JIM BERRY & ASSOCIATES 4540 TIMBERLUX CIRCLE ANCHORAGE, ALASKA PHONE / FAX: (907)

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1 JIM BERRY & ASSOCIATES 4540 TIMBERLUX CIRCLE ANCHORAGE, ALASKA PHONE / FAX: (907) jberry@gci.net August 19, 2016 TO: U.S. Coast Guard Sector Anchorage U.S. Environmental Protection Agency Attn: Captain of the Port, Western Alaska Room 537, Federal Building PO Box W. 7th Avenue, Box #19 JBER, AK Anchorage, Alaska WesternAlaskaFacilities@uscg.mil Whittier.Robert@epa.gov RE: Yukon Koyukuk School District (YKSD) Kaltag School Oil Storage Amended Facility Response Plan Submittal On behalf of the Yukon Koyukuk School District, I submit the enclosed amended Facility Response Plan (FRP) for its Kaltag School. Kaltag is on the west bank of the Yukon River, 75 miles west of Galena and 335 miles west of Fairbanks. Geographic coordinates of Kaltag are 64 20' N, ' W. The community tank farm is on Eight Avenue at A Street. It is about 800 feet west of the Yukon River. The School is located about 2,000 feet southwest of the community tank farm. The amendments solely address the award of a new contract to Frontier Fuel Service (FFS) to provide spill response personnel and expertise at all schools. There have been no changes to fuel storage tanks or piping. All revised pages are listed on the Record of Revisions Page (page 1-8) of the FRP. FFS replaces the previous contractor. The new contract provides the same service as the previous contract. FFS services include on-site maintenance, required inspections and tests, training, and spill response including Qualified Individual responsibilities and authority. FFS is a Wasilla based corporation organized to contract for the operation and maintenance of rural Alaskan bulk fuel storage facilities. The existing FRP was approved by the Coast Guard by letter dated August 6, 2013 and by the EPA by letter dated June 11, The Coast Guard approved a request for equipment alternative of 250 feet of sorbent boom by letter August 7, The approvals are included in the enclosed FRP. The mailing address, telephone numbers, and contact persons for YKSD fuel storage compliance are: Yukon Koyukuk School District Contact Person: 4762 Old Airport Way Kerry Boyd, YKSD Superintend of Schools Fairbanks, Alaska Phones: District (Fairbanks) (907) , School (Kaltag) (907) Please acknowledge receipt of the amended FRP. It is our understanding this amendment will not affect the current FRP approvals unless further action is requested by the Coast Guard or EPA. Please forward all correspondence regarding the Kaltag School to the YKSD address listed above with a copy to me. Sincerely, Jim Berry cc: Yukon Koyukuk School District, Gale Bourne Frontier Fuel Service, David Campbell

2 YUKON KOYUKUK SCHOOL DISTRICT KALTAG SCHOOL OIL STORAGE KALTAG, ALASKA FACILITY RESPONSE PLAN PREPARED TO SATISFY: U.S. COAST GUARD & U.S. EPA RESPONSE PLAN REQUIREMENTS (1) FWPCA Section 311(j) - (OPA 90) (2) 33 CFR, Part (3) 40 CFR, Part AMENDED AUGUST 2016

3 Captain of the Port United States Coast Guard Western Alaska 510 L Street, Suite 100 Anchorage, AK Staff Symbol: spi Phone: (907) FAX: (907) WesternAlaskaFacilities@uscg.mil 16611/ANC-K-102 August 6, 2013 Yukon Koyukuk School District Kaltag School Attn: Kerry Boyd 4762 Old Airport Way Fairbanks, AK Subj: FACILITY RESPONSE PLAN (FRP) Ref: (a) YKSD Kaltag FRP received June 25, Dear Mr. Boyd: Reference (a) is Approved as a substantial harm facility. Your FRP will expire July 24, An annual review of the FRP shall be conducted in accordance with Title 33 Code of Federal Regulations Part , and any revisions shall be submitted to the Captain of the Port within thirty days of the change. If no revisions are required, the facility owner or operator shall indicate the completion of the annual review on the record of changes page. This letter must be kept in the front of your FRP for review by Coast Guard personnel during inspections. Any future correspondence should include your facility s unique identification number (ANC-K-102). Questions or comments concerning your FRP shall be directed to the Facilities Branch at Sector Anchorage: (907) Submit any revisions to the above address. Sincerely, D. G. BUCHSBAUM Lieutenant Commander, U. S. Coast Guard Chief, Inspections Division By direction CC: Jim Berry, Jim Berry & Associates Facility File

4 Captain of the Port United States Coast Guard Western Alaska 510 L Street, Suite 100 Anchorage, AK Staff Symbol: sp Phone: (907) FAX: (907) WesternAlaskaFacilities@uscg.mil 16611/ANC-K-102 August 7, 2013 Yukon Koyukuk School District (YKSD) Kaltag School Attn: Kerry Boyd 4162 Old Airport Way Fairbanks, AK Dear Mr. Boyd: I have reviewed your request dated June 25, 2013 to substitute 250 feet of sorbent boom as an alternative for the 200 feet of containment boom required by Title 33 Code of Federal Regulations (CFR) Part (d) at the YKSD Kaltag fuel storage facility. In accordance with 33 CFR (a)(1), I am granting your request with the understanding that purchasing, maintaining, and deploying containment boom is economically and physically impractical for your geographic remote facility and the employment of sorbent boom offers a more effective means of responding to a spill at your facility. Please keep a copy of this letter with your facility records. Please direct any questions or comments concerning this alternative to the Sector Anchorage Facilities Branch at (907) Sincerely, S. L. JOHNSON Commander, U. S. Coast Guard Chief, Prevention Department By Direction Copy: Facility File Jim Berry, Jim Berry & Associates

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8 1.1 FACILITY CONTACTS & EMERGENCY RESPONDERS Facility Name: Street Address: Borough: Mailing Address: Kaltag School N/A The community tank farm is on Eight Avenue at A Street. It is about 800 feet west of the Yukon River. The School is located about 2,000 feet southwest of the community tank farm. None Yukon Koyukuk School District 4762 Old Airport Way Fairbanks, Alaska DISTRICT (FAIRBANKS.) SCHOOL (KALTAG) Phone: (907) (907) Fax: (907) (907) YKSD Superintendent of Schools: (907) Facility Qualified Individuals: (refer to Section 2.3.2) PRIMARY ALTERNATE Name: Kaltag School Principal David Campbell Title: Principal / Head Teacher Frontier Fuel Service (FSS) Phone: office (907) (907) School Incident Command System Personnel: (refer to Section 2.3.3) INCIDENT COMMANDER phone* Kaltag School Site Principal*...(907) David Campbell, Frontier Fuel Service...(907) *Initial Incident Commander until relieved on site by Frontier Fuel Service I.C. OPERATIONS SECTION CHIEF Frontier Fuel Service personnel...(907) LOGISTICS SECTION CHIEF Frontier Fuel Service personnel...(907) Kaltag School personel...(907) YKSD Fairbanks personnel...(907) ADMINISTRATION SECTION CHIEF Frontier Fuel Service personnel... (907) YKSD Fairbanks personnel... (907) PUBLIC INFORMATION OFFICER Kerry Boyd, YKSD Fairbanks... (907) SAFETY OFFICER David Campbell, Frontier Fuel Service... (907) GOVERNMENT LIAISON Kerry Boyd, YKSD Fairbanks... (907) School Spill Response Team: (refer to Section 2.3.1) Kaltag School Site Principal / Head Teacher... (907) Kaltag School Site Maintenance Person... (907) Frontier Fuel Service personnel... (907) YKSD Fairbanks personnel... (907) /16

9 1.2 FACILITY OWNERSHIP, OPERATION, MAINTENANCE The School owner is the State of Alaska, Dept. of Education located at in Juneau, Alaska. The School operator is the Yukon Koyukuk School District located in Fairbanks, Alaska. YKSD is responsible for the operation of the fuel system at the Kaltag School. The School fuel system consists of storage tanks #11, 12, 13, 14 in the community tank farm, the fuel transfer pipeline to the School, and intermediate tank #IT-1 at the School. Appendix 1 of this FRP describes and identifies the location of the fuel system components. In addition, YKSD is responsible to ensure the its tank farm impound and security measures are maintained and operated in accordance with EPA requirements described in School s Spill Prevention Control and Countermeasure Plan (SPCC), and the marine pipeline is maintained in accordance with Coast Guard requirements described in the School s Marine Transfer Operations Manual. YKSD has contracted Frontier Fuel Service, LLC (FFS) to provide spill prevention, response, and compliance assistance at all its schools. FFS services include on-site maintenance, required inspections and tests, training, and spill response including Qualified Individual responsibilities and authority. LLC is a Wasilla based corporation organized to contract for the operation and maintenance of rural Alaskan bulk fuel storage facilities. 1.3 FACILITY LOCATION / STORAGE INFORMATION Kaltag is on the west bank of the Yukon River, 75 miles west of Galena and 335 miles west of Fairbanks. The tank farm is at Eighth Avenue and A Street. Geographic coordinates of Kaltag are 64 20' N, ' W. The School is located about 2,000 feet southwest of the community tank farm. Date of Oil Storage Start-up: 1999 (current tank farm) Total Number of School Tanks: 4 storage tanks, 1 intermediate tank Storage Capