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6.1. ERMUSR 05-13-2003 J Elk River Municipal Utilities 322 King Avenue phone: 763.441.2020 Elk River,MN 55330 Fax:763.441.8099 May 6, 2003 To: Elk River Municipal Utilities Commission John Dietz Jerry Takle James Tralle From: Bryan C. Adams Subject: Spill Prevention Control and Counter Measure Plan In 1996, Associated Consultants Engineers Inc. developed the initial Spill Prevention Control and Counter Measure (SPCC) plan. The EPA issued new SPCC regulations that require ERMU to revise the current plan and incorporate the new rules. The new rules were to be adopted by February 17, 2003, with full implementation by August 18, 2003. Due to comment to EPA concerning the new rules, the adoption date has been delayed to August 17, 2004, with implementation by February 18, 2005. Associated Consultants Engineers has revised our plan to satisfy the new rules. Attached for your review are the following pertinent sections of this SPCC plan. The entire document is available if you desire to review it. 1.0 Introduction and Summary of Applicable Regulations. 1.2 Necessary Alterations to Implement the SPCC plan. The cost to implement this plan is in the $10,000-$15,000 range. 2.0 Implementation. Certification of Substantial Harm Determination Form. Drawings Staff recommends this plan be received and filed with authorization to implement the plan. 1.0 INTRODUCTION 1.1 SUMMARY OF APPLICABLE REGULATIONS The United States Environmental Protection Agency (EPA) has established regulations for oil pollution prevention in the Code of Federal Regulations, Title 40 (40 CFR), Parts 110 through 112. The regulations require that a petroleum Spill Prevention Control and Countermeasure (SPCC)plan be prepared if it could reasonably be expected that a harmful quantity of oil could be discharged into navigable waters of the United States or adjoining shorelines. These regulations apply to facilities that have a total of 1,320 or more gallons of above ground oil storage. Transformers containing mineral oil fall under the SPCC regulations. The regulations require that a report must be sent to the EPA Regional Administrator and the Minnesota Pollution Control Agency (MPCA) within 60 days of a single spill of more than 1,000 gallons or two spills of 42 gallons or more each from the same facility within a year. All spills regardless of size must be reported to the MPCA. A spill is defined as any spilling, leaking, pumping, pouring, emitting, emptying or dumping of petroleum. A Discharge Notification Form is included in Appendix A and should be sent to both agencies listed if a spill should occur. The Notification Form should include the facility name, location, maximum facility storage capacity, rn normal daily throughput, spill date, description, cause, corrective action and additional preventive m measures that have been taken. A copy of the SPCC plan should be submitted with the notification form. The EPA requires that a complete copy of the SPCC plan be maintained at the facility if it is attended at least 4 hours per day, or at the nearest office if not attended. The facility management must make the plan available to the Regional Administrator of the EPA for onsite review during normal working hours. The SPCC Plan must be reviewed and revised, if necessary, every five years and anytime there is a change to the oil storage facilities. The EPA requires that a registered professional engineer certify all SPCC plans and amendments. If the facility does not experience any changes in the oil storage 1 facilities within the five-year review period, the facility manager can accomplish the five-year review. If the review indicates that new technologies will offer significantly improved discharge prevention and control,the new technologies should be implemented and included in the SPCC plan or an amendment to the plan. New facilities going into operation before August 17, 2004 must have SPCC plans in place within six months of startup. Facilities commencing operation after August 17, 2004 must have SPCC plans in place by February 18, 2005. Facilities beginning operation after February 18, 2005 must have their SPCC plans in place before startup. The above timetable for new operations also applies to any change at an existing facility that affects petroleum storage or use activities. The EPA requires that all facilities with the aggregate aboveground storage capacity of 1,320 gallons or more of oil maintain a SPCC plan. Containers of oil less than 55 gallons need not count toward the 1,320-gallon value. However, the Regional Administrator of the EPA can require any facility under the jurisdiction of the EPA to prepare a SPCC Plan, or an applicable part thereof. 2 1.2 NECESSARY ALTERATIONS TO IMPLEMENT THE SPCC PLAN-40 CFR 112.7 1 The installation of several facility improvements is critical to the implementation of this SPCC plan. The plan is contingent upon making the following facility alterations: 1 1. Conduct spill prevention training at least once each year(40 CFR 112.7(f)). 2. Add NFPA warning labels and product identification labels to all tanks inside and outside the plant. This will aid the fire department in the event a fire occurs (State Fire Marshal's office). 3. Place a sign on the substation fence with the name, address and emergency phone number for the facility. The sign will allow non-utility personnel to contact the utility in event of a discharge or other emergency (State Fire Marshal's office). 1 4. Provide secondary containment for the substation transformers (40 CFR 112.7(c)). The existing substation rock, along with the physical size and grading of the substation may provide adequate secondary containment. The largest substation transformer holds 4,153 gallons of mineral oil. The substations have a 6-inch base of crushed rock. If the rock has 50% voids, the required substation are for containment would be: (4,153gal) 0.134ft' gal = 2,226 ft' �6inchesX50% lft(12inch) All of the ERMU substations are larger than 2,226 square feet. A soil analysis would help determine the percentage of voids in the crushed rock at each substation. Additional rock can be added if needed. Any substation modifications must also comply with the National Electric Safety Code. 5. Provide means of secondary containment for the tanker truck during the unloading process (40 CFR 112.7(h)). Secondary containment can be by means of a berm or curb. The volume 3 of the containment area must be equal to the largest compartment of the tanker plus sufficient freeboard for precipitation. A suggested design for a truck unloading area is included in the appendix. As an alternative, temporary, portable truck unloading secondary containment barriers can be obtained from suppliers of spill cleanup products. A third alternative might be to place a low earth berm at the eastern perimeter of the drive area. An opening or pipe could be place in the berm for drainage. A sandbag or valve could be used to create a temporary ponding area during the truck unloading process. A suggested berm design is provided in the Appendix. 6. Provide means of containment for the 55-gallon drums in the plant basement. A pallet containment system or a small curbed area would be acceptable (40 CFR 112.7(c)). 7. Provisions must be made for draining standing water from secondary containment areas such as plant basements, pipe trenches, diked, bermed or curbed areas (40 CFR 112.8(c)(3)). A sump with manually operated pump or one or more drainpipes,with lockable manual valves, can be installed to facilitate the removal of standing water. The sump pump or drain valves must be opened only by facility personnel and records must be kept of each drainage event. The record must be made apart of this SPCC plan. Appendix B includes a log sheet for record keeping purposes. Valves must remain locked in the closed position except when draining standing water. The standing water must be examined and determined to be free of oil contamination before bermed or walled areas can be drained. If any oil sheen or accumulation of oil is observed, the standing water must be drained through an oil-water separator before being discharged to the storm sewer or waterway. 8. Provide warning signs and chock blocks to prevent the tank truck from making a premature departure (40 CFR 112.7 (h)(2)). 9. Inspect and test each aboveground tank or container for integrity on a regular basis (40 CFR • 4 112.8(c)(6). The time interval between inspections shall be based on good engineering practice and generally accepted industry standards such as American Petroleum Institute (API) 653. API 653 recommends draining, cleaning and internally inspecting tanks every 10 years unless a previous inspection indicates a longer time period between inspections is acceptable. Particularly for bulk tanks, visual inspection must be combined with another technique such as hydrostatic,radiographic, ultrasonic acoustic emissions, or another system of non-destructive shell thickness testing. 10. Maintain quick access to a source of oil booms to cross the nearby waterway and enough pillows, pads, and absorbent sheets to absorb a 100-gallon spill. Also ensure access to oil barrels, portable oil pumps and sandbags in the event of a petroleum discharge (40 CFR 112.7(a)(3) and (5)). I hereby acknowledge that I have reviewed Section 1.2 and understand that several facility improvements are required to fully implement this SPCC plan. Bryan Adams, General Manager Date 5 2.0 IMPLEMENTATION—40 CFR 112.7 The SPCC plan will meet the following objectives when fully implemented. 1 Improve the facility to minimize the chance of a discharge. 2. Provide adequate secondary containment to impound discharged material if the primary containment fails. 3. Train the appropriate oil-handling employees to follow proper procedures;both to minimize the chance of a spill and to take corrective action in the event a spill occurs. It is the responsibility of the Owner to keep the SPCC Plan current, on file available able up n request by authorized officials. The SPCC Plan must be reviewed every five years. be done by the Owner. If a change has been made to any of the oil storage systems the plan reviewed and certified by a Registered Professional Engineer. All recommended physical and operational changes within this plan must be put in place by February 18,2005 or within six months of the date of this plan. Any physical or operational change made after February 18,2005 must have the SPCC Plan update in place prior to startup. Associated Consultants Engineers(ACED,a member i of the Short Elliott Hendrickson Group(SEH),will keep the original Plan and any revisions on file. 1 The Owner must approve, sign and implement the SPCC Plan as soon as possible. The Owner is responsible for training the appropriate Utility employees in the procedures set forth in this Plan. "l 2.1 MANAGEMENT APPROVAL - 40 CFR 112.7 J This SPCC plan is fully approved by the management of Elk River Municipal Utilities and the necessary resources have been committed to implement the plan as described. 1 Date . , . . . . . l Bryan Adams, General Manager 1�i 6 ,ii i CERTIFICATION OF SUBSTANTIAL HARM DETERMINATION FORM Facility Name: Elk River Municipal Utilities Facility Address: 322 King Ave. Elk River, MN 55330 1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons? YES NO X 2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation within any aboveground storage tank area? YES NO X 3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance(as calculated using the appropriate formula in Attachment c-III to this appendix or a comparable formula[)such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? For further description of fish and wildlife and sensitive environments,see Appendices I,II,and III to DOC/NOAA's"Guidance for Facility and Vessel Response Plans: Fish and Wildlife and Sensitive Environments" (see Appendix E to this part, section 10, for availability)and the applicable Area Contingency Plan. YES NO X 4. Does the facility have a total oil storage capacity greater than or equal to I million gallons and is the facility located at a distance(as calculated using the appropriate formula in Attachment C-III to this appendix or a comparable formula')such that a discharge from the facility would shut down a public drinking water intake? YES NO X 5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a reportable oil spill in an amount greater than or equal to 10,000 gallons within the last 5 years? YES NO X CERTIFICATION [certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate, and complete. 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MUNICIPAL ELECTRIC UTILITY D PHONE: (952) A MEMBER OF THE SEH APP 1 x FAX 9 2)29112-2601 CROUP SC LE DATE (952) ELK RIVER, MINNESOTA WWW.SEHINC.COM 1/2"a1'-0" 1/8/03 i