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SPCC & ODC PLAN

6.0  SPILL RESPONSE



NOTIFICATION OF RELEASE


University Personnel

Level 1 Emergency

1. Notify Area Personnel - Notify personnel in the spill area (Boiler Plant, Dedmon Center, or Facilities Management). Spill will typically be handled by properly trained area personnel.

2. Contact Safety Director - Contact Safety Manager if assistance with proper response procedures is required.
Note: If spill situation worsens or additional assistance is required, follow notification procedures for level 2-3 emergencies.

Level 2-3 Emergencies

1.  Notify University Police Department - The person detecting the spill shall immediately notify the University Police Dispatcher at 831-5500.

2.  Notify Emergency Personnel - The University Police Dispatcher will notify the appropriate University personnel including:

3.  The Safety Director or alternate will be immediately notified of a spill exceeding 25 gallons or that enters or threaten to enter the storm drains or New River.


Regulatory Agencies

1. The Safety Director or alternate shall perform all required regulatory notifications. A list of regulatory agencies that must be notified in the event of a spill (including the agency phone number and the circumstances under which they should be notified) is provided below. When notification is required the respective agencies must be notified within 24 hours.

a)  Virginia Department of Environmental Quality, West Central Regional Office
(540) 562-6700
Any oil spill in excess of 25 gallons or that reaches a surface water body.

b) Virginia Department of Emergency Services
(800) 468-8892
Any oil spill in excess of 25 gallons or that reaches a surface water body.

c) EPA Region III
(215) 814-9016
Any oil spill that reaches a surface water body (navigable water).

d) National Response Center
(800) 424-8802
Any oil spill that reaches a surface water body (navigable water).

e) Radford LEPC
(540) 731-3617
Any oil spill in excess of 25 gallons or that reaches a surface water body.


2.  The information to be reported to regulatory agencies includes the following:


Local Police and Fire Department

Radford University has an agreement with the City of Radford Fire Department that the Fire Department will assist the University in spill response activities when needed. Under such circumstances the Chief of the Radford City Fire Department will serve as the senior response official directing the response effort. The Radford City Police Department may also be notified of significant spills that cannot be controlled by University Personnel. The City of Radford Fire and/or Police Department spills local police and fire department should be notified if any of the following criteria are met:

Norfolk Southern Railway Company

The Norfolk Southern Railway Company (NS), Virginia Division Chief Dispatcher (540-981-4739) shall be notified of any spills that reach the railroad right-of-way and/or when response actions carry over to the right-of-way. The Chief Dispatcher can then direct and control train traffic as needed to facilitate response actions.

Emergency Response Contractors

1.  Radford University has a standing agreement with a local spill response contractor that can be mobilized to the site when needed. This contractor is listed below:

Company Name: LCM Corporation
Business Phone: (540) 344-5583
24-Hour Phone: (800) 774-5583

2.  The Contractor is located in Roanoke, Virginia and can mobilize to the University in 60 minutes. A copy of the agreement of understanding between the University and the Contractor is available in the Safety Office along with a listing of emergency response equipment.



GENERAL SPILL RESPONSE PROCEDURES



A suggested procedure for response to a spill event is presented below. Personnel responding to a spill will assess the release prior to the start of any response action. Refer to the MSDS for proper material handling equipment, materials, and procedures. Aggressive actions such as attempting to stop the flow or cleanup procedures will be performed by properly trained individuals. Individuals at the university with proper training include Safety Office and Boiler Plant personnel.
The University maintains personal protective equipment (PPE) and spill response equipment at several locations on campus.  Those facility personnel trained for response actions have been trained in the use of PPE and spill response equipment.

1. Evacuation:  If the spill requires special equipment and containment is extremely hazardous, then all personnel are to evacuate the area and wait for outside assistance from the Radford City Fire Department and/or Emergency Response Contractor.

2. Stop the Flow:  Isolate source of the leak or spill if safe to do so. Shut off flow of oil by closing valves, shutting off pumps, isolating plugs, and/or other appropriate methods. Generally, valves to control flow are found at the base of above ground storage tanks, near a coupling point or at a transitional point.

3. Shut Off Ignition Sources:  All possible sources of ignition are to be shut off (motors, electrical equipment, electrical circuits, open flames, and any other possible sources of sparks or fire).

4. Notify/Warn Personnel:  If the spill is not readily contained or exceeds 25-gallons notification of University and outside personnel must be made as outlined in the above section and the Radford University Emergency Operations Plan.

5. Contain the Spill:  If it is safe to do so, contain spilled oil in the smallest possible area. There are several containment methods that may be quickly implemented during a release. Small spills may simply be contained with the use of absorbent material (granular material, pads, booms, etc). Larger spills may often require the construction of earthen or timber dams and/or berms to contain the flow.

6. Product Recovery and Disposal: Product recovery and disposal measures shall be undertaken once the spill source has been corrected and the flows contained. Removal and recovery of spilled oil should be initiated and proceed as rapidly as circumstances permit. The Safety Office will supervise the recovery and disposal of spilled materials. Disposal of spilled materials will be performed in compliance with local, state, and federal regulations. Product may be recovered by one of the suggested measures listed below:

a)  Product may be recovered from sumps, reservoirs or containment structures with the use of a pump or skimmer with discharge into an appropriate container.
b)  Product may be recovered from behind booms or from basins using a floating skimmer pump with discharge into an appropriate container.
c)  Small quantities of product may be recovered using absorbent materials, which are then placed into drums or similar containers.
d)  Oil scavenging/recycling contractors may be called in to recover large quantities of spilled materials.

7. Use Good Judgment: The response actions presented in the above paragraphs outline general methods that may be utilized to contain spilled material. Since spills can occur in an infinite number of situations and circumstances, it is impossible to provide specific instructions for every event. Therefore, response personnel must exercise their own good judgment and common sense when implementing spill containment measures to achieve the primary objective of safely confining the spilled material to minimize impact to human health, physical property and the environment.



SPECIFIC SPILL RESPONSE SCENARIOS


Spills Limited to Ground Surface

General

1.  Assess the nature of the release and determine a) if the spill has escaped the containment structure and b) if the spill volume escaping containment exceeds 25 gallons.

2.  Notify appropriate university personnel.

3.  Other university personnel, Radford City Fire Department, and/or emergency response contractors shall be notified and mobilized as necessary. The Safety Office will notify regulatory agencies. The Police Department will contact university personnel, emergency response agencies and the spill contractor if in-house personnel cannot handle the spill. The decision to call the spill contractor will be made in consultation with the Safety Manager and will be based on the amount of the spill and the potential threat to the environment.

4.  If you have the proper training, isolate the spill source by closing valves, shutting down pumps, installing temporary plugs, or using other appropriate methods.

5.  If spilled material is contained within a secondary containment structure, recover the material for reuse or disposal. If spilled material is not contained within a secondary containment structure and you have the proper training, use the following steps to contain and control the spill:

Boiler Plant

1.  Place absorbent booms, pads, sandbags, earthen berms, and/or excavated sumps/reservoirs at the down gradient end of the spill to prevent further migration.

2.  Protect grate inlets in driveway and building ramp by surrounding the inlets with absorbent booms, berms, etc.

3.  Prevent migration of oil into the storm drainage ditch to the north of the ASTs using booms, pads, earthen berms, etc.

4.  Clean up the spilled materials using spill pads, socks, pillows, or absorbents. Wear appropriate personal protective equipment such as gloves and eye protection.

5.  Once the spilled material is contained the material should be recovered for reuse or disposal as appropriate.


Dedmon Center

1.  Place absorbent booms, pads, sandbags, and/or earthen berms at the down gradient end of the spill to prevent further migration.

2.  Protect trench drain outlet at the service entrance by installing slide gate and protect curb inlet(s) in driveway with absorbent booms or berms.

3.  Prevent migration of oil into the storm drainage system that discharges to the New River.

4.  Clean up spilled materials using spill pads, socks, pillows, or absorbents. Wear appropriate personal protective equipment such as gloves and eye protection.

5.  Once the spilled material is contained the material should be recovered for reuse or disposal as appropriate.

Facilities Management

1.  Place absorbent booms, pads, sandbags, earthen berms etc. at the down gradient end of the spill to prevent further migration.

2. Protect curb inlets in the servicing areas by surrounding the inlets with absorbent booms, berms, etc.

3. Prevent migration of oil through the storm drainage system to the detention pond.

4.  Clean up the spill using spill pads, socks, pillows, or absorbents. Wear appropriate personal protective equipment such as gloves and eye protection.

5.  Once spilled material is contained, the material should be recovered for reuse or disposal as appropriate.

6. Notify Facilities Management once the spilled material has been contained and recovered so that the appropriate repairs can be made.


Oil Spills to Storm Drains, Drainage Ditches or Surface Water Bodies


General

1. Assess the nature of the release and confirm that spilled material has reached a storm drain, drainage ditch, or surface water body.

2.  Immediately notify the University Police so that notifications of outside agencies can be made. The Police Department will notify the Safety Office, appropriate university personnel, and emergency response agencies. The Safety Office will notify regulatory agencies.

3.  The Police Department will call the spill contractor if in-house personnel cannot handle the spill. The decision to call the spill contractor should be made in consultation with the Safety Director. The decision will be based on the amount of spilled material and the potential threat to the environment.

4.  If you have the proper training, isolate the spill source by closing valves, shutting down pumps, installing temporary plugs, or other appropriate method.

5. For spills reaching the storm drainage system the following steps shall be used by properly trained individuals (40-hour HAZWOPER) to contain and control the spill:


Boiler Plant


1. Any spilled material entering the grate inlets at the building driveway or ramp can be recovered at the drain outlet (east of tank containment dikes). This will be done by Boiler Plant or Safety Office personnel at the university or by the spill contractor.

2. If there is no flow of water at the time of the spill the material can be contained with absorbent booms or an excavated sump or berm.

3. If the spill occurs during a precipitation event the use of floating booms or the construction of an underflow dam may be required. Allow for the flow of storm water under the barrier. A series of barriers may be required to completely contain the spilled oil.

4. Any spilled material that enters the storm drainage ditch to the north of the ASTs can be recovered in a similar manner. Every effort should be made to contain the spilled material before it enters the storm sewer flowing under the Dedmon Center.


Dedmon Center


1. If there is no or low flow in the storm sewer, plug a downstream manhole outlet, if safe, using a plug or absorbent material. Safety office personnel or the spill contractor will seal the manhole. Appropriate personal protective equipment will be worn. The Safety Office must approve the use of respirators. Recover oil and water using pumps or skimmers.

2. If there is a high flow of storm water, place floating booms or baffles into a downstream manhole to contain oil while allowing the storm water to flow under the baffle/boom and out of the manhole. Such recovery efforts may be required at more than one manhole. The placement of booms or baffles will be performed by the Safety Office or the spill contractor.

3.  If oil reaches the storm drain outlet to the New River oil should be contained at the Outfall if possible using floating booms and baffles with skimmer pumps. Again a series of barriers may be necessary to contain the oil. Additional downstream containment measures may be necessary and should be directed as needed based upon river and oil flow conditions. The spill contractor and/or hazardous materials teams will perform spill containment procedures on the New River with assistance from the Safety Office.

Facilities Management Area

1. Safety Office personnel or the spill contractor will attempt to contain and recover oil at the storm water detention basin. If there is little or no flow into the basin, plug the outlet and recover spilled material. If there is high flow, then place floating booms or baffles in the basin to contain oil while allowing storm water to flow out of the structure.

2. If oil reaches the ditch flowing from the basin to the New River, the spill should be contained using underflow dams, floating booms, baffles, etc. prior to the outfall to the river. This will be done by Safety Office personnel or the spill contractor.

3. If oil reaches the river, it should be contained as close as possible to the outfall using floating booms and baffles with skimmer pumps. A series of barriers may be necessary to contain the oil. Additionally, downstream containment measures may be necessary and should be directed as needed based upon river and oil flow conditions. The spill contractor and/or hazardous materials teams will perform spill containment procedures on the New River with assistance from the Safety Office.

4. Once downstream flow of oil has been contained, continue controlling the source of the leak so that no additional oil enters the water body.

5. Recover oil from drainage ditches and the riverbank using absorbent materials or other appropriate means.

6. Once the spilled material has been contained and recovered Facilities Management shall be notified so that the appropriate repairs can be made.

 

INCIDENT TERMINATION


The emergency is terminated when the situation is manageable, and there is no longer a discharge or threatened discharge of any materials. Termination of the incident will be made by the Emergency Coordinator at the university in consultation with the Safety Director. The magnitude and duration of emergency response will depend on a variety of factors including the quantity of material released, the extent of the impact, and threat to property, human health, and the environment. Follow up cleanup measures may be required by federal, state, and/or local government agencies to address impacted soil, surface water, shorelines; and/or groundwater.


DISPOSAL


All wastes generated during response activities must be recovered and reused or otherwise disposed of in accordance with federal, state, and local regulations. The Safety Office will handle the recovery and disposal of hazardous materials. General guidelines for handling typical waste streams generated during response activities are listed below. DEQ can be consulted as necessary for additional guidance. There is no time restriction for on-site staging of non-hazardous petroleum wastes. However, these materials should be removed as soon as practical. Any hazardous wastes generated typically must be removed from the site within 180 days.

1. Recovered Oil and Impacted Water:  Recovered fuel oil and impacted water should be collected and placed into drums, tank trucks, or temporary storage tanks. A fuel recycler may manage recovered oil while impacted water should be characterized for off-site treatment/disposal.

2. Impacted Soil:  Soil or debris should be placed into drums, roll-off boxes or stockpiled on a bermed plastic liner and covered. Impacted soil should be stored on-site only until proper treatment/disposal requirements are identified and proper disposal arrangements can be made.

3. Impacted Equipment and Materials:  Impacted equipment and materials should be temporarily stored and disposed as described above or can be decontaminated (rinsed, steam-cleaned, washed, etc.) and reused or recycled. All cleaning should be done in a controlled area, and all liquids from the cleaning should be collected and disposed of properly. Any supplies that are depleted or destroyed as the result of the spill or subsequent response measures shall be replaced as soon as possible.


POST DISCHARGE REVIEW


Within two weeks of a spill incident, a formal review will be performed with the Safety Director, Police Director, and appropriate University staff. This post discharge review will be conducted to evaluate the cause of the spill, the success and/or failure of the response measures utilized and to identify possible actions to prevent recurrence. Information resulting from this review will be used to improve and/or update the Plan if needed. A Hazardous Materials Incident Report (Appendix B) will be completed at this time and will document the spill and countermeasures taken. The form will be maintained on file at the Safety Office and the appropriate facility for five years.

APPENDIX A-  POTENTIAL EQUIPMENT FAILURES

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