.
   Your first choice is to  meet the corrosion pro-
   tection requirements  for new tanks and piping
   (see page 9). Your other choices, described
   below, depend on whether  you are protecting
   the tank or the piping.
   Protecting  Tanks

   You have three choices for "upgrading*
   tank for corrosion protection:
your
     • The interior of a tank can be lined
        according to industry codes (see page 39
        for codes).  Tanks using only an interior
        lining for corrosion protection must pass
        an inspection in  10 years and
        reinspections every 5 years after that to
        ensure that the lining and tank are
        structurally  sound.

     • Tanks using only  cathodic protection
        must meet the general requirements for
        cathodic  protection and satisfy one of the
        methods  below to  make sure that the tank
        is structurally  sound:

        — If the  tank is less than 10 years old,
          you can use one of the monthly leak
          detection monitoring methods noted on
          page  10.

        — If the  tank is less than 10 years old,
          you can have  two tank tightness tests
          conducted.  The first test must take
          place before you install cathodic
          protection, and  the second test must
          take place between 3 and 6 months
          later.

        — If the tank is 10 years old or more,
          it must be internally  inspected and
          assessed to make sure that the tank is
          structurally  sound and free of corrosion
          holes before a cathodic protection
          system is installed.
                  You can combine tank interior lining with
                  cathodic protection.  If you use this
                  combined method, you are not required to
                  have the inierior  lining periodically
                  inspected.
Protecting Piping

Unless the existing piping is made of noncor-
rodible material, it must meet the requirements
for cathodic protection of new metal piping,
except that the existing piping does not need to
be coated with a corrosion-resistant coating
(see page 9).
                                                   13-35
-------
                                                                                               PAGE 33
Q.  What are "installation mistakes" and
how can they be  avoided?

A.  Improper installation is a significant cause
of fiberglass-reinforced plastic (FRP)  and  steel
UST failures, particularly piping  failures.
Proper installation is crucial to ensure the
structural integrity of both the tank and its pip-
ing.  Installation includes excavation, tank
system siting, burial depth, tank system assem-
bly, backfilling of the tank system, and surface
grading.   Many mistakes can be made during
installation.  For example, mishandling of the
tank during installation  can  cause structural
failure of FRP tanks or damage to steel tank
coatings  and cathodic protection.  Improper
layout  of piping runs, incomplete tightening of
joints,  inadequate  cover pad construction,  and
construction accidents can lead to failure of
delivery  piping.

Installation problems result from  careless  in-
stallation practices that do not follow recog-
nized industry codes and procedures.  If owners
and operators make  sure that their installers
carefully follow the correct  installation proce-
dures called for by industry  codes, the number
of installation mistakes  will be significantly
reduced.   See page 39 for industry codes on in-
stallation.  See page 37  for sources of informa-
tion  on installation.
Q.  What are spills and overfills?  How can
they be stopped?

A.  Many of the leaks at UST systems are actu-
ally the result of spills and overfills (which  are
two separate problems).  In fact, these releases
are at least twice as numerous as tank or piping
releases. Spills most often occur at the fill  pipe
opening when the delivery truck's hose  is dis-
connected,  usually releasing only a  few gallons.
Repeated releases of even  small volumes, how-
ever, can create real environmental problems.
Overfills occur less  frequently  but  usually re-
lease much larger volumes. When a tank is
overfilled, large volumes can  be released
through untight fittings on  the top of the tank
or the vent pipe.   The tightness of these fittings
normally would not  be a problem as long as the
tank was not filled beyond its capacity.

There are three keys to solving  the problems of
spills and overfills.  First, you  must make sure
that the volume available in the tank is greater
than the volume of product to be transferred to
the tank before the transfer is made.

Second, you have to make sure that the transfer
operation is watched constantly to prevent
overfilling and spilling.  See page 39 for appro-
priate industry codes.

Third, you  must use equipment that can pre-
vent or severely limit spills and overfills (see
below for when you have to do this).  Spill
prevention  devices,  such as spill catchment
basins  or dry disconnect couplings, are readily
available.  Overfill  prevention devices  auto-
matically shut off flow when the tank is nearly
full. Other overfill  devices either restrict flow
or trigger an alarm when the tank is nearly  full.

Your new UST system must be equipped with
both spill and overfill prevention devices when
it is installed.  Your existing USTs  must have
these devices by December 1998.  The  only
exception to this requirement is if your UST
system is filled only by separate transfers of no
more than 25 gallons. In  these cases, you do
not have to follow the spill and overfill equip-
ment requirements.
                                           13-36
-------
PAGE 34
   Q.  What leak detection methods will satisfy
   the  leak detection requirements for new or
   "upgraded"  petroleum USTs?

   A. You must provide your UST system with a
   method, or combination of methods, of leak
   detection that allows  you to meet the following
   three basic requirements:

     * You can detect  a leak from any portion of
        the tank or its piping that routinely
        contains  petroleum;

     • Your leak detection equipment is
        installed, calibrated, operated, and
        maintained  in accordance with the
        manufacturer's  instructions;  and

     • Your leak detection equipment meets the
        performance requirements described in
        the Federal regulations,  sections 280.43
        or 280.44.

   EPA is developing brochures  that  fully describe
   the various ways you can meet the leak detec-
   tion requirements (see page 38).   Leak detec-
   tion methods are presented in  the Preamble to
   the UST regulations (Section IV.D.) and in the
   rule (Subpart  D, Sections 280.43 and 280.44).
   The descriptions below briefly identify leak
   detection methods for tanks and piping.
Leak Detection  for Tanks

Leak detection for tanks can consist of one or a
combination of the following methods:
Tank Tightness  Testing Combined with
Inventory Control

This method  combines manual inventory con-
trol information  (measured daily and  compiled
monthly) with tank  lightness  testing every 5
years.  Tank  tightness testing requires taking
the UST out of service while changes in level
or volume over time are measured. This method
can be used only by new or upgraded  USTs
during their first 10 years  of  operation (or until
1998, whichever is later).  After that,  one of the
monthly  monitoring methods  below must be
used.
Automatic Tank Gauging Systems

This method uses automated processes to moni-
tor product level and  inventory control.
                                                      Monitoring for Vapors in the Soil

                                                      This method samples vapors in the soil gas
                                                      surrounding the  UST.  Leaked petroleum pro-
                                                      duces  vapors that can be detected in the soil
                                                      gas.  The regulations describe  several require-
                                                      ments for using  this leak detection method. For
                                                      example, this method requires  using porous
                                                      soils in the backfill  and locating the monitoring
                                                      devices in  these porous soils near the UST sys-
                                                      tem.
                                                13-37
-------
                                                                                             PAGE 35
Monitoring for Liquids on the Ground Water

This method monitors the ground  water table
near an UST for the presence of released free
product on the water table.  Monitoring wells
near the UST are checked frequently to see if
petroleum can be detected.  The regulations
allow manual and automatic methods for de-
tecting petroleum in the monitoring wells.   The
regulations also describe several requirements
for the use of this method. For example, this
method cannot be used if the water table is
more than 20 feet below the surface of the
ground.
Interstitial  Monitoring

This method detects leaks in the space between
the UST and a second barrier or wall.  The
regulations describe several general perform-
ance requirements for the application of inter-
stitial monitoring with double-walled USTs,
USTs fitted with internal liners, and USTs us-
ing partial interception barriers  located below
the UST.
Other Methods Approved by the Regulatory
Authority

If other methods can be shown to work as ef-
fectively as the methods described above for
leak detection, then these alternative methods
can be approved by the regulatory authority.
One Additional Method with Restricted Use

Manual tank gauging can be used as the sole
method of leak detection, but only  with tanks
that are 550 gallons or less.  This method in-
volves taking two stick measurements at least
36 hours apart when the lank is not open for
use. Also, manual tank gauging can be used in
place of manual inventory control in tanks
ranging in size from 551 to 2,000 gallons.  In
these cases, however, manual tank  gauging
must be combined with  tank tightness testing.
Leak Detection  for  Piping

If you have pressurized piping, you need to do
two  things:

  • Install an automatic  line leak detector,
     and

  • Either conduct an annual line tightness
     test,

     Or conduct monthly  leak detection
     monitoring using one of the  following
     methods  noted above for tanks:  vapor
     monitoring, ground-water monitoring,
     interstitial  monitoring, or other approved
     monthly  methods.

If you have suction piping, you need to do one
of two things:

  • Either conduct line  tightness tests every 3
     years,

     Or conduct monthly  leak detection
     monitoring as described above for
     pressurized piping.

You do not need to have leak detection if your
suction piping meets some basic design  re-
quirements:

  • Below-grade piping  is sloped so that the
     piping's  contents will drain back into the
     storage tank if the suction is released.

  • Only one check valve is included in each
     suction line and is located directly below
     the suction pump.
                                             13-38
-------
                                                                                 PAGE 37
       VIDEOS,  BROCHURES,  AND HANDBOOKS
                                   ON  USTs
Videos

Installation
"A Question of When: Tank Installation for
Inspectors"

"In Your Own Backyard"
Available for purchase only, $22.85 each, pre-
paid.

Order from:

  National Fire Protection Association
  Ann:  Jim Smalley
  Batterymarch Park
  Quincy, MA  02269
 "Doing It Right" (coming soon)
For information:

   U.S. Environmental Protection Agency
   Office of Underground Storage Tanks
   P.O. Box 6044
   Rockville, MD 20850
 Closure
 "Tank Closure Without Tears: An Inspector's
 Safety Guide"
Video and companion booklet available for
purchase, $25.00, prepaid.
Booklet  only, $5.00, prepaid.

Order from:

   New England Interstate Water
   Pollution Control Commision
   Attn:  VIDEOS
   85 Merrimac Street
   Boston, MA  02114

Video and companion booklet available for
loan, $5.00, prepaid.

Order from:

   New England Regional Wastewater Institute
   Two Fort Road
   South Portland, ME 04106
                                         13-39
-------
PAGE 38
   Brochures
   Corrective  Action

   "Oh No!" -- Leaks and Spills: What Do You
   Do? (coming soon)

   Leak Detection

   "Leak Lookout"  ~  Using External Leak De-
   tectors to Prevent Petroleum Contamination
   from  Underground Storage Tanks

   Financial  Responsibility

   Financial Responsibility  Requirements
   Summary (coming soon)
These brochures may be ordered from:

   U.S. Environmental Protection Agency
   Office of Underground  Storage Tanks
   P.O. Box 6044
   Rockville, MD  20850
Handbooks
"Financial Assurance Programs: A Handbook
for States" (coming soon)
"Funding Options for State and Local
Governments"
"Underground Storage Tanks: Building State
UST Compliance Programs"
These handbooks may be ordered from:
U.S. Environmental Protection Agency
Office of Underground Storage Tanks
P.O. Box 6044
Rockville, MD 20850

"Cleanup of Releases from Petroleum USTs:
Selected Technologies"

Stock No. 055-000-00272-0, S7.50 prepaid.
This handbook may be ordered from:
Superintendent of Documents
Government Printing Office
Washington, D.C. 20402


                                              13-40
-------
                                                                                       PAGE 39
            INDUSTRY CODES  AND STANDARDS*
Installation

API Publication 1615, 1987, "Installation of
Underground Petroleum Storage  Systems,"
Recommended  Practice, 4th Edition

PEI RP-100-87, 1987, "Recommended Prac-
tices for Installation of Underground  Liquid
Storage Systems"
 Tank Filling Practices

 API Publication 1621, 1977, "Recommended
 Practice for Bulk Liquid Stock Control at Re-
 tail Outlets," 3rd Edition (A revised edition
 is now available.)

 NFPA 385, 1985, "Standard for Tank Vehicles
 for Flammable and Combustible Liquids"
Closure

API Bulletin 1604, 1987, "Removal and Dis-
posal of Used  Underground Petroleum Storage
Tanks," Recommended Practice, 2nd
Edition
Lining

API Publication 1631,  1987, "Interior Lining
of Underground Storage Tanks," Recom-
mended Practice, 2nd Edition

NLPA  Standard 631, 19-, "Spill Prevention:
Minimum 10 Year Life Extension of Existing
Steel Underground Storage Tanks by Lining
Without the Addition of Cathodic
Protection"(DRAFT)
Corrosion Protection

API Publication 1632,  1987, "Cathodic Protec-
tion of Underground Petroleum Storage Tanks
and Piping Systems,"  Recommended Practice,
2nd Edition

NACE RP-0169-83,  1983, "Recommended
Practice:  Control of Corrosion on Underground
or Submerged Metallic Piping Systems"

NACE RP-0285-85,  1985, "Recommended
Practice:  Control of External Corrosion on
Metallic Buried, Partially Buried, or Sub-
merged Liquid Storage Systems"
General (Repair, Spill and Overfill,
Installation,  Compatibility)

API Publication  1626, 1985, "Storing and Han-
dling Ethanol and Gasoline-Elhanol Blends at
Distribution Terminals and  Service Stations,"
1st Edition

API Publication  1627, 1986, "Storage and
Handling of Gasoline-Methanol/Cosolvcnt
Blends at Distribution Terminals and Service
Stations"

API Recommended  Practice  1635, 1987,
"Management of Underground Petroleum  Stor-
age Systems  at Marketing and Distribution
Facilities," Recommended Practice, 3rd
Edition

NFPA 30, 1987,  "Flammable and Combustible
Liquids  Code"

NFPA 30A, 1987, "Automotive and Marine
Service  Station Code"
"This list includes the most relevant codes and
standards for underground storage tank
systems.  Organizations are identified on
page 40.
                                           13-41
-------
PAGE 40
      ORGANIZATIONS TO CONTACT FOR  TANK INFORMATION
   ACT - Association for Composite Tanks
   108 North State Street
   Suite 720
   Chicago, IL  60602
   (301) 355-1307 (for information requests)

   API - American Petroleum Institute
   1220 L Street, N.W.
   Washington, DC 20005
   (202) 682-8000

   Fiberglass Petroleum Tank and
   Pipe  Institute
   One SeaGate, Suite 1001
   Toledo, OH  43604
   (419) 247-5412

   NACE ~ National  Association of Corrosion
   Engineers
   Box 218340
   Houston, TX 77218
   (713) 492-0535
NFPA -- National Fire. Protection Association
Batterymarch Park
Quincy, MA  02269
(617) 770-3000

NLPA - National Leak Prevention Association
P.O. Box 29809
Cincinnati, OH  45229
(513) 281-7693
l-(800)-543-1838

PEL -- Petroleum Equipment Institute
Box 2380
Tulsa.'OK  74101
(918) 743-9941

Steel Tank Institute
P.O. Box 4020
Northbrook, IL  60065
(312) 498-1980
                                              13-42
-------
14.1  WORKSHOP G:   CLEAN AIR ACT REQUIREMENTS FOR  PROPER
     NOTIFICATION AND REMOVAL OF ASBESTOS FROM BUILDINGS
-------
14.1  WORKSHOP  G:    CLEAN  AIR  ACT  REQUIREMENTS  FOR PROPER
      NOTIFICATION AND REMOVAL OF ASBESTOS FROM BUILDINGS

Pauline G. Levin. Chief, Asbestos Management Section, EPA-Region III.

      Ms. Levin presented key events that have been incremental in the development of EPA's
asbestos program.  These events are outlined in the attached chronology.

      Federal regulatory requirements for asbestos are authorized under TSCA and the Clean
Air Act.  It is recommended that commercial or institutional building owners have an asbestos
operations and maintenance program that includes identification of asbestos, description of work
practices, surveillance and record keeping including medical and respiratory programs for the
workers.
                                      14-1
-------
EPA ASBESTOS PROGRAM CHRONOLOGY
1972  List asbestos as a hazardous air pollutant.

1973  Set standard of "no visible emissions" for the milling of asbestos, the manufacturing of
      asbestos products, and the demolition of buildings. Prohibited the spray application for
      most uses of friable materials containing more than one percent of asbestos.

1974  Issued water effluent guidelines for asbestos manufacturing point sources and new source
      performance  standards.

1975  Extended the "no visible emissions"  standard to waste collection and disposal.

1978  Prohibited most friable,  sprayed-on asbestos.

1979  Initiated a technical assistance program to help schools  identify and control friable
      asbestos-containing  materials.  Announced  Agency's intention to consider regulating
      commercial uses of asbestos.

1980  Listed asbestos as a hazardous waste in  proposed rules.  Proposed rule for schools to
      identify and notify EPA of any friable asbestos in schools.  Proposed a rule under TSCA
      requiring  the reporting of production and exposure data on asbestos.

1982  Issued final rule  on the identification and  notification of friable  asbestos-containing
      materials  in schools.  Also, issued  final rule under TSCA requiring  the reporting of
      production and exposure data on asbestos.

1984  Conducted national survey of public buildings to  determine  the extent of asbestos-
      containing materials.

1985  Made first distribution of annual ASHAA loans and grants to financially needy schools.

1986  Proposed the ban and phase-out of most asbestos products and  the  uses of asbestos.
      Distributed second round of ASHAA funds  to schools. Began developing a regulation
      to carry out the newly  enacted Asbestos Hazard Emergency Response Act (AHERA).
      EPA used the "regulation negotiation" process, which calls for including  all interested
      and affected constituencies in the actual development of the regulation.

1987  Proposed and subsequently finalized regulations for AHERA implementation which were
      distributed to public and private schools. Distributed third round of ASHAA funds to
      schools.  Developed and finalized Model Accreditation Plan.
                                         14-2
-------
 1988  Distributed grants totaling $15 million to states for AHERA inspections and management
       plans.  Distributed fourth round of ASHAA funds  to schools.  Submitted report to
       Congress on asbestos in public and commercial buildings, which proposed a three-year
       program of increased  guidance, technical  assistance,  and  enforcement  of current
       regulations.  Provided training to AHERA state designees and EPA's Regional Asbestos
       Coordinators on proper AHERA implementation. Appointed an Asbestos Ombudsman
       at EPA headquarters to respond to  citizen concerns, questions, and complaints about
       asbestos-in-schools issues. Provided  schools with AHERA implementation support in the
       form of guidance materials, a  nationwide teleconference, and  technical  assistance.
       Approved over 400 training courses  for accreditation  f asbestos consultants.

1989   Distributed fifth round of ASHAA funds to schools.   Continued inspections under
       AHERA in  schools.   Continued accreditation  of training courses.   Issued Ban  and
       Phasedown Rule for manufacture, importation, processing, and distribution in commerce.
       Held dialogue on Public and Commercial buildings. Developed coordination of AHERA
       and NESHAP.  Stated approval of state programs to take over accreditation of courses.

1990   Reauthorization  of Asbestos School Hazard Abatement Act (ASHAA). First phase of
       Ban  and Phasedown Rule went into effect.   Continued inspections under AHERA in
       schools.
                                      14-3
-------
15.1 KEYNOTE ADDRESS - IS TOTAL COMPLIANCE ACHIEVABLE?
-------
15.1   KEYNOTE ADDRESS - IS TOTAL COMPLIANCE ACHIEVABLE?
Christian  R. Holmes. Deputy Assistant  Administrator for  Federal  Facilities,  Office of
Enforcement, EPA, Headquarters.

       Mr. Holmes presented a keynote address focusing on the environmental challenge at
federal facilities. He discussed his observations concerning environmental problems at federal
facilities and difficulties encountered in addressing these problems.  He stressed the importance
of identifying key problem areas and securing resources to correct the problems. According to
Mr. Holmes, his observations indicate that environmental problems at federal levels are getting
worse.

       There are 1200 facilities on  the National Priorities List (NPL). Approximately 115 of
these  facilities are  federal facilities.  Mr. Holmes  sees a series of waves crashing down on
federal facilities in the future,  resulting in increased NPL  listings and a greatly increased
workload.  Under RCRA, 250 federal facilities are Transport, Storage and Disposal Facilities
(TSD). Eighty percent of these will require corrective action resulting in a further increase in
workload.   Huge management  challenges, exceeding even  those of the private sector  will
develop. Lastly, interagency agreements and feasibility studies must be developed. In summary,
there will be a phenomenal increase in federal facility workload.

       The largest problem in dealing with the increased workload as Mr. Holmes stated,  will
be a shortage of staff to oversee cleanup activities.  Whether the agency will be able to carry
out its responsibility will depend on supplemental appropriation and reprogramming.  With a
workforce turnover rate of 20 to 50 percent annually, there is also a need to consolidate training.

       According to Holmes, it is necessary to identify key problem areas at federal facilities
and the specific threats to the environment. There is a need to identify short term problems and
then secure resources to fix the problems.

       Tools and approaches at the  disposal of federal facilities to accomplish these objectives
are as follows;

       1)     Agreements on compliance, violation, and enforcement.
       2)     Systematic approach to cleanup technologies.
       3)     Communication:   Need to start communicating to others what methods are
             successful.
                                        15-1
-------
16.1  THE NEW OFFICE OF FEDERAL FACILITY ENFORCEMENT ORGANIZA-
     TION AND GOALS
-------
16.1  THE NEW OFFICE OF FEDERAL FACILITY ENFORCEMENT ORGANIZA-
      TION AND GOALS
Gordon Davidson. Director Office of Federal Facilities Enforcement EPA, Headquarters.

      Mr. Davidson discussed EPA's philosophy on compliance and clean-up and the intended
goals and anticipated regulations of the Office of Federal Facility Enforcement.  Mr. Davidson
stressed  that enforcement is not one of the goals  but a tool to  achieve a commitment of
environmental compliance.  It is EPA's goal to establish memorandums of agreements (MOAs)
as a step towards achieving environmental compliance at federal facilities. It is necessary to
have agreements that are enforceable in court.

      The MOAs should clarify roles and responsibilities of the parties. They should include
a schedule that defines who does what and when.  An action plan that reflects relative priority
of problems should be clearly defined.  The MOAs allow EPA to prioritize  problems. EPA
plans to continue, as a policy, to focus on these agreements.

      The goal on the clean-up side is to expedite response actions. The primary objective in
clean-up operations is to contain waste so it can be disposed of properly.

      Mix waste management problems were also addressed.  EPA hopes to achieve the
following with their compliance strategy; clear definition of the mix waste problem nationwide,
national prioritization of problems and identification of successful technologies for dealing with
mix waste problems.   EPA has suggested that certain  federal  facilities  be used to  test
environmental technologies.
                                       16-1
-------
17.1  PANEL ON BUILDING A MULTI-MEDIA ENVIRONMENTAL PROGRAM
-------
 17.1   PANEL ON BUILDING A MULTI-MEDIA ENVIRONMENTAL PROGRAM
Panelist:     Len Richardson, Director, Environmental Support Office
             Captain James Taylor. Commander, Norfolk Navel Shipyard
             Colonel Gerald P. Williams. Deputy Commanding Officer, Fort Belvoir

Moderator:   Robert E. Greaves, Chief, RCRA Enforcement and UST Branch EPA, Region III

Richardson

       Mr. Richardson discussed the Department of Defense (DoD) headquarter's perspective
on environmental issues. He stated there is a sincere apathy in the DoD to meet environmental
responsibilities, however within the past year some progress has been made.

       In August of 1989, Secretary Cheyney  challenged the DoD  to be the federal leader in
environmental compliance  and protection.   Secretary Cheyney  stated  that  environmental
consideration must be integrated and budgeted into all activities and that meeting environmental
standards must be a command priority at all levels. Environmental concerns  need to be clearly
communicated. The Environmental Support Office created defense and environmental initiatives
to meet Secretary Cheyney's challenge.

       Mr. Richardson referred to an Environmental Initiatives Forum held at an earlier date.
At this conference, Secretary Cheyney addressed issues regarding defense and the environment.
He said to choose between them is impossible  in this real world of serious human  threats and
general environmental concern.  The goal is to build environmental ethic into the daily business
of defense. Good environmental planning and management need to be exercised before actions
are taken. The environmental initiatives are designed to produce a plan and to integrate goals
into day to day operations.  Mr. Richardson presented  the three phases of the  environmental
initiatives process as  follows;  assess  military conformance  and progress,  develop broad
sustainable compliance and, develop leadership goals with cost schedules.

       The greatest challenge within the DoD vision is to sustain the momentum they have now.
To meet this challenge,  the DoD is developing a strategy by 1992.  This strategy will include
every aspect of how the DoD carries out business.  Operation  and installation, acquisition of
major weapons  systems, procurement of equipment and supplies, and production  of  military
materials will be analyzed.  The following list indicates the goals DoD hopes to accomplish as
part of the 1992 strategy:

       •  Help command the environmental mission to maintain momentum and support.
       •  Provide adequate policy, dollars, and manpower.
       •  Provide institutional and educational training to advance knowledge in the field.
       •  Establish environmental career  field for military and civilian personnel with pay
          comparable to private industry.

                                         17-1
-------
       •   Involve public and regulators early in the decision process.
       •   Provide a clear road map of how to solve environmental problems more efficiently.

       An environmental management study will be developed as part of the overall defense
management review process.  The study objectives are to reduce overhead costs and provide a
solid basis for establishing DoD leadership in environmental activities.  The goal of the study
is to look at the organizational structure in the DoD in order to streamline the  environmental
structure and implement environmental programs.

       Congress  has  implemented a new resource management program to establish a
recommitment to natural resources and to develop, identify, and manage all significant wildlife,
geophysical, cultural,  and historical resources on DoD land.
Taylor

       Captain Taylor discussed his experiences in using total quality management to conduct
operations at the navy's oldest and largest industrial facility.  A brief introduction to the Norfolk
Naval Shipyard was presented along with discussion of the strategic plan and vision of how they
were set up to mold environmental policy to support daily business at the yard.

       Since Norfolk Naval Shipyard started operations in 1776, environmental problems have
been building.  The 1300 acre  shipyard sits on the south branch  of the Elizabeth River.  All
work required on navy ships takes place in this yard.

       The following are  significant principles for a successful environmental program which
are outlined in the strategic operations plan for the shipyard;

       1.   Incorporate total quality management or total quality leadership principles into daily
           business at Norfolk Naval Shipyard.
           A.  Establish a Quality and Productivity Improvement Committee
           B.  Maintain a well trained work force.
           C.  Establish levels of management to insure quality processes.
       2.   Define responsibilities.
       3.   Incorporate planning and design.
       4.   Hold annual audits.
       5.   Maintain enforcement crews to hold daily inspections.

       In his summary, Captain Taylor emphasized the following key elements for successful
total quality management;

       1.   Investment of resources
       2.   Corrective action programs
                                          17-2
-------
       3.   Communication with work force
       4.   Commitment

       In his closing remarks he noted that if all of the elements are not activated, there will not
be a total program.
Williams

       Colonel Williams emphasized that federal facility  compliance to the detail is very
important and everyone  at the conference can help achieve this.  Fort Belvoir is going to go
through a lot of what the Norfolk Naval Shipyard has already done to get their program
organized and on the correct path.

       Colonel Williams gave examples of how unaware personnel may be of many materials
in existence  on  the  installation.  Therefore, an emphasis on education as well as public
involvement should be made.
Greaves

      Mr. Greaves feels the following six areas are needed for maintaining and developing
multi-media environmental planning;

       1.   Establish a high level of focus for program compliance.
      2.   Develop environmental management systems.
              Perform comprehensive waste characterization
              Perform internal audits
      3.   Improve environmental support services.
      4.   Implement training.
      5.   Coordinate environmental planning.
      6.   Integrate new regulations.
                                         17-3
-------
18.1   OVERVIEW OF CHESAPEAKE BAY FEDERAL FACILITY COMPLIANCE
      INITIATIVE AND WHAT WE WILL DO NEXT
18.2  ATTACHMENTS
         List of Federal Facilities Covered by EPA, Region III, Chesapeake Bay Multi-media
         Federal Facility Compliance and Enforcement Initiative

         EPA Chesapeake Bay Federal Facility Compliance Initiative
-------
18.1   OVERVIEW OF CHESAPEAKE BAY FEDERAL FACILITY COMPLIANCE
       INITIATIVE AND WHAT WE WILL DO NEXT
Neil Swanson. Manager, Bay Federal Facilities and Multi-Media Compliance Initiative EPA,
Region in

      When EPA Administrator, William Reilly, accepted the Chair of the Chesapeake Bay
Executive Council in December,  1989,  one of his goals for 1990 was to make the federal
community a role model for environmental compliance.  The Chesapeake Bay Federal Facility
Compliance Initiative was a direct result of this commitment and the goal of physical compliance
or a signed compliance agreement with EPA or the State by December 31, 1990 was established.
In this presentation,  a status of the Initiative to date was presented as outlined in the attached
materials. A great deal of progress has been made, yet a number of facilities must still come
into compliance. The majority of the presentation covered  issues and challenges which have
arisen during this Initiative. Many  are listed in  the attached material.  The key  items on the
positive side have been an increased level and detail of communication, high level attention given
to environmental issues, and the ability to expedite the bureaucratic process to achieve results.

      On the downside, EPA Region HI has encountered some data and inspection reporting
delays, some legal and resource impediments and have found it difficult to transfer successes into
quantifiable  environmental  improvements.  EPA's general plans for the upcoming year were
outlined.   EPA  will continue its emphasis on Bay  federal facility compliance.   However,
pollution prevention  and long-term compliance strategy development will be emphasized.  The
momentum gained by this  year's  initiative must be maintained and converted into long-term
success.   Again, the goal of the federal community as the role  model for  environmental
compliance can and  shall be achieved through a partnership between EPA, the States and the
federal facilities.
      The federal facilities initiative has two goals:

           1)  100% compliance.
          2)  Establish a continuous cooperative effort to build on.

      Mr. Swanson recognized the accomplishment of these goals as being a fairly tough task,
he focused on major issues.

      Of 50 facilities on the list, 37 started in non-compliance.  There are 12 facilities still in
non-compliance and 9 new violators have been added to the list.

      Issues and challenges that face all facilities are as follows:

          1)  Communication and  information transfer.

                                       18-1
-------
           2)   Training in new regulations (For example, new regulations being developed for
               storm water discharge).
           3)   Establishing data tracking systems.
           4)   Developing a multi-media approach.
           5)   Developing compliance indicators.
           6)   Promotion of success story publicity.

       EPA is an regulatory agency and they are supposed to enforce all laws and regulations.
The public looks to EPA to enforce regulations. In working with the Department of Defense,
the EPA must keep its purpose in mind.

       Problems created over legal versus technical issues cause difficulties for facilities. Legal
issues  take time to solve.  The Department of Defense is now beginning  to achieve federal
compliance and there are many legal issues  for them to go through.

       Facilities also need to know who the actors are in the bureaucratic arena and what
resources are available to  them.  A long term multi-media environmental strategy, including
inspection plans, needs to be developed and public involvement must be initiated. The bottom
line, according to Mr. Swanson is that the federal government should be taking the lead in all
of these issues.
                                         18-2
-------
         LIST OF FEDERAL FACILITIES
                 COVERED  BY
               EPA, REGION 3
CHESAPEAKE BAY MULTI-MEDIA FEDERAL FACILITY
   COMPLIANCE AND ENFORCEMENT INITIATIVE
                   For more information contact:
                        Neil R. Swanson (215) 597-6509
                                       or
                         Koge Suto, Jr. (215) 597-1231
                   18-3
-------
                          INTRODUCTION

The attached list was compiled to support one of two compliance
goals that the U.S.  Environmental Protection Agency has set for
all federal agencies with facilities located in the Chesapeake
Bay watershed.  The goal is to achieve full federal facility
compliance in the watershed by December 31. 1990.  EPA is working
with the District of Columbia and with the Bay states—Maryland,
Pennsylvania, and Virginia—who have primary authority for most
environmental programs, to achieve this goal within this short
timeframe.

The parameters of this goal can be defined as follows:

     1.   It applies to all major federal facilities or those
          that have a potential major impact on Chesapeake Bay
          water quality.  This includes, but is not limited to,
          all facilities that are in significant noncompliance
          (SNC) or its equivalent in the Bay drainage area.  It
          also includes all Department of Defense (DOD)
          facilities listed in Appendix B of the EPA/DOD Coopera-
          tive Agreement, i.e., those facilities that were
          identified through the Tetra-Tech study as having a
          potential for significant impact on the Bay's water
          quality.

     2.   EPA and the States will be seeking compliance for all
          sources that significantly impact the Bay in all
          environmental programs for which we have regulatory
          authority.  This includes

               —National Pollutant Discharge Elimination System
                  (NPDES),
               —Resource Conservation and Recovery Act (RCRA)
                 Program,
               —Air emissions if the source will have a signi
                 ficant impact on Bay water quality,
               —PCB requirements of the Toxics Substances
                 Control Act (TSCA), and
               —any hazardous waste sites that are currently on
                 the National Priority List (NPL) or proposed to
                 be listed.

     3.   Violations of other programs that may not have a direct
          impact on Bay water quality may be included during the
          negotiation of compliance agreements.  For example,

               —violations of drinking water standards for
                 public water systems,
               —violations of requirements for the removal and
                 disposal of asbestos in buildings  (NESHAPS),
               —PCB record-keeping and labelling violations,
               —RCRA Class II violations, and
                               18-4
-------
               —any violations of air emissions standards
                 without significant impact on the Bay.

     4.   Our primary goal is physical compliance by December 31,
          1990.   If that cannot be reasonably achieved within the
          established timeframe then we will seek a legally
          binding agreement containing a schedule for compliance
          beyond December 31, 1990 signed by the federal agency
          and EPA or the appropriate State agency.

     5.   The attached list focuses on SNC or its equivalent
          based on data available as of December 31, 1989.  It is
          a dynamic list that will be changed as facilities
          achieve compliance or go into noncompliance status
          during the year.  EPA and the States will continue to
          monitor for new violations that come to our attention
          by December 31, 1990.  Violations that occur within
          this timeframe will be added to the list.

There is another concurrent compliance goal that federal facili-
ties should be aware of.  During the same timeframe, EPA and the
Bay States will be taking appropriate action to cut the NPDES SNC
rate in half.  The parameters of this goal can be defined as
follows:

     —The goal applies to all facilities in the Chesapeake Bay
       watershed with major NPDES permits, i.e., municipal,
       industrial, and federal facilities,
     —The goal is 50 percent reduction of the rate of SNC by
       December 31, 1990.  (The rate of SNC was 8.3 percent in
       1989, including federal facilities.)
     —The goal is physical compliance by December 31, 1990 or a
       legally enforceable document (compliance agreement or
       consent order) establishing a schedule for compliance
       signed by the facility and EPA or the appropriate state
       authority.

NOTE:  Any federal facilities in SNC under the NPDES program are
       already included on the attached list.
                               18-5
-------
             Definition of Significant Noncompliance

To assist you with understanding the attached list we have
provided brief summaries of the definition of Significant Noncom-
pliance (SNC) or its equivalent for each media program cited in
the list.  The guidance establishing these definitions is much
longer and more complex.  For this reason, we have also iden-
tified an EPA or, where appropriate, State contact for each
program.  If you have any questions about the violations cited or
if you want more detailed information on SNC, please call the
designated contact directly.

In addition, EPA and the States expect all violations to be
corrected.  Obviously, violations vary in degree and SNC is an
attempt to identify serious violations and chronic violators that
require priority attention.

     NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES)

Contact:  EPA - Carol Stokes-Cawley, Chief
                General Enforcement Section
                Water Management Division
                (215) 597-3689

          State - (MD) Merrylin ZawMon (301)  631-3574
                       James Pittman (301) 631-3386
                       Maryland Dept. of the Environment

                  (PA) Stan Rudisill, Bureau of Water Quality
                       Management, Pennsylvania Dept. of
                       Environmental Resources
                       (717) 787-8184

                  (VA) John Roland
                       State Water Control Board
                       (804) 367-6775

All violations of NPDES permit conditions and enforcement orders
are violations of the Clean Water Act.  The term "Significant
Noncompliance" (SNC) identifies the most serious violations
including:

          any monthly average effluent violation that meets the
          Technical Review Criteria  (TRC)*, for the same parame-
          ter at the same outfall, occurring at least two months
          within a six month period.
          any monthly average effluent violation, for the same
          parameter at the same outfall, occurring at least four
          months within a six month period.
          any effluent violation that causes or has the potential
          to cause a water quality or public health problem.
                              18-6
-------
                          NPDES  fcont'd)

          any violation of a compliance schedule milestone date
          by 90 days or more (i.e., start of construction, end of
          construction, attain final compliance).
          any report late by 30 days or more.
     —   any violation of permit requirements  (pretreatment
          program, narrative conditions).
          any violation of an enforcement order (administrative
          and judicial).

NOTE:     For purposes of the Chesapeake Bay Initiative, all
          instances of NPDES program noncompliance will be
          addressed.

     *TRC is a factor by which the monthly average pollutant
     limit is multiplied to determine the severity of a viola-
     tion.  The TRC for conventional pollutants is 1.4; the TRC
     for toxic pollutants is 1.2.  If an effluent violation
     exceeds the product of the permit limit for that parameter
     multiplied by its TRC, it is designated as a TRC violation.

     Example

     —   The monthly average permit limit is 30 mg/L (conven-
          tional pollutant).
          The reported monthly average result is 45 mg/L.
          1.4 (TRC) x 30 mg/L (permit limit) = 42 mg/L
          Since the reported result (45 mg/L) exceeds 42 mg/L, it
          is considered a TRC violation.  Two TRC violations of
          the same parameter at the same outfall within a six
          month period indicates significant noncompliance.

          RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)

Contact: EPA - John G. Nevius
               State Enforcement Section
               Hazardous Waste Management Division
               (215) 597-2381

          State - (MD) Butch Dye, Maryland Dept. of the
                       Environment
                       (301) 631-3400

                  (PA) Rick Shipman, Bureau of Waste Management
                       Pennsylvania Dept. of Environmental
                       Resources
                       (717) 787-6239
                              18-7
-------
                          RCRA (cont'dl

                  (VA)  Karol Akers
                       Virginia Dept. of Waste Management
                       (804) 225-2496

The RCRA program classifies both violators and violations.  It
does not use the term significant noncompliance.

A High Priority Violator (HPV) is a handler who causes or poses a
substantial likelihood of exposure to waste or its constituents.
An HPV is a chronic violator or one who substantially deviates
from program requirements or the terms of a permit, order, or
decree by failing to comply in a timely manner.  Regulating offi-
cials consider the combined effect of violations, the result of
previous inspections, and the violator's responsiveness in
correcting previous violations in classifying a violator as an
HPV.

A Medium Priority Violator  (MPV)  is a handler with one or more
Class I violations who does not meet the criteria for an HPV.

RCRA violations are classified as follows:

     Class I - Any deviation from regulations, or provisions of
               compliance orders, consent decrees or agreements,
               or permit conditions which could result in failure

               —to assure that hazardous waste is destined for
                 and delivered to authorized treatment, storage,
                 or disposal facilities (TSDF's); or
               —to prevent releases of hazardous waste or its
                 constituents, both during the active life and
                 applicable post-closure periods of the facility
                 operation where appropriate; or
               —to assure early detection of releases; or
               —to perform emergency clean-up or other correc
                 tive action for releases.

     Class II - Any other violation that would not be considered
                a Class I violation.

                               AIR

Contact:  EPA - Christie Johnson
                Enforcement Policy and State Coordination Section
                Air, Toxics & Radiation Management Division
                (215) 597-3023
                               18-8
-------
                          AIR  (cont'd)

          State - (DC)  Don Wambsgans, Chief
                       Engineering Services Section
                       DC Dept. of Consumer & Regulatory Affairs
                       (202)  767-7370

                  (MD)  Ronald E. Lipinski,  Administrator
                       Enforcement Program, Air Mgmt. Administra-
                         tion,  Maryland Dept. of the Environment
                       (301)  631-3220

                  (PA)  Jim Salvaggio, Chief, Abatement &
                       Compliance Division, Bureau of Air Quality
                       Control, Pennsylvania Dept. of
                       Environmental Resources
                       (717)  787-9256

                  (VA)  Pam Faggert, Director
                       Division of Technical Evaluation,
                       Virginia Dept. of Air Pollution Control
                       (804)  786-5481

A violator is identified as a significant violator if they meet
any one or more of the following criteria:

     1.   A source that is in violation of National Emissions
          Standards for Hazardous Air Pollutants (NESHAPS) re-
          quirements other than asbestos demolition and renova-
          tion requirements.
     2.   A source violating new source requirements, including
          New Source Performance Standards (NSPS), Prevention of
          Significant Deterioration (PSD) requirements, and Part
          D nonattainment area permitting requirements.
     3.   A Class A source that is in violation of a State
          Implementation Plan (SIP) if the source is located
          where it will impact a nonattainment area and is
          violating the pollutant for which the area is in
          nonattainment.
     4.   A source that is violating a federal consent decree or
          administrative order or a state consent decree or
          administrative order (because the source would also be
          in violation of the SIP).  A source violating a state
          decree or order is a significant violator only if the
          decree/order addresses violations for pollutant for
          which the area is in nonattainment.
     5.   Any federal facility violator.
                              18-9
-------
                     PCB REQUIREMENTS OF THE
               TOXIC SUBSTANCES CONTROL ACT (TSCA)

Contact:  EPA - John Ruggero,  Chief
                TSCA Enforcement Section
                (215) 597-9937

The TSCA program defines SNC as a violation of one of the regula-
tions under TSCA that will result, at a minimum, in an ad-
ministrative complaint issued in accordance with the appropriate
Enforcement Response Policy, and for which the penalty will be at
least $25,000.  For federal facilities, a facility is in SNC if
the violation(s) would normally result in a formal enforcement
action.  However, these actions are handled in accordance with
the EPA Federal Facility Compliance Strategy (the Yellow Book).


                  SAFE  DRINKING WATER ACT  (SDWA)

Contact:  EPA - Thomas Conlon, Enforcement Coordinator
                Water Management Division
                (215) 597-8241

                Patti Kay Wisniewski  (for general drinking water
                info.), Water Management Division
                (215) 597-9032

          State - (MD):  Barry O'Brien, Chief, Facilities Inspec-
                         tion Division, Water Supply Program,
                         Maryland Department of the Environment
                         (301) 631-3706

                  (PA):  Jeff Gordon, Compliance & Enforcement
                         Unit, Division of Water Supplies,
                         Pennsylvania Dept. of Environmental
                         Resources  (717) 787-9037

                  (VA):  Evans Massie, Division of Water Supply
                         Engineering, Virginia Dept. of Health
                         (804) 786-1766


The SWDA regulates public water systems.  A community water
system would be in SNC if it meets  any of the following criteria:

     1.   violates the Maximum Contaminant Level (MCL) for
          microbiological contaminants or turbidity for four  or
          more months during any  12  consecutive month period, or
                                 18-10
-------
                          SDWA (cont'd)

     2.   is a major violator of monitoring or reporting require-
          ment for microbiological contaminants or turbidity or
          Total Trihalomethane (TTHM) for 12 consecutive months,
          or
     3.   violates the MCL for microbiological contaminants or is
          a major violator of the monitoring reguirments for
          these contaminants for a combined total of 12 consecu-
          tive months, or
     4.   violates the MCL for turbidity or is a major violator
          of the monitoring requirments for this contaminant for
          a combined total of 12 consecutive months, or
     5.   exceeds the level for which exemptions may be issued
          for any regulated inorganic, organic (excluding TTHM),
          or radiological contaminant, or
     6.   exceeds the MCL for TTHM for two or more running annual
          averages during the year, or
     7.   fails to monitor for or report the results of any one
          of the currently regulated inorganic, organic (other
          than TTHM), or radiological contaminants since the
          Federal requirements for that contaminant became
          effective (June 24, 1977), or
     8.   violates a requirement of a written and bilaterally
          negotiated compliance schedule.

NOTE:     EPA's Drinking Water Program is modifying the SNC
          definition, which will be used beginning in FY91.  It
          will include non-transient, non-community water systems
          in FY91 (they are not covered by the present defini-
          tion for SNC).  Transient, non-community water systems
          serving 500 or more people will be included in FY92,
          followed by all remaining systems in FY93.  EPA an-
          ticipates that this change will increase the number of
          water systems in SNC.

Chronic violators of drinking water regulations are classified as
persistent violators.  A community water system is a persistent
violator if during a 12 consecutive month period, it

     —   has four or more monthly violations of the bacterio-
          logical or turbidity MCL's or the monitoring and
          reporting requirements for these MCL's.
          has had two or more quarterly violations of the bac-
          teriological or turbidity MCL's or the monitoring and
          reporting requirements for these MCL's.
          has violated the TTHM MCL for one running annual
          average.
          has violated the monitoring and reporting requirements
          for TTHM for two or three quarters.
                              18-11
-------
                                9

                          SDWA (cont'd)


NOTE:     If a system meets the persistent violator definition
          and the SNC definition, the system is considered as
          SNC.
                                18-12
-------
                                10
              KEY TO IDENTIFYING INFORMATION IN THE
             CHESAPEAKE BAY FEDERAL FACILITIES LIST

The list will receive a new date whenever changes are made to it.
Check the date in the upper left corner of the page to ensure
that you are working from the most recent copy of this list.

Column l  State/NPDES Number - If the facility has a current
          NPDES permit, the number of that permit will appear in
          this column.  If the facility has more than one permit,
          additional permit numbers may appear under the "Com-
          ments" column.

Column 2  Facility Name - The name of the facility as it appears
          in EPA data bases.

Column 3  Federal Facility I.D.  Number - The number assigned to
          each federal facility in the GSA data base.

Column 4  New Violation Since 12/89 - Violations that occurred
          during/since December 1989 will be identified by a "T"
          (True).  Violations that occurred before December 1989
          will be identified by an "F" (False).

Column 5  Date of Compliance or Agreement - When a facility
          achieves physical compliance or signs a compliance
          agreement, the date will appear in this column.

Column 6  Comments - This column will be used to identify the
          media program in which the violations occurred and a
          brief description of the nature of the violations.  It
          will also indicate the activities which have been
          conducted to bring the facility into compliance.
                               18-13
-------
          EPA CHESAPEAKE BAY
FEDERAL FACILITY COMPLIANCE INITIATIVE
                   1990
                              Decembers, 1990
                    18-14
-------
          GOALS
o 100% COMPLIANCE OF BAY FEDERAL
  FACILITIES BY DECEMBER 1990
O ESTABLISH CONTINUING COOPERATIVE
 EFFORT WITH ALL FEDERAL FACILITIES
 TO ENSURE ONGOING COMPLIANCE
            18-15
-------
HIGHLIGHTS OP FEDERAL FAr.ll ITY INITIATIVE
     o GEOGRAPHIC AREA: ENTIRE CHESAPEAKE BAY WATERSHED
     o MULTI-MEDIA PROGRAM COVERAGE
      (NPDES,SDWA,RCRA,NPLJSCA,AIR)

        - MAJOR VIOLATIONS AS OF DECEMBER 1968
        - SIGNIFICANT POTENTIAL IMPACT ON BAY
        - ALL MAJOR NPDES FEDERAL FACILITIES IN BAY
        - TOTAL OF 50 DOD AND NON-OOO FEDERAL FACILITIES
     o OBJECTIVE: ATTAIN PHYSICAL COMPLIANCE IF POSSIBLE,
      OR IF NOT, FORMAL AGREEMENT WITH EPA AND/OR STATE
      CONTAINING SCHEDULE FOR ACHIEVING COMPLIANCE
     o STATIC LIST: CURRENT KNOWN VIOLATIONS ARE TOP
      PRIORITY
     o DYNAMIC LIST: WILL EXPEDmOUSLY WORK TO RESOLVE
      ANY NEW NONCOMPUANCE (MAJOR AND MINOR)
                      18-16
-------
                       C/i'esapeafce   Bay
                         FEDERAL  FACILITIES
                       COMPLIANCE INITIATIVE
EPA
REGION
       ol Dtl*mt F»cilitlt»
A Non-Otpj r t««»l ol Dtlimt ficilit
g Or iglRil I > Out ol Co«>pli|(ic«
gltturntd to Complltitct $lnc« 0
-------
                     STATUS OF CHESAPEAKE BAY
              FEDERAL FACILITY COMPLIANCE INITIATIVE
                      (Through November 1990)
START OF INITIATIVE - DECEMBER 1989
     13 - COMPLIANCE                    37 - NONCOMPLIANCE
          (13 DoD)                            (29  DoD,  8  NON-DoD)
STATUS THROUGH OCTOBER 1990
     38 - COMPLIANCE                     12  - NONCOMPLIANCE
          (32 DoD, 6 NON-DoD)                 (10  DoD,  2  NON-DoD)
                    25 RETURNED TO COMPLIANCE  STATUS
                    (ACTUAL OR COMPLIANCE SCHEDULE)
                           (19 DoD, 6 NON-DoD)
ASSESSING POTENTIAL NEW VIOLATIONS
9 Facilities - New Noncompliance  Since  9/15/90
           (8 DoD, 1 NON-DoD)
3 - COMPLIANCE                 6  - NONCOMPLIANCE
    (3 DoD)                        (5  DoD,  1  NON-DOD)
                                    18-18
-------
                        ISSUES/CHALLENGES

l.   Communication/Information Exchange
          (EPA, States, Facilities)

2.   Training/Complexity of Regulations

3.   Data/Tracking Systems Inadequate

4.   Multi-Media Approach Difficult

5.   How do we show environmental improvements?

6.   Foster partnerships yet maintain enforcement presence

7.   New noncompliance

8.   Inspection report delays

9.   Legal vs technical issues

10.  Bureaucratic process

        Organizational structures

        EPA vs State enforcement lead

        Escalation process

        Resources
                               18-19
-------
                          WHAT'S NEXT?
1.   Continue process/partnerships established


2.   Expand to include all media

     (i.e., UST, asbestos)


3.   Pollution prevention


4.   Develop  long   term   multi-media  environmental  compliance
     strategy.


5.   Federal community as role model
                                 18-20
-------
19.1  STATUS REPORT FROM THE WORKING SESSION ON THE LONG-TERM
     COMPLIANCE PLAN
19.2  ATTACHMENTS

     •  Compliance Monitoring and Enforcement Strategy for the NPDES Program
-------
19.1  STATUS REPORT FROM THE WORKING SESSION ON THE LONG-TERM
      COMPLIANCE PLAN
Carol Stokes-Cawley. Chief NPDES General Enforcement Section EPA, Region IH

      Ms. Cawley  reported that  last  December, under the Chesapeake Bay Compliance
Initiative (CBCI), Administrator Riley set two compliance goals for the Chesapeake Bay.  One
was to cut significant non-compliance or water violators in half by the end of the year.  The
second was to have all federal facilities in 100% compliance by the end of the year. During the
year, EPA, DoD,  and other federal facilities have been doing a lot of things innovatively and
differently to work toward accomplishing the administrative goals.

      To provide a preliminary evaluation of the 1990 Initiative in the  Chesapeake Bay and to
develop  a set of recommendations  for  1991  which build upon the  efforts to achieve 100%
compliance, a working session was planned at the Federal Facilities Conference.  The session,
which consisted of over 90 people, broke into groups. Each group came back with two things
that worked and two things that needed improvement in the initiative.  Each participant was
asked to vote for one activity or program identified as the most  successful component of the
initiative and one activity or program that needed improvement.  The results are as follows:

      Strengths of the Initiative

          High command attention (helped communication and budgeting)
          Communication between EPA, State and facilities has improved because of initiative
          Priorities were established
          Willingness by Regulators to participate more freely in negotiations
          Meetings with workers and all levels
          Summarized what needed to be done and feedback from EPA
          Information good and helpful
          August, 1990 meeting - Facility, EPA, States  (mtg. in Washington,  D.C., which
          promoted communication) facilitated communication (went through the UST)
      •   Progress report helped get out information on good  things going  on at facilities
          (D.O.D. progress report).

      Weaknesses of the Initiative

      •   List:     Not Accurate
                   Accusatory
                   Not Timely
                   Doesn't reflect risk
                   Can't get off
      •   Unrealistic expectation or goal (100%)
      •   Lack of awareness of goals - what they mean; how they were established

                                       19-1
-------
           Need clear direction to come into compliance and leeway for budget decisions
           Haste makes waste - Forced into initiative under tight timeframe
           Emphasis only on D.O.D. facilities - need to bring in others
           Communications - Late notification of initiative
           Accusatory  language - showing up on list  before formal notification to  federal
           facility of violation.

       In the second half of the work session, individuals were asked to recommend activities
that would  improve  compliance in the long term.  The following are a few of the ideas which
were discussed;

       1)   Develop a realistic program, a goal outline, and a specific reporting outline.
       2)   Focus on environmental audits to assure continued compliance (recommended EPA
           conduct  more multi-media inspections).
       3)   A yearly tour of the hazardous storage areas of the facility by the commander.
       4)   Develop a better exchange of information and even better communication among
           EPA, Federal Facilities, and State Agencies.
       5)   There is a need  for more staff and adequate funding.
       6)   Publish a list of violators quarterly in local newspapers.
       7)   Perform multi-media inspections.
       8)   Compliance and agreement for compliance are not the same thing. Sustainability of
           compliance is an issue which needs to be resolved.

       A questionnaire was also distributed that asked participants to identify an initiative that
would  improve compliance at Federal Facilities within the Bay Watershed.   The following
responses were compiled:

       1) Better information exchange between EPA, Federal Facilities and states.  Need info
       exchange mechanism.  For example, we are trying to complete a corrective action plan
       for USTs.  However, SWCB has yet to approve any  CAP (Navy) or provide a model for
       an appropriate "approvable" (sic) CAP.

       2) A yearly tour by the Facility Commander of areas used to store hazardous waste.

       3) Identify requirements for environmental personnel at facility level and then approve
       "fenced" money to fund these people.

       4) More staff and adequate funding at the activity level.

       5) To have a realistic program and goal outline developed by joint committees to follow
       and a specific reporting outline.

       6) Focus on environmental audits to insure continued compliance.  Find areas that need
       work and then work toward corrective actions.

                                         19-2
-------
7) Communicate to facilities the potential impact on resources (i.e., budget, staff) to
negotiate compliance versus cleaning up/preventing, by themselves.

8) That there  be workshops by each state  and their program  for  federal facility
compliance.

9) Publish a list of violations every quarter in leading newspapers in that state.

10) If Chesapeake Bay Initiation is to clean up the water of the Bay, then information/
inspection/attention should follow the 80/20 rule (80% problems by 20%  causes).  Major
impact/improvement areas should be highlighted and activities should be emphasized in
this area. For example, storm water management. What is the impact/benefit to the bay
of BMP and retrofits of grandfathered facilities via the current posture of compliance?
Would it be more beneficial to work on erosion or to address the asbestos portion of the
Clean Air Act?

11) A.   Redirect EPA resources  to conduct more multi-media  environmental audit of
         Federal Facilities.   Follow-up the assistance visits with "inspection visits"  to
         ensure the identified deficiencies have been corrected.  The audits need to go
         beyond "regulatory issues" and address environmental management and pollution
         prevention issues.

    B.   Since "compliance status" is a relatively poor indicator of environmental quality,
         develop better measures of environmental quality.

    C.   Emphasize an  enlightened  self-interest  and  personal accountability among
         individuals as  the key  success  factor  to achieving  environmental quality
         objectives.

12) I recommend that more pollution prevention initiatives be emphasized. This will put
us on the course to substantial compliance by preventing the pollution in the first place.
This would get us into the mode of not needing enforcement.

13) Compliance is not necessarily a measure of Environmental Quality.  Recognize that
compliance is only a part of the solution.  Other parts of the  solution relate to non-
compliance issues, i.e., non-point source controls, programs, public awareness, the level
of public participation or outdoor recreation use.
                                   19-3
-------
     COMPLIANCE MONITORING
              AND
          ENFORCEMENT
           STRATEGY

            FOR THE

         NPDES PROGRAM
        CHESAPEAKE BAY

               BY

        STATE OF MARYLAND
      STATE OF PENNSYLVANIA
        STATE OF VIRGINIA
U.S. ENVIRONMENTAL PROTECTION AGENCY
              1990
                19-4
-------
   TABLE OF CONTENTS


     1. INTRODUCTION

  2. PURPOSE AND GOALS

3. COMPLIANCE MONITORING
  AND ENFORCEMENT STRATEGY
           19-5
-------
    CHESAPEAKE BAY

COMPLIANCE MONITORING
         AND
ENFORCEMENT STRATEGY
 WORK GROUP MEMBERS
      MARYLAND:

     PATSY ALLEN
      JAMES METZ
    JAMES PITTMAN
  MERRILYN ZAW-MON

    PENNSYLVANIA:

    LEON OBERDICK
   STANLEY RUDISILL
       VIRGINIA:

     JOHN ROLAND
  RICHARD KOZLOWSKI
      TERRY ODA
  JOSEPH PIOTROWSKI
 CAROL STOKES-CAWLEY
          19-6
-------
                            INTRODUCTION

The Administrator  of the U.S. Environmental  Protection  Agency (EPA),
William J. Reilly at his inaugural to chair the Chesapeake Bay Executive
Council on December 19,  1989, challenged members of  the Council to
improve compliance of dischargers in the Chesapeake Bay drainage area.
Specifically, he challenged the States of Maryland, Pennsylvania  and
Virginia, and the EPA to:

      • Reduce significant noncompliance by 50%,  and

      • Bring federal  facilities  into  compliance.

Both of these goals were to be achieved by the end of 1990.

The States and EPA accepted the challenge and proceeded to work together
to improve coordination and cooperation between  the agencies.   Further,
established  compliance monitoring and  enforcement procedures  were
reviewed and improved as necessary and feasible within the time
constraints.

Predicting success of the compliance initiative, the States and EPA
formed a work group to develop a long term Compliance Monitoring and
Enforcement Strategy to build upon that success.   The goal of the  strategy
is to  continuously improve the effectiveness of the compliance  monitoring
and enforcement program  of  the agencies to  ensure that noncompliance
will continue to diminish.   This,  in turn, will  ensure that the goals to
reduce pollution and restore the living resources of the  Chesapeake Bay
will be achieved and  maintained.

The Strategy has  twenty-one objectives which will be accomplished over
the next few years.  A committee composed  of staff from the States of
Maryland,  Pennsylvania and Virginia and EPA will be convened to oversee
the implementation of the Strategy.  The committee's responsibility will
be  to initially develop an  implementation plan by  spring 1991, and
subsequently, to ensure that the plan is  being implemented.   The
Committee will also prepare  periodic  reports on the status of
implementation and of compliance in the Chesapeake Bay drainage area.
These  reports will be submitted  to the  various committees  of the
Chesapeake Bay Program and the general public.
                                  19-7
-------
                     CHESAPEAKE BAY

                  COMPLIANCE MONITORING
                           AND
                  ENFORCEMENT STRATEGY

                         FOR THE
                     NPDES PROGRAM
PURPOSE:
    MAXIMIZE NPDES  COMPLIANCE TO  ENSURE THE PROTECTION
    OF PUBLIC  HEALTH, THE ENVIRONMENT AND LIVING
    RESOURCES.

    ENHANCE COOPERATION AND COORDINATION AMONG THE
    STATES AND EPA TO CONTINUOUSLY IMPROVE COMPLIANCE
    WITH ENVIRONMENTAL REQUIREMENTS IN  THE  CHESAPEAKE
    BAY DRAINAGE AREA.
GOALS OF THE STRATEGY:
    • ESTABLISH PROCEDURES FOR CONTINUOUSLY  IMPROVING
    COMPLIANCE IN THE CHESAPEAKE BAY WITH THE AIM OF
    ELIMINATING NONCOMPLIANCE.

    • ESTABLISH A  COMMON BASIS FOR INITIATING AND
    RESOLVING ENFORCEMENT ACTIONS.

    • ESTABLISH PROCEDURES FOR COOPERATION AND
    COORDINATION  TO MAKE EFFECTIVE USE OF THE RESOURCES
    AND STRENGTHS OF THE INDIVIDUAL STATES AND  EPA, AND
    PREVENT DUPLICATION OF EFFORT.

    • PROMOTE THE USE OF POLLUTION PREVENTION METHODS
    WHICH CONSIDER MULTI-MEDIA IMPACTS TO MAXIMIZE
    ENVIRONMENTAL AND PUBLIC HEALTH BENEFITS.
PURPOSE AND GOALS    9/5/90                       PAGE 1 OF 1

                          19-8
-------
                               CHEASAPEAKE  BAY

                           COMPLIANCE MONITORING
                                       AND
                           ENFORCEMENT  STRATEGY

                                     FOR THE
                                 NPDES PROGRAM
 1.  MAKE  EFFECTIVE USE  OF  CURRENT ENFORCEMENT AUTHORITIES.
 OBJECTIVE 1.1: Maintain the Exceptions List at zero after July 1, 1991  thru:

 1.1.1  Taking forma! enforcement action against all violators in significant
       noncompliance (SNC) for the same pollutant before the end of the second
       consecutive quarter for which such violations persist (timely and apropriate
       enforcement actions).

 1.1.2  Using EPA to notify SNC dischargers of potential federal actions where the
       state feels federal assistance would assist in quick resolutions.

 1.1.3  Initiation by EPA of appropriate enforcement action (after consultation with the
       state), when timely and appropriate enforcement action has not been taken by
       the state to prevent a violator from appearing on the Exceptions List.

 1.1.4  Referral of state selected cases to EPA for federal enforcement.
OBJECTIVE 1.2: Eliminate SNC by January 1, 1993 thru:

1.2.1   Developing procedures to identify and address violations before they become
      SNC, including  reviewing historical violators to ensure that past problems have
      been fully addressed and closely monitoring dischargers who are discharging
      at levels near their limitations.

1.2.2   Rapidly escalating enforcement responses to prevent violations from becoming
      significant.

1.2.3   Establishing clear enforcement response criteria to ensure that appropriate
      enforcement actions are taken to address violations.


OBJECTIVE 1.3: Expand the use of criminal sanctions to ensure the integrity of the
the self monitoring and reporting system of the NPDES program by:

1.3.1  Establishing criteria for screening information to identify criminal activity.
COMPLIANCE MONTTOR1NG AND ENFORCEMENT STRATEGY                         Pavel 0(6
-------
1.3.2  Developing procedures to investigate suspect situations to identify the violation
      and determine its nature.

1.3.3  Improving communication betwen state and federal criminal investigators
      and prosecutors on possible criminal cases.


OBJECTIVE 1.4 Improve oversight on Federal Facilities to ensure compliance is
expeditiously achieved and maintained by:

1.4.1   Developing state and EPA procedures promptly notifying a federal facility of the
      occurrence of a violation and for escalating enforcement response.

1.4.2  Establishing an early decision point  for possible state referral to EPA of federal
      facility cases.

1.4.3  Revising procedures in EPA to promptly resolve federal compliance issues.

1.4.4  Providing quarterly federal facilities compliance status reports to the DOD
      Chesapeake Bay coordinator for senior level DOD assistance in resolving
      noncompliance.
2. ESTABLISH A  COMMON BASIS  FOR INITIATING  AND RESOLVING
ENFORCEMENT  ACTIONS.
OBJECTIVE 2.1: Use common procedures and criteria to rapidly identify and
address noncompliance, including the following:

2.1.1  Requiring and reviewing DMR's on a monthly basis to identify all types of
      violations.

2.1.2  Establishing enforcement reponse criteria to estimate violations.

2.1.3  Establishing quality control criteria or automating DMR review of major facilities
      to ensure consistent evaluation.

2.1.4  Revising Enforcement Management Systems to reflect any updated
      procedures.
OBJECTIVE 2.2:  Enhance pretreatment enforcement by addressing failure by
Municipal  Treatment Plants to adequately implement their programs and enforce
noncompliance of Industrial Users by:
COMPLIANCE MONITORING AND ENFORCEMENT STRATEGY    i 9 _ i A               Pme 2 of6
-------
 2.2.1  Improving monitoring of pretreatment implementation where appropriate thru
       increased use of  biomonitoring and chemical pollutant specific analysis at
       municipal plant discharges.

 2.2.2  Implementing pretreatment training programs for municipalities

 2.2.3  Increasing the severity of enforcement responses against all pretreatment
       violations, including the assessment of penalties.

 2.2.4  Adding pretreatment  violations to the Quarterly Non-Compliance Reports
       (QNCRs).

 2.2.5  Increasing use of enforcement against violations by Industrial Users by EPA
       and the states.

 2.2.6  Identifying, monitoring and enforcing when necessary at Industrial Users
       discharging to municipalities not required to have pretreatment programs.


 OBJECTIVE 2.3: Closely monitor  permits with  new NPDES requirements to
 maintain high compliance rates by:

 2.3.1  Developing requirements in new permits or companion enforcement orders  for
       toxics, stormwater, sludge and Combined Sewer Overflows to meet water
       quality standards.

 2.3.2  Revising procedures to monitor the permits to ensure that compliance with new
       program requirements will be timely achieved, or that appropriate enforcement
       proceedings are taken at an early date.
OBJECTIVE 2.4: Increase emphasis on minor NPDES facilities in the Chesapeake
Bay compliance and enforcement program by:

2.4.1  Developing procedures to maintain or progressively increase where necessary
      the number of minor dischargers routinely monitored for compliance.

2.4.2  Setting priorities for addressing minor dischargers based on impacts on water
      quality and living resources.
OBJECTIVE 2.5: Increase enforcement of operator certification and training
requirements at Wastewater Treatment  Plants by:

2.5.1  Implementing a standard permit condition to make operator certification an
      enforceable permit requirement.

2.5.2  Requiring periodic renewal of the license or annual continuing education
      obligations for the municipal treatment plant operators.
COMPLIANCE MONTTORING AND ENFORCEMENTSTRATEGY                         Paee3 of 6
                                           19-11
-------
2.5.3 Expanding operator licensing for pretreatment and wastewater treatment
      operators at industrial plants.


OBJECTIVE 2.6: Use and improve the quality of the Permit Compliance System
(PCS) to review waste loads, evaluate trends and assess compliance by:

2.6.1  Commiting the necessary resources to ensure data quality to make PCS the
      common NPDES data base for the Bay.

2.6.2 Continuing efforts by EPA to make PCS more user friendly in all aspects of data
      entry and use.
3. TARGET ENFORCEMENT ACTIONS  FOR  MAXIMUM ENVIRONMENTAL
RESULTS.
OBJECTIVE 3.1: Target inspections at dischargers in noncompliance to improve
compliance by:

3.1.1  Targeting inspections at violators; where resources are limited.

3.1.2  Revising criteria for prioritizing inspection targets.

3.1.3  Evaluating and developing improved inspection procedures if necessary.

3.1.4  Establishing a field citation program where appropriate.

3.1.5  Conducting Bay-wide inspector training thru EPA sponsorship.


OBJECTIVE 3.2: Target compliance monitoring and enforcement actions at
environmentally sensitive areas to enhance protection of the living resources by:

3.2.1  Identifying areas sensitive to point source discharge violations.

3.2.2  Ensuring both major and minor permits specify requirements that are sufficiently
      stringent to protect against adverse effects and are clearly enforceable.

3.2.3  Developing and implementing an education program to heighten the sensitivity
      of the dischargers to the living resources needing protection.

3.2.4  Establishing a method for quick detection of violations and criteria for early
      enforcement response in sensitive areas.
COMPLIANCEMONITORING AND ENFORCEMENTSTRATEGY    19_12                Paee4of6
-------
 4.  ESTABLISH PROCEDURES  FOR COOPERATION  AND COORDINATION
 TO MAKE EFFECTIVE USE OF THE RESOURCES AND  STRENGTHS QF
 THE  INDIVIDUAL STATES  AND EPA.  AND PREVENT  DUPLICATION OF
 EFFORT.



 OBJECTIVE 4.1: Strengthen the enforcement partnership by improving procedures
 for sharing of information and responsibilities between the states and EPA.


 OBJECTIVE 4.2: Increase the use of administrative and civil penalty authorities of
 the states to those established under the federal Clean Water Act by:

 4.2.1   Increasing administrative, civil and criminal enforcement authorities at least
      equivalent to those authorized under the Clean Water Act where necessary.

 4.2.2   Developing and adopting a state-wide penalty policy that will recoup.-where
      appropriate, economic benefit and gravity of the violations.


 OBJECTIVE 4.3:  Continue to conduct state/EPA quarterly enforcement meetings to
 review noncompliance and enforcement plans.
OBJECTIVE 4.4:  Continue to conduct joint annual meetings to share information
and accomplishments between all states and EPA.
5. PROMOTE THE USE OF POLLUTION PREVENTION METHODS WHICH
CONSIDER  MULTI-MEDIA IMPACTS TO MAXIMIZE ENVIRONMENTAL
AND  PUBLIC HEALTH  BENEFITS.
OBJECTIVE 5.1:  Establish Chesapeake Bay-wide NPDES compliance awards to
create positive reinforcement to comply by:

5.1.1 Developing criteria for identifying exemplary dischargers.

5.1.2 Establishing an awards system, including frequency and type of award,
     selection committee, etc.
OBJECTIVE 5.2: Establish municipal wastewater pollution prevention (MWPP)
programs to promote compliance at POTWs thru:

5.2.1 Defining the basic elements of a MWPP programs applicable to all Bay municipal
     facilities.
COMPLIANCE MONITORING AND ENFORCEMENT STRATEGY     19-13              Pate5of6
-------
5.2.2 Implementing a MWPPP appropriate for each state.


 OBJECTIVE 5.3: Conduct periodic conferences with the regulated community to
discuss new requirements and promote compliance.


OBJECTIVE 5.4: Increase the use of publicity on a cooperative basis to increase
incentives to comply and create a deterrence against noncompliance by:

 5.4.1  Making the list of significant noncpmpliers, including Federal facilities, available
      each quarter for publication in available newsletters and local media.


OBJECTIVE 5.5: Improve public access to compliance information for all
Chesapeake Bay dischargers through:

5.5.1  Improvement of public access by EPA to the national computer database, the
      Permit Compliance System (PCS).

5.5.2 Periodic meetings with EPA, the States and citizens to discuss compliance
      monitoring and enforcement.
COMPLIANCE MONITORING AND ENFORCEMENT STRATEGY                        Paee6of6
                                          19-14
-------
20.1 PROGRESS REPORT ON THE DoD/EPA AGREEMENT ON THE CHESAPEAKE
    BAY
-------
20.1   PROGRESS REPORT ON THEDoD/EPA AGREEMENT ON THE CHESAPEAKE
       BAY

Len Richardson, Director, Environmental Support Office, U.S. Department of Defense

The first DoD/EPA agreement concerning pollution prevention in  the Chesapeake Bay was
signed in September, 1984. DoD agreed to develop and initiate a pilot environmental program.
This program included a  study at 66 installations to determine the relative impacts of their
activities on the  Chesapeake Bay.   The study was completed in  1987 for a total  cost of
$570,000.

Results indicated that DoD was not a major contributor of pollution in the Bay. Mr. Richardson
noted that the DoD manages less than 1 % of the bay land area adjacent to the Bay. The study
also concluded that significant reductions at DoD facilities have been achieved.

A second agreement between DoD and EPA was signed in December of 1987. This agreement
went beyond the  1984 agreement and established specific commitments to achieve the overall
goals  of the Chesapeake Bay Program.  One action taken by DoD was the development of
federal facility implementation plans  which included a computer tracking program for  water
quality management. DoD also agreed to undertake a more active role in Bay restoration. For
example, one facility has been cultivating marshland along a tributary of the Bay.

The most recent  Chesapeake Bay Agreement was signed on April 20th,  1990 by Secretary
Cheney and the EPA.  Findings of the 1987 water quality study were incorporated in addition
to provisions for auditing, inspection and participation goals.  Langley Air Force Base and
Norfolk Navel Shipyard have been selected to serve as model facilities to demonstrate pollution
prevention techniques.
                                       20-1
-------
21.1   THE TOXICS REDUCTION STRATEGY FOR THE CHESAPEAKE BAY
21.2  ATTACHMENTS
         Major Flowchart - Major Committees in the Chesapeake Bay Program
         Chesapeake Bay Toxics Program Timeline
         Chesapeake Bay Basinwide Toxics Reduction Strategy
-------
21.1  THE TOXICS REDUCTION STRATEGY FOR THE CHESAPEAKE BAY
Richard Batuik. Chesapeake Bay Liaison Office, EPA Region HI.

This presentation focused on the toxic related issues in the Chesapeake Bay Program.  The two
goals that address the toxic issue in the Bay are 1) a toxic free bay by elimination of discharges
from all controllable sources and 2) by the year 2000, reduction in the input of toxic substances
to levels that would result in no toxic impacts on Bay wide resources.

Several strategies are being used to achieve these goals.  First, it is necessary to define existing
toxic impacts on the Bay and evaluate their stress on the system.  Institutionalizing efforts are
being made to reduce toxics and existing regulatory mandates continue to be expanded. As part
of the  toxic reduction initiative, a toxics of concern list based on risk assessments has been
developed and a baseline toxics loading inventory has been conducted.
                                        21-1
-------
0<
UW
^u
                3
                             en
•al Agenc
»mmittee
                      si
                      "* s
                      .§-£
                      0)
                      0
                    en c

                    S O
                    _N(J
                      en
                                 dJ

                              "c ^
                              QJ ."tJ

                              C C


                              o o
                            f3.52

                                         •§$
                                         -j ^_>
                                     c
                                     o

                                      II
                                        S o

                                        11
                                                       3
                                                       O


                                                    a:
                                                          5
                                                          c

                                                                 .0 S
                                                                    "8
                                                                    t;  Q-
                                                                    £.2
                                                                    o
                                                                    a
                                                                 •§
                                                                    bOu
                                                                  bO
                                                                  
-------
      DO

    —p5

      c/i 3
      u S
      *" °
      * ?»
      sill
                   I
      w 2 O
I
3
cn
                   §2
                  fl
                  > o
                  32
                   J S
                   •*« **


                   II


                   * *
21-3
-------
              CHESAPEAKE BAY
        TOXICS PROGRAM TIMELINE
       — Federal  Facilities  Perspective  —
Chesapeake Bay Program - Research Phase: 1978-1983
Chesapeake Bay Agreement of 1983 signed: 1983
Chesapeake Bay Program - Implementation Phase: 1984
Chesapeake Bay Agreement of 1987 signed: Dec. 1987
Basinwide Toxics Reduction Strategy adopted by the
  Chesapeake Executive Council: Dec. 1988
toxics Blue Ribbon Panel convened:  March 1989
Toxics Subcommittee convened for
  its first meeting: Sept 1989
Federal Facilities Compliance Initiative announced by
  EPA Administrator Reilly:  Dec. 1989
                         21-4
-------
 CHESAPEAKE BAY BASINWIDE
TOXICS REDUCTION STRATEGY
The long term goal of the this Strategy
is to work towards a toxics free Bay by
eliminating the discharge of toxic
substances from all controllable
sources.
By the year 2000 the input of toxic
substances from all controllable sources
to the Chesapeake Bay will be reduced to
levels that result in no toxic or bioaccu-
mulative impacts on the living resources
that inhabit the Bay or on human health.
                  21-5
-------
 CHESAPEAKE BAY BASINWIDE
TOXICS REDUCTION STRATEGY
  -  STRATEGY PRIORIT
Further definition of existing and
potential Bay toxics issues and impacts.
Institutionalizing coordinated efforts
necessary for addressing toxics
reduction issues and ultimately
achieving the long term goal of a "toxics
free" Chesapeake Bay.

Building on existing legislative and
regulatory mandates while taking
advantage of innovative technologies to
change the assessment, control,
reduction and prevention of toxics
loadings to the Bay.
                 21-6
-------
 CHESAPEAKE BAY BASINWIDE
TOXICS REDUCTION STRATEGY
Chesapeake Bay Toxics of Concern

Basinwide Toxics Loading Inventory

Baywide Toxics Monitoring Program

Chesapeake Bay Toxics Research
Program

Basinwide Integrated Pest Management

Chesapeake Bay Toxics Critical Issues
Forums

System for Measuring Progress under
the Strategy

Chesapeake Bay Ecological Risk
Assessment Framework for Toxics
               21-7
-------
ROLE FOR FEDERAL FACILITIES
  IN IMPLEMENTATION OF THE
BASINWIDE TOXICS REDUCTION
	STRATEGY	

More active participation in activities of
the Toxics Subcommittee and its
workgroups.

Become key players in the building of
institutional mechanisms for addressing
and implementing toxics assessment,
control, reduction and prevention issues
and actions.

Recognize leadership role in pursuing
implementation of more innovative
technologies for toxics reduction and
prevention within the Bay basin.

Beyond compliance, establish clear
goals for further toxics reduction and
prevention from Bay basin facilities.

Share implementation experiences with
other federal facilities, Bay basin states
and local jurisdictions.
                  21-8
-------
22.1  TOUR:          EPA REGION m, CENTRAL REGIONAL LABORATORY
                    AND DAVID TAYLOR RESEARCH CENTER
22.2  ATTACHMENTS
        Brochure - David Taylor Research Center
        Characteristics of Waste under RCRA
-------
22.1  TOUR:           EPA REGION m, CENTRAL REGIONAL LABORATORY
                        AND DAVID TAYLOR RESEARCH CENTER

      Tour Guide:  Norman Fritsche

      The  tour  of the  central  regional laboratory stressed the  control of hazardous
materials/wastes at CRL by tracing samples and chemicals from receipt in  the lab through
analysis to final disposal.  The CRL tour included a brief review of laboratory facilities and
analytical capabilities.

      The second stop on the tour was the Navy's David Taylor Laboratory.  The Lab has
several projects involving improved management of wastes on ships that were described.
                                     22-1
-------
£--.
11
-=! -Q
J<
« 5
£.£=
re o
= D.
< "
*- W
CC ^
Is
™ C3
J I
Er* t-
CC CH
cx c
£c§
x
_Q3
n.
E
u
u
E
re
c
0*
'5
t~
CO
£
£
3
>>

,w
E
CD


U.
DC
I
'"
TT-
CO
re



'•5
"5
CO
03
"C
">
L^
«
e
'03
c V
2 ^
S c
«e cj
" 13
 ?>
"3
o
earch Division, Portsm
VJ
03
Dfi
w,
C
O
_0
X
M
S
o
o
B.
a.
3
O.
«"s
-2 JS
"u >i
tS *"
1 a3
5 E5
CO _
0) g
•£ x
-a S
C a
CD d.
artments
13~
"3
projects involve severs
tH
05
C
CJ
>i
CC
2
to
03
M
CD
"u
the development of n<
c
fT
„»
y
M
'^D
O.
.2 5
-2 o
tS .2
lough specialized assi
Maritime Administrat
~ 03
T3 £
C ~-
< IB
«; ~
"in S.
c/;
03
0)
J5
_0
"u
O
D.
D.
en
ts
03
LM
•5
"D
c
"-"
03
E
c
c
cc
"S
c/3
(D CO
E «
Q- p
C r
"03
03
"C
03
v:
. O/
C ^
5^ us
S J2
c "
O -S
c c^
>. cc
i- c;
r;
c.
-c
c
CO
re
CO
03

'C
CO
C
nponent:
5
u
-c
to existing platforms ar
t/:
c
E
03
c
tl«
D.
P
C
03
•c
ishments are possible
a.
E
c
U
rc
a.
y;
H
-c
d
TO
d
u
«
CD
X
W
£
a.
c
CO
, .
C
03
C
O
c.
-a
c
re
c/i
03
G
u.
03
D-
w:
-c
03
_C
<« "03
C C
03 C
C O
"ocE
E 03
n
H
•4
X
8
M
it
The Annapolis Laboratory is the former U.S. Naval
Kngineering Experiment Station, which was estab-
lished in 1908 under the guidance of Rear Admiral
O w
••- re
C g
.2 03
V, W
K 3
_ a;
03 C
C ^
'So —
°l
i|
-c .5
- re
— E
> "Si
03 5
2T3
. C
S *
a.
&.S
Q P
(expanded, the station was renamed the Marine
Kngirieering Laboratory in 1963. The site became part
of the Center in 1967 and now houses two major
technical departments,
s The Propulsion and Auxiliary Systems Depart-
ment performs research and develops and evaluates
a variety of naval machinery. The Department
addresses such areas as propulsion, auxiliary and
electrical machinery components and systems:
electrical and machinery systems integration;
machinery dynamics and acoustic quieting; electric/
magnetic quieting; ship automation and control; and
shipboard energy availability and conservation.
* The Ship Materials Engineering Department
conducts research and development in metals and
alloys, corrosion, welding and fabrication, fuels and
lubricants, coatings, elastomers and plastics, ship-
board fire engineering, shipboard pollution abate-
ment and advanced composites. Recent develop-
ments include high strength, low alloy steels,
coatings for marine gas turbines, thermal spray
coatings, anti-fouling organotnetallic coatings and
aluminum anodes for shipboard cathodic protection.
The Department also works on smoke control
systems, fire extinguishing, fire resistant hydraulic
fluids and other projects, like a steam injection
disinfection system.
22-2
-------
a
of
                                        J2 x •*
                                        Uw-3
                                         X b. i~
                                         » 5 O
                                        JS g 2
                                         S u o>
                                         S 03 -C
                                        _1 "O **
                                        2 s 2
                                           ' D
Departm
underwate
e that ships
other dev
on charac
                                         .a e s - .a
e
's
                                         *- ^- •-
                                         03 c to
                                         » ® Q
                                         S E~
                                        _e t: «
                                        — co —
                                        u- Q. C
                                         O 0> O
                                         >>Q -z
                                         c
                                         =2 -c •-
                                         E E- Q
men
ens
                                       S2  —
• Te Ship Acous
and develop
vibrations, to
water weapons and
acoustic and vibrati
ed an Anechoic Flow Facil
the coustic Research Detach
e Department conducts full-sc
evalu
and a
Id. T
                                                     *>•§ g 3 ^
                                                    .£ ™ "3 £ tu
                                                    — • ••—•- i—i
                                                     § » s *S
                                                    cE£^
                                                    it Hi
                                                    ° 5 5 " -5
                                                    §n si
                                                    2 u « * a-
                                                      en 3 U »

                                                    •mil
                                                    S '~ 1: ra
                                                    •£ -o J= QJ 0)
                                                    JS $ £ £?£
                                                    <^cj S'S
                                                                        «-  — «
                                                                   « o  , 5 - o g.J5  .
                                                                   — .-fc.3
                                                                   .2 C « Q..H « T> T .2
                                                                 11IHII4|i
                                                                 Sfi.8gU°.-S3|S




                                                                        •c -a^ £ 3 S
evelop
techn
app
ent d
s ADP
f Navy
s, nume
ign, ma
uisition
fare anal
n additio
tes high
other De
ate
y o
ure
desig
acqu
warf
s. I
era
nd


Carderock Laboratory

-a
Hi
develops new vehicle concepts based on advanci

i , £


aerodynamics technology. To ready the most prom
ing concepts for full-scale development, the Depart
ment uses wind tunnels and towing tanks, flight tes
and manned craft trials. Current projects include
advanced rotorcraft, super-maneuverable aircraft
and surface effect ships.

"5
• The Ship Electromagnetic Signatures Departme
is responsible for research and development in
&4
'S
electromagnetic signatures for Navy ships and th
associated wakes. These efforts include electro-

£ S-

t«
o
magnetic theory, analytical models, countermeasui
design and control techniques, scale-model measui
ments in Center laboratories, trials at sea, and signa
and image processing development. Another maj
function is design engineering and instrument
support for both Department and Center projects

"5

** u.
<*v
« a °
• The Ship Structures and Protection Departme
develops structural concepts and design analysis
methods to ensure lighter, stronger, more reliable
ships and submarines. The Department also dete
mines the vulnerability of all types of naval ship
and develops ways to protect them against comb
threats and peacetime hazards. The effectiveness

o -a ;-
antiship and ASW weapon warheads is appraised I
support weapon design and deployment. Model an
full-scale tests are conducted to confirm behavioi
esear Center i
arch, development
r for naval vehicles
       £ •- £ ^ = - r^
.c
u
e
&
5 s g
"fli
a|l
 ^ -™ w-i
JS 2 co
H
 2"« -
•5- > S
_c
 •n ^ ' ^i
 « 2 S
•*- -C u}
 f~J
 § ™~g
 -i-
111
 -S.E-^
 J -c =c
 e > i
 £5-^
 c£ £
  '' u
              75 t- r- O t~
              -^ a  . r^ oa
       s i. §. 11
       s s £ | ft
       2 S " ^ H~
       > _• -S g g
       S "5 3 § .2P
is 5* a
    . cc ^
   r <£ M
   •— yi •>
   a 01 _
   p <- tc
   | 3 g
   -0 "er a
   10 -So1*"
   C C '^
     O_— k-l
       a>
            "~ a
            w QJ
              &-•
            S ffl
            S S
primary conc
airc'.raft com
ment of vehi
    « c3
    ca S
    ' G.
     aj
     c;
    3 ^ — .^:
S T3
-5 5
ca v:
i 5T t; » g ra .2
t; o; _5 "S .~ « —
         a»-
         , cc -O
         S £ g
         151
         P£ cr
ploy!
nd en
nt
                 ^£P"5   Sp^fll^.
                 "•SSoo^^-C"1")?
                 5»Sj5.sss-1^.s|  s
                 ^ca ^ .-S S 6 *s ss  e
                                         3.3>«:32 .
                                        j? S & S -2 P.
                                     IS

                              .
a
              -a

Center
officer
detachme

25
•S-2
II
o —
•—• co
>, t.
E= S
^5
> <
CO I_
a S
J! «
  01



2 „
^: a. c
« '3 '3
    CO
	. _a
CO



co g
03 «-

5l
•g«
2s"
« "^5
II
u ^
« "0
« o
c •>-

QJ —.
•£•0
  c
.2 ^2
§J2
EC
t: o
  >-,






!! 11!
2II1I
E s S^-S
« -^ a » «
•5 -* *, oo cu
IP e C-S co —
r/T1'— . C "
.s-11 i s
5 « E-S^
co C >i
• - 03 b*
« *:. co
^ -C S
u u —
IS -a £
O) C
> CO
£ *
                                                             •a a.

                                                                   co w








                                               03 CO
                                          asi-e-SJ
                                            = S.-S'"
                                            5 -2P2 ®
                                            * « tn —
                                              * S O
                                               £ u

 s-s •-
 « y « T3
flS-si
 Hie
 S^ 2»*
•^ ciJ C w
 >>s s "S
a a-2 T3
•s-s-i!
£-a a.
"Sgi
£-a °G
    11




                                                       «
                                                       5^
                                                         o






                                             22-3
Si
c S
3 *
*^ Cfl
-a S
.£ 2
5 IP
o
U3 l«
0) O.
2 C
> o
0 Q.
t- CO
O- 0)
- S
g-b
i i
•Ccd
(9 (D
a. u.
fa
M CO
e >,
0 >
•£ CO
2 z
'> 0

"S
"O
o


u
9i
>
0
U
-------
                CHARACTERISTICS OF WASTE UNDER RCRA
                                Background
     In 1976 Congress passed  the Resource Conservation and Recovery Act
(RCRA) which directed the  U.  S.  Environmental Protection Agency (EPA) to
develop and implement a program  to protect human health and the environment
from improper hazardous waste management.  EPA  first focused on large
companies which generate the  greatest portion of hazardous waste.  In
recent years, however, public attention has been drawn to the potential
for environmental  and health  problems that may  result from mismanaging
even small quantities of hazardous waste.  In November, 1984, the Hazardous
and Solid Waste Amendments to RCRA were signed  into law.  With these
amendments, Congress directed EPA to establish  new requirements that
would bring small  quantity generators who generate between 100 and 1,000
kilograms of hazardous waste  In  a calendar month into the hazardous waste
regulatory system.  EPA issued final regulations for those 100 to 1,000
kg/month generators on March  24, 1986.  Most of the requirements were
made effective September 22.  1986.
     A waste is any solid, liquid or contianed  gaseous material that you
no longer use, and either  recycle, throw away,  or store until you have
enough to treat or dispose.
     There are two ways a  waste  may be  brought  Into the hazardous waste
regulatory system:  "listing", and identification through "characteristics"
testing.  Listed wastes appear on any one of the four lists of hazardous
wastes contained in the RCRA  regulations (40 CFR Part 260),.  These wastes
have been listed because they either exhibit toxic constituents that
have been shown to be harmful to health and the environment.  Characteristic
wastes are those which are ignitable, corrosive, reactive or are EP  toxic
(40 CFR Part 260).  Some wastes  are considered  to be  "acutely hazardous".
                                    22-4
-------
These are wastes that EPA has determined to be so dangerous 1n small
amounts that you may accumulate only 1 kg/month.
     There are three categories of Hazardous Waste Generators:
          1)  generators of no more than 100 kg (conditionally exempt).
          2)  100 to 1,000 kg (small quantity generators).
          3)  generators of 1,000 kg or more per month.
Each of the categories has Its own regulations which are found 1n 40 CFR
Part 260.  The EPA facility must follow all state regulations first If
they are more stringent than the federal guidelines.  For example, Maryland
small quantity generators are those who generate between 100 - 550
kg/month.
                                        22-5
-------
           SAMPLE   DISPOSAL   FORM
Sourc«:_
Progrta:,
Analysis:.
Analyst:_
Data:.
Lab * |.

1
1
1
1
1
1
1
1
I
1
HON-Regul
Liquid f
1
1
1
I
1
I
1
1
atcd tfaite
Solid f Oil
1
j
1
1
1
1
I
1
I
II
1 j
| i
II
1 j
II
II
j j
II
II
II
j j
Regulated
Liquid 1 Sol
1
1
1
1
1
1
1
1
1
1
1
I
Vacte
id 1 Oi-)
1
1
1
1
1
1
1
1
1
1
1
                            22-6
-------
                                              LISTING OP CHEMICALS IN LOCATION 335
CHEMICAL NAME
  HP ANY NAME
PURCHASE ORDER NUMBER
       STOCK NUMBER
USER   DATE ORDERED
           DATE RECVD.                          IN
ORDER f    PACK LIST *   EXP.DATE HAZARD FLAM  STOCK
LOCATION   LOT/SERIAL*   DISCARD  CARCIN (Y/N) (Y/N) UNIT SEC
1,5-DIPHENYLCARBOHYDRAZIDE POWDER
J. T. BAKER CHEMICAL CO.

1,5-DIPHENYLCARBOHYDRAZIDE POWDER
J. T. BAKER CHEMICAL CO.

1,3-DIPHENYLCARBOHYDRAZIDE POWDER
J. T. BAKER CHEMICAL CO.

2-ETHYL-HEXANOIC ACID
KODAK CO.

4-AMINOANTIPYRINB
FISHER SCIENTIFIC
6PB-039-NNLX
4-AMINOANTIPYRINB
DAK CO.

ALUMINUM OXIDE (ALUNDUM)
THOMAS SCIENTIFIC
6PB-005-NNST
ALUMINUM OXIDE (ALUNDUM)
THOMAS SCIENTIFIC
6PB-005-NNST
ALUMINUM OXIDE (ALDNDUM)
THOMAS SCIENTIFIC
6PB-OOS-NNST
ALUMINUM REF STD
CONOSTAN INC.

AMMONIUM FLUORIDE
FISHER SCIENTIFIC
6PB-039-NNLX
AMMONIUM OXALATB
UNK K620-03
08/01/87

UNK K620-03
08/01/87

UNK K620-03
/ /

UNK P4442
11/01/83

UNK 0-1123
12/14/85

UHK 6902
05/01/78

UNK 1590-018
/ /

UNK 1590-D18
/ /

UNK 1590-D18
/ /

UNK AL
08/01/83

UNK A-665
06/01/72

UNK A-679
1400
335

1400
335

1*02
335

1*63
335

33
335

1*03
335

1397
335

1397
335

1)97
335

1*27
335

5
335

13
08/20/87

621718
08/20/87

621718
/ ,

3*6502
11/15/83

A13B
01/14/86

853083
05/10/78

BCF
05/02/88

1344-28-1
05/02/88
• .
1344-28-1
05/02/88

1344-28-1
08/10/83

5026
06/15/72

726242
06/19/86
/ / N N Y 250 335
N

/ / N N Y 25G 335
N

/ / N N Y 25C 335
N

/ / Y N Y 5000 335
N

/ / N N Y 100G 335
N

/ / N N Y 100G 335
N

/ / Y N Y POUN 335
H D

/ / Y N Y POUN 335
H D

/ / Y N Y POUN 335
N D

/ / N N Y 2 OZ 335
H

/ / Y N Y 453G 335
N

/ / Y N Y 4530 335
                                                                  22-7
-------
                                                      REVISED 6/13/89
                          CRL INVENTORY CONTROL SLIP
1.  CHEMICAL NAME:.

2.  Stock #	
                                    DATE:.
                  Lot or Serial #_
3.  Chemical Destination:

      a.  Empty!	I           Expired!	1

      b.  New^	X     Room #	    Date Ordered.

      c.  Removed from               to
                                        MoveL.
      d.  Removed from.
                  _to_
4.  Chemical Manufacturer or Supplier:

      a.  Aldrich             	

      b.  Arundel/Linde        ..

      c.  Baker                _

      d.  Burdick & Jackson       _

      e.  Chem. Services          ..

      f.  Daigger             	

      g.  Eastman             	

      h.  Baxter "            	
5.  Amount

      a.  Pint

      b.  Gallon

      c.  Ounce

      d.  Pound



6.  Initials	
Basic
Unit
Quantity
                          (Room)

                          (Room)
                        i.  Fisher              	

                        J.  Supelco Inc.        	

                        k.  Thomas              	

                        1.  Matheson            	

                        m.  Mallinckrodt        	

                        n.  Roberts             	

                        o.  Other (please specify)
Basic
Unit
Quantity
                        e.  Liter

                        f.  Gram

                        g.  Kilogram

                        h.  Cylinder

                        i.  Mtlliliter
                                      22-8
-------
 APPENDIX A



List of Attendees
-------
             Federal Facilities Conference Attendees
William F. Alcarese
Hawkins Point Road
U.S. Coast Guard Yard
Baltimore, Maryland  21226

Danielle Algazi (3ES43)
J.S. EPA, Region III
Environmental Planning Section
841 Chestnut Building
Philadelphia, PA  19107

^athew Amann
Safety Office
Rm 10-63  HFA-205
5600 Fishers Lane
Rockville, MD  20857

Thomas E. Baca
Deputy Assist Secretary for Defense
(Environment)
The Pentagon, Room 3D833
Washington, DC  203001-8000

3yron Bacon
Walter Reed Army Medical Center
5825 16th Street, N.W.
Washington, DC  20012
     Baker
3SA ROB

Richard Batiuk (3CBOO)
Chesapeake Bay Liaison Office
J.S. EPA, Region III
Annapolis, Maryland

^laria Bayon
sfASA HQ
400 Maryland Avenue, S.W.
Washington, DC  20546

Darwin Benidict
/A Medical Center
3erry Point, MD  21902

William Beverly
JSDA, ARS, BARC, FMOD, FEE, USS
Building 426  BARC-E
Beltsville, MD  20705
                                   A-l
 Rhoda Binley
 FDA Safety Office
 Rm 10-63  HFA-205
 5600 Fishers Lane
 Rockville,  MD  20857

 Teresa Boucher
 David Taylor Research Center
 Navy
 Bethesda,  MD  20084-5000

 MaryAnn Boyer (3ES43)
 U.S.  EPA,  Region III
 Environmental Planning Section
 841 Chestnut Building
 Philadelphia,  PA  19107

 Joe Bowden,  Law Enforcement Specialist
 Gettysburg  National Military Park
 Gettysburg,  PA  17325

 James Bridges
 Risk  Reduction Evaluation Lab (RREL
 26  West Martin L.  King Drivee
 Cincinnati,  Ohio  45268

 Donald  L. Brower
 AMSLC-RK
 HQ  US Army  LABCOM
 2800  Powder Mill Road
 Adelphi, MD  20783-1145

 Alan  L.  Brown  (3EA21)
 US  EPA,  Region III
 841 Chestnut Building
 Philadelphia,  PA  19107

 Capt. William  Buckingham,  Chief
 Environmental  Planning
 Boiling  AFB,  DC  20332-5000

 Nicholas Cavallaro
 U.S.  Army Test & Evaluation  Command

 Paul  Carroll,  Mgmt Analyst
 FDA,  Center  for  Devices &
 Radiological  Health
 12720 Twinbrook  Parkway  HF-Z-20
Rockville,  MD  20852

Jengfu J. Chen
Naval Weapons  Station
Yorktown, VA   23691-5000
-------
Jerry G. Cleaver
Environmental Programs Department
National Naval Medical Command
Bethesda, MD  20814

Don Clymer
US Dept of Agriculture
Allegheny National Forest
Box 847
Warren, PA  16365

Scott Coflin
Environmental Programs Department
National Naval Medical Command
Bethesda, MD  20814

Second Lt. Chris Cole
MD National Guard

Angelo Colianni
AFKA-Z1-EH-E, Building 2212
Ft. Meade, MD  20755-5115

Elizabeth Creel
EPA HQ
401 M. Street, SW
Washington, DC  20460

Jim Curlin
Pollution Prevention
 Information Clearing House
McKlean, VA

Shirley Curry
Andrews Air Force Base
1776 ABW/DEEV
Camp Springs, MD  20331-5000

Jayne Dahm  (3ES40)
U.S. EPA - Region III
841 Chestnut Building
Phila, PA   19107

Kerin J. Dame
U.S. Army Core of Engineers
Planning Divisino
P.O. Box 1715
Baltimore, MD  21203

Gordon Davidson, Director  (OS-530)
U.S. EPA, HQ
Office of Federal Facility Enforcement
401 M Street, SW
Washington, DC  20460
Mark Decot
USAF/LEEVIN
Boiling Air Force Base .
Washington, DC  20332-5000

Joseph S. DeLasho
Director Utilities/ Environmental Divi
Chesapeake Division
Washington Navy Yard
Washington, DC  20374

Eufrosina Diaconu
Environmental Engineer
DPSC-WIS-8A
2800 South 20th Street
Philadelphia, PA  19101

Major Michael C. Dougherty
HQ, U.S. Army Material Command
Alexandria, VA  22333

Olga Dominguez
408 Walnut Drive
Annapolis, MD  21403

Catherine L. Dow
Environmental Protection Specialist
Ordnance Environmental Support Office
Naval Ordnance Station
Indian Head, MD  2064

Hal Dusen, Environmental Engineer
913 Tactical Air Group/DEEV
Willow Grove Air Reserve Facility
Willow Grove, PA  19090-5130

Henry Dutcher, DOA
Aberdeen Proving Grounds
Aberden, MD  21005-5423

Russell Dyrland
Patuxent Wildlife Research Center
Route 197
Laurel, MD  20708

Jim Edward
U.S. EPA, HQ
401 M Street, SW
Washington, DC  20460

Thomas Eisiminger
Naval Security Group - HQ
Chesapeake, VA  23322
                                        A-2
-------
Fran Elford
Washington Navy Yard
Washington, DC  20374

Manton Emerson
VA Medical Center

Barbara Engel
Department of the Army
Fort Belvoir, VA 22060-5113

George English (3HW31)
On-Scene Coordinator
U.S. EPA, Region III
841 Chestnut Building
Phila, PA  19107

Edwin B. Erickson, (3RAOO)
Regional Administrator
U.S. EPA, Region III
841 Chestnut Building
Phila., PA  19107

Diana Esher, Chief,
Environmental Planning Section
U.S. EPA, Region III
841 Chestnut Building
Phila., PA  19107

John L. Feustle
607 Coleraine Road
Baltimore, MD  21229

William Fletcher
USDA, ARS, BARC, FMOD, FEE, USS
Beltsville, MD  20705

Sue Ellen Foor
Hercules Incorporated
P.O. Box 210
Rocket Center, WV  26726

Thomas E. Franklin
193D Special Operations Group/SGPB
Harrisburg International Airport
^iddletown, PA  17057-5086

Elizabeth L. Freese
Environmental Compliance Branch Head
20MNAVSECGRVCOM (6435)
3801 Nebranska Ave., NW
Washington, DC  20939-5213
Wayne Funkhouser
Head, Operations and Maintenance
U.S. Department of Agriculture
Facility Engineering Branch
Beltsville, MD  20705

James E. Gansel
Riverbank Army Ammunition Plant
Riverbank, CA  95367-0670

John R. Ganz
U.S. Department  METC
P.O. Box 880
Morgantown, WV  26507-0880

Basit H. Ghori
AMSLC-RK
HQ U.S. Army LABCOM
2800 Powder Mill Rd.
Adelphi, MD  20783-1197

Warren Gillette
Smithsonian Institution
Environmental Protection Specialist
Environmental Management & Safety
490 L'enfant Plaza - Suite 4202
Washington, DC  20560

Dennie Goss
R.D. 1 Box 200A
Olanta, PA  16863

Karen Gray
Fort Meade  AFKA-ZI-EH-E
Fort Meade, MD  20755-5115

E. Jacqueline Grimes
National Security Agency
9800 Savage Road
Ft. Mead, MD  20755-6000

Robert E. Greaves (3HW60)
Chief, RCRA Enforcement & UST Branch
U.S. EPA, Region III
841 Chestnut Building
Phila., PA  19107

Michael J. Green
NASA HQ (Code NXG)
400 Maryland Ave., SW
Washington, DC  20546
                                       A-3
-------
Henry Gunther
Philadelphia Naval Shipyard
Phila., PA  19112-5087

Patricia Haggerty
Law Engineering
4465 Brookfield Corporate Drive
Chantilly, VA  22021

William C. Hallow
U.S. Naval Academy
Annapolis, MD  21402

Ed Hammerburg
Maryland Department of the Environment
2500 Broening Highway
Baltimore, MD  21224

Charlene Harrison (3HW62)
U.S. EPA, Region III
TSCA Enforcement Section
841 Chestnut Building
Phila., PA  19107

Jeff Hass (3WM41)
U.S. EPA, Region III
Drinking Water/Control Section
841 Chestnut Building
Phila., PA  19107

Steven R. Hearne
Army Environmental Office
Attn: ENVR-EP
1	677 Pentagon
Washington, DC  20310-2600

Peter Hill
U.S. Army
H/Q DESCOM
LetterKenny Army Depot
Attn:  AMSDS-CC
Chambersburg, PA  17201-4150

Colleen Hillman
Law Engineering
4465 Brookfield Corporate Drive
Chantilly, VA  22021

William Hofmann
Letterkenny Army Depot
Chambersburg, PA  17201-4150
Karen F. Hogsten
Dept. of Justice
Bureau of Prisons
320 First St.,  NW
Washington, DC  20530

Joe Hoenscheid
Senior Environmental Protection Special.
Defense Logistics Agnecy
Cameron Station  DLA-5M
Alexandria, VA  22304-6100

Ted Horan
Social  Security Administration
6401 Security Blvd.
Baltimore, MD  21235

Bruce Hornaday
David Taylor Research
Carderock  Lab
Bethesda,  MD  20084-5000
 Kathy  Hudson
 Fort Meade
 AFKA-ZI-EH-E
 Fort Meade, MD
20755-5115
 John Hunton
 Warrenton Training Center
 P.O. Box 700
 Warrenton, VA  22186

 Bill Hutchison
 David Taylor Research
 Carderock Lab
 Bethesda, MD  20084-5000

 Joyce A. Jatko
 1700 St. Margarits Road
 Annapolis, MD

 Koury Johnkins
 2604 Rhode Island Ave., NE
 Washington, DC  20018

 Karen Johnson, Chief  (3WM43)
 UIC Section
 U.S. EPA, Region  III
 841 Chestnut Building
 Phila.,  PA   19107
                                        A-4
-------
 n W. Joyner
.S. Air Force
 gional Environment Office
 lanta, GA  30335

 »yce Jatko

'.chael Kane (substitute for Brian Keck)
 tval Air Station

'.ke Kanowitz
'.rector Emerency Management
iryland Department of the Environment
>OiO Broening Highway
iltimore, MD  21224

arry Kosteck
reject Manager, U.S. Army
rotection Base Modern Activity
^ISMC -PBC, Building 171
icatinny Arsenal, NJ  07806-5000

yula F. Kovach, Chief
ivironmental Protection Branch
ational Institutes of Health
ailding 13, Room 2W64
ethesda, MD  20892

art Kuhn
97 Standard Ct
mold, MD  21012

tanley L. Laskowski, Director
ffice of Pollution Prevention & Planning
.S. EPA HQ
01 M Street, SW
ashington, DC  20460

harles Lechner
berdeen Proving Grounds
berdeen MD

ohn Lee
ASA, Langley Research Center
S-106,
ampton, VA  23665-5225

oe Letorneau
ASA/GSFC
Bill Lewis, Chief
Maintenance & Operations
Veterans Affairs Medical Center
1201 Broad Rock Blvd.
Richmond, VA  23249

Pauline Levin, Chief  (3AM32)
Pesticides & Grants
U.S. EPA, Region III
841 Chestnut Building
Phila, Pa  19107

Capt. Gabriel Lifschitz
Andrews Air Force Base
1776 ABW/DEEV
Camp Springs, MD  20331-5000

Barry Lincoln
Environmental Programs Department
National Naval Medical Command
Bethesda, MD  20814

Will Lintner
Naval Facilities Engineering Command
200 Stovall St
Alexandria, VA  22332-2300

R. Donald Little
13417 Rich Lynn Court
Highland, MD  20777

Maryalice Locke  AEE-20
U.S. Federal Aviation Administration
800 Independence Ave., SW
Washington, DC  20591

Juan Lopez
US Army Test & Evaluation Command

Harvey C. Lyon
David Taylor Lab
Carderock Lab
Bethesda, MD  20084-5000

First Lt. Douglas Reed Macmillan
State Environmental Specialist for the
5th Regiment Armory
29th Division Street
Baltimore, MD 21201-2288

Kenneth L. Malick
886 Lark Drive
Harrisburg, PA  17111
                                      A-5
-------
Ross Mantione
Tobyhanna Army Depot
Tobyhanna, PA  18466-5054

Milton Harder
MD Dept. of the Environment

Pamela D. Marks
MD Dept. of the Environment
2500 Broening Highway
Baltimore, MD  21224

Cam Martin
Head, Office of Public Affiars
NASA Langley Research Center
Hampton, VA  23665-5225

Michael M. McCahill (Naval Ord MD)
Route 2 Box 76C
Indian Head, MD  20640

Scott McNally
VA Medical Center

Gary McSmith
Richmond, VA

Karen B. Menczer
AMSLC-RK
HQ US Army LABCOM
2800 Powder Mill Rd.
Adelphi, MD  20783-1145

Tawnya Mercer
David Taylor Research
Carderock Lab
Bethesda, MD  20084-5000

Frank Messineo
USDA, ARS BARC, FMOD, FEB, EPS
Beltsville, MD  20705

Julie Metz
Planning Division
Baltimore Corp of Engineers
P.O. Box 1715
Baltimore, MD  21203

Sherry Milas
Federal Facilities  Enforcement Office
Washington, DC
Edmund Miller
9622 Commonwealth Blve.
Fairfax, VA  22032-2822

Russel Milnes, Principal Deputy
Deputy Assistant Secretary for Defense
(Environmental) DASD(E)

Joe Montgomery
Office of Federal Activities
U.S. EPA HQ
401 M Street, SW
Washington, DC  20460

Lloyd Tolento Moore
Walter Reed Army Medical Center

Jeffrey Morris
Navy
David Taylor Research Center
Bethesda, MD  20084-5000

Steve Morris
VA Hospital
Richmond, VA

Joane Mueller
MD Dept. of Highway

Georgette Myers
Letterkenny Army Depot
Chambersburg, PA  17201-4150

Wayne Naylor, Chief  (3HW63)
UST\Lust Enforcement
U.S. EPA, Region III
841 Chestnut Building
Phila., PA  19107

Marian B. Nuckolls
GSA, ROB
(202) 708-5082
Mike Baker

Edward Olenginski, Manager
Utilities/Environment Branch
Chesapeake Division
Washington Navy Yard
Washington, DC

Bret Oltjen
Fort Meade
MD RTE 175
Fort Meade, MD  20755
                                       A-6
-------
hn C. Ordaz
vironmental Engineer
fice of Environmental Mgmt & Safety
0 L1enfant Plaza
shington, DC  20460

ry Orth
N Naval Security Station
01 Nebraska Ave., NW
shington, DC  20390

hn Palcer
rrenton Training Center
0. Box 700
rrenton, VA  22186

id Parramore
vironment Safety and Health Office
.iladelphia Naval Shipyard
dla., PA  19112-5087

.chard Pecora
sistant Secretary Operations
iryland Department of the Environment
iOO Broening Highway
iltimore, Maryland  21224

ones  A. Pedrick, Jr.
SPA Coordinator
trine Corps Combat Development  Command
aantico, VA

.chard V.  Pepino, Chief  (ES40)
ivironmental Assessment Branch
.S. EPA, Region  III
11 Chestnut Building
lila., PA  19107

2rnie Perry
.S. Army  Test  &  Evaluation  Command

:ephan J.  Pijar,  Sr.
DA,  Center for Devices  &  Radiological  Hec
2720  Twin Brook Parkway  HFZ-20
ockville,  Maryland  20857
eltsville Research Facility
eltsville, MD  20705

enny Plumeau
aw Engineering
465  Brookfield Corporate Drive
hantilly,  VA  22021
Gary M. Pominville
MAJ BDE ENGR
157th SIB (M),
Horsham, PA  19044

Deborah A. Potter
135 Cherwell Court
Williamsburg, VA  23188

David A. Prevar, USDA
Agricultural Research Service
Beltsville Area
National Agricultural Library
Room 020
Beltsvile, MD  20705

Ned Pryor
Naval Facilities Engineering Command
200 Stovall St.
Alexandria,  VA  22332-2300

Larry Ramsey
GSFC/NASA

Timothy Rath
Navy
David Taylor Research Center
Bethesda, MD  20084-5000

Steve Rice
Naval Electric Systems Engineering Activ
Saint Inigoes, MD  200684

Len Richardson

David J. Riedel, P.E.
Chief Engineering & Housing Division
Bldg. 250 Vint Hill Farms Station
Warrenton, VA  22186

Lew Riess
Philadelphia Naval Shipyard
Philadelphia, PA  19112-5087

Caroline H.  Roe,
Env. Compliance Officer
NAL, RM.20
10301 Baltimore Blvd.
Beltsville,  MD  20705

Charles Roland
Area Maintenance Support Activity 113
Green Castle, PA
                                       A-7
-------
 Russell Rowe
 Department of Defense

 LTJG Matt Ruckert
 Coast Guard Reserve Training Center
 213 Brad Court
 Newport News, VA  23603

 Lydia Sanchez
 Felipe B. Sanchez
 P.O. Box 180
 Dahlgren, VA  22448

 Gary Schneider
 Department of Energy W.V.
           Martha Stanczak
           Tobyhanna Army Depot
           Attn:  SDSTO-JD
           Tobyhanna, PA  18466-5078

           John P. Stasko
           Patuxent Wildife Research Center, RTE ]
           Laurel, MD  20708

           Albert Steel
           Walter Reed Medical Center
           6825 16th St.,  NW
           Washington, DC  20012

           Capt.  H.A. Stephan
           CO NAVAMPHIBASE, Little Creek
           Norfolk, VA  23521-5140
 William M. Schultz                       Janice Streeter
 Air Force Experimental Training Activity Public Works Dept (Code N492)
 P.O. Box 1447                            Naval Amphibious Base, Little Creek
 Williamsburg, VA  23188                  Norfolk, VA  23521-5141
 Edward Schwenk
 Environmental Programs Dept.
 National Naval Medical Command
 Bethesda, MD

 Leslie Scott
., VA Medical Center
••'Perry Point, MD

 Steve Sekscienski
 Department of the Army
 Directorate of Engineering & Housing
 Fort Belvoir, VA  22060-5113

 Vince Sexton
 Social Security Administration
 6401 Security Blvd.
 Baltimore, MD  21235

 Doug Sharp
 EPIC
 Victor Smith
 Naval Electrical Systems Eng,
 Saint Inigoes, MD  20684
Act
 Henry Sokolowski, Chief (3HW26)
 CERCLA Federal Facility Section
 U.S. EPA, Region III
 841 Chestnut Building
 Phila., PA  19107
George Sundstrom

Koge Suto (3WM52)
U.S. EPA, Region III
841 Chestnut Building
Phila., PA  19107

Conrad Swann
Aberdeen Proving Grounds
Aberdeen, MD  21005-5423

Neil Swanson (3CBOO)
U.S. EPA, Region III
841 Chestnut Building
Phila., PA  19107

Steven Swope
3128 Riverview Drive
Colonial Beach, VA  22443

W. Wade Talbot
U.S. EPA Environmental Photographic
  Interpretation Center/ORD
Vint Hill Farms Station
Bicher Road, Building 166
Warrenton, VA  22186-5129
              *~°

Capt. James Taylor, Commander
Norfolk Naval Shipyard
Attn: Code 100
Portsmouth, VA  23709
                                       A-8
-------
 udy Taylor
 'ort Meade, AFKA-ZI-EH-E
 •ort Meade, MD  20755-5115

 'irst Lt William Thacker
 Environmental Coordinator
 tolling Air Force Base
 Jashington, DC  20332-5000

 Jregory A.  Thompson

 lajor Robert Thompson
 Acting Dept. of Defense
 SPA Liaison Officer
Jon Ware

Robert B. Webster
448 McClellan Drive
Pittsburgh, PA  15236

George Weeks
Naval Air Statipn
Patuxent, MD  20670

Roger West
Coast Guard Reserve Training Center
Route 3, Box 1154
Glouster, VA  23061
Judy Timberlake,  Commander                 Colonel Gerald Williams
VTTN:  CETHA-EC-A                           Deputy Commander
Aberdeen Proving Grounds                   Fort Belvoir
J.S.  Army Toxic & Hazardous Materials Agen. Attn:  DEH-ENRD  Bldg. 1442
\berdeen, Maryland  21010-5401             Alexandria,  VA  22060-5113
Timothy Toplisek
J.S.  Army HQ  DESCOM
jetterKenny Army Depot
\ttn:  AMSDS-INE
2hambersburg,  PA  17201-4150

2apt. Gerald Torrence
562A Forney Loop
?ort Belvoir,  MA  22060

John Turner
:hief of Safety Office
Dept. of Defense

^orraine Urbiet (3ES43)
federal Facilities Coordinator
J.S.  EPA, Region III
341 Chestnut Building
?hila,  PA  19107

Thomas Vegella
Industrial Hygienist - FDA
12720 Twin Brook Parkway
*ockville, Maryland  20852

-------
APPENDIX B



Survey Results
-------
                              A106 SURVEY
                                 RESULTS
PARTICIPATING AGENCIES
Smithsonian Institution                      National Aeronautics and Space -
Department of Air Force                    Administration
Department of Army                       Environmental Protection Agency
Department of Navy                       Department of Agriculture
Department of Defense                     Department of Energy
Federal Aviation Administration              Defense Logistics Agency
Virginia National Guard                     Veterans Administration

Number of Respondents:   28
TRAINING

1. Have you had any training on A106?      yes 57%  no 36%  N/A 7%

      a) If yes, what has your training consisted of?  (Check as many as apply)
        [number of respondents selecting each training source; out of 28]

            7  handbook materials
            12  help from others familiar with the program
            6  training workshop on A106
            4  other  (Computer program, A106 instructions, Completing
                       project forms)

            3  no response


2. How would you rate your training? Average: 4.6 (acceptable)
  Selection by category:

    682              1            11
(1-3) poor   (4-6) acceptable  (7-9) good    (10) exceptional    N/A
3. How would you improve A106 training?
      - Increase availability
      - Clarify forms and instructions
      - Supply a manual
      - Offer facility specific guidance
                                     B-l
-------
PROJECT REVIEW

4. How long have you been involved with the A106 process?
      21%  less than 1 year       40%  between 1  - 3 years
      21%  more than  3 years     18%  no response

5. How much time were you given to review projects?

  Selection by category:

     JL          jL              _3_      _4_          JL
  1 -2 weeks     3-4 weeks    > 1 month     ?      No response
6. Is your Agency and office using A106 as a planning tool?
  Yes   61%     No  32%    No response 7%
      If yes, what disincentives exist for you to use A106 as a planning tool?
            - Poor timing
            - A106 is a low priority
            - Headquarters makes adjustments
            - Insufficient training
            - Limited access to information
            - A106 doesn't apply to industrially funded projects

      If no, do you have any other system that helps you plan your
      agency's/facility's environmental needs?
            - Internal workplan/ budget system
            - Local budgeting
            - Pollution Control Reports
            - Annual facility audits
            - EPA enforcement initiatives
7. What feedback did you receive regarding the project? (Check as many as apply)
  [number of respondents selecting each feedback source; out of 28]

       9   Recommended needed project sheet
       6   Conversations with facility representative (s)
       3   Federal facility compliance agreement negotiation
       3   Other (from headquarters)
       5   No feedback
       5   No response
                                     B-2
-------
8. Do you know if the project was finally funded?
  yes  57%   no 11%    ? 11%    No response 21%

      If yes, what was the final outcome (i.e. project was close to budget,
      time frame, etc.)?
            - 2 projects: cost > budget
            - 3 projects: variable
9. What do you think the goals of A106 are? (Check as many as apply)
  [number of respondents selecting each goal as one of several; out of 28]

      22  For budgeting purposes               19  For tracking purposes
      21   For program planning                  15  For pollution control
      20  For compliance                       1   Other ( ? )

       1   No response

      52% Chose 4 or more of the above
      41% Chose 2-3 of the above
       7%  Chose 1 of the above

      a) Have the goals  been reached?
        yes  36%  no  46%   ? 7%   No response  11%
10. What areas would you improve in the A106 process?  (Check as many as apply)
   [number of respondents selecting each area; out of 28]

      14  training                    8  forms
      10  timing                     4  review chain
      10  budgeting                 4  other: - Computerization of A106
                                         - Training publicity
       6  no response                    - Direct Feedback
BUDGETING

11. How effective is A106 in determining budget requirements for environmental
   projects?  Average: 5.5 (adequate)

Selection by category:
       _3_             _7_              _6_         J_        11
(1-3) ineffective   (4-6) adequate   (7-9) effective   (10) very     N/A
                                                effective
                                    B-3
-------
12. Is a 2-year budget cycle compatible for funding projects necessary for
   compliance?       yes  39%   no 36%   N/A  7%   No response 18%
13. How would you improve the budgeting process?
      - Make future projections     - Allot funding for newly identified projects
      - Increase feedback          - Allot funding for environmental compliance
      - Speed up the process      - Ensure use of funds on project "start" date
      - Link A106 to Army  1391     - Include daily budget in A106
      - Use appropriated funds for all
       required projects
OTHER RESOURCES

14. Did you use any additional resources to help you with A106 such as a
   computerized data system?
      - Computerized data system
      - EPA facilities
      - Spreadsheets
15. What is the best way to obtain up-to-date A106 information?
      - Computer file          - Installation updates
      - EPIC                 - Directly from EPA
      - Internal Tracking System
16.  Do you currently send projects to state agencies?
   yes  11%   no  78%  ?  4%   No response  7%
    a) Do you think that state agencies should be involved?
      yes 39%    no 32%   ?  7%   No response  22%
17. Other comments?
      - Original Forms should be supplied.
      - A106 is time consuming with little benefits.
      - A106 should not lead to enforcement actions because information is
       volunteered.
      - A106 is focused on clean-up, not on prevention.
-------
               Federal Facilities Conference Evaluation
                         Summary of Results*

I.  Workshops

The speakers for each workshop were rated on a scale from 1 (poor) to 5
(excellent). The following figures represent the average rating for each
category.
TOPIC
Pollution Prev.
Program
Refresher course
onTSCAPCB
requirements
New developments
in CERCLA
New drinking water
requirements
Spill prevention
and response
UST compliance
Asbsestos/
NESHAPS
PREPARED
4.2
3.3
4.3
4.5
4.3
4.5
4.3
HELD
ATTENTION
4.0
3.2
4.0
4.1
4.1
4.2
4.2
UNDERSTOOD
TOPIC
4.3
3.5
•
4.4
4.4
4.5
4.3
4.3
COMMENTS:
      Offer workshops more than once... Presentations lacked detailed
information... Too general... Provide more information on SDWA standards
for community systems... New Clean Air Act requirements were not
addressed... Allow more time for discussion.
      Excellent handouts...Handouts of slides and presentation notes would
be helpful...Overheads were not ledgeable...Not all acronyms were
understood... Some speakers lacked sufficient knowledge of RCRA and TSCA
requirements.
      Well organized overall.
* 66 Conference attendees completed the Conference Evaluation.

                                  8-5
-------
II. Questions and Answers:

1. Were you satisfied with the accommodations provided by the Ramada
  Inn?
                  Yes....    88%      No...   12%

2. Please make suggestions for future conference locations:
      Annapolis, MD, Williamsburg, VA, Washington, D.C., Philadelphia, PA,
      Baltimore, MD, Richmond, VA.

3a. Was the tour well organized?
                  Yes...   92%      No...    8%
 b. Was the content of the tour appropriate?
                  Yes...   92%      No...    8%
 c. Comments:
      Provide a briefing on the lab before the walking tour...Spend more
      time on the lab processes and inspection procedures...Tour was very
      enjoyable.

4a. Did the Pollution Prevention presentation enhance your knowledge of
   this new strategy in any way?
                  Yes...   94%      No...    6%
 b. Would you be interested in receiving more information on the
   subject in  the future?
                  Yes...   96%      No...    4%
 c. Comments:
      Excellent... Very important... Offered new and pragmatic ideas...
      Include in future agenda...  Not aware an Act was passed... Too
      general... Need more information on  alternative materials, waste
      stream analysis, and EPA requirements for federal facilities...
      Pollution prevention programs are desirable but funds are limited.

5a. Did you like the opportunity to choose among several activities(e.g.
   different workshops, tour vs. strategy working  session)?
                  Yes...   90%      No...    10%
 b. How would you like to see workshops scheduled in the future?
             Grouped...   61%        Individually...   39%
 c. Comments:
      Offer workshops more than once... Offer only two courses per group...
      Provide an opportunity to interface with the speakers... Offer evening
      discussion groups... Maintain original schedule of workshops... Provide
      more handouts.
                                 B-6
-------
6. How would you rate the overall preparation and presentation of the
  conference by EPA? (scale: 1 =poor, 5=excellent)
                  Rating: 4.1

7a. Would you like to see more panel discussions at future events?
                  Yes...  82%       No...   18%
 b. Comments:
      Taylor and Williams gave pertinent and informative talks; they were
      excellent.

8. Did you prefer panel sessions on...
      Regulations/technology review only?                  8%
      Discussion of issues only?                           2%
      Both of the above?                                  90%

9. If you were running the conference next year, what changes (if any)
  would you make in order to achieve the best possible results?
      Improve registration procedures... PreregisteYed attendees would
      get preference... Mail agenda three months before conference...
      Provide an attendance list in advance... Reduce session time to 50
      minutes... Begin earlier and end earlier... Shorten breaks... Provide
      tables.

      Offer most popular workshops more than once... Have more speakers,
      fewer workshops... Present keynote address first... Invite more
      installation commanders and allot them more time during panel
      discussions... Encourage participation from non-DOD facilities and
      state program experts... Offer more breakout session's.

      Give presentations on successful clean-up operations... Provide
      information on state priorities... Provide handouts of slide
      presentations and overheads... Improve the quality of overheads...
      Provide "Yellow", "Red", "Blue", and "Purple" books to new facility
      personnel... Continue to emphasize organization and management...
      Extend conference to five days.
                                 B-7
-------
10. Do you have any suggestions for agenda topics at future conferences?

      Stormwater Regulations and Management
      Sewage Sludge Regulations
      Permit Writing
      Waste Minimization
      Community Pollution Prevention Program Model
      Media/ Public Awareness of Environmental Issues

      New Hazardous Ranking system
      New Remedial Technology and Technology Transfer
      New Clean Air Act
      RCRA Laboratory Waste Regulations/Solutions
      Compliance Tracking (EPA and State levels)
      Multi-media Audits

      Managing and Organizing an effective facility Environmental Office
      Integration of the NEPA Process with Substantive Compliance
      NEPA/CERCLA Integration
      RCRA/CERCLA Integration
      Household Hazardous Waste Identification
      Impact of GSA Facilities on the Bay

      RCRA Reauthorization
      Non-point Source Pollution Control
      Federal Facilities with Laboratories (NIH, FDA, DA)
      Compliance Strategy
      "Lessons Learned and Change Required"
      Results and Trends in Compliance and Regulation
      Panel Discussion on the Formulation of Regulations
                                      B-8
-------
-------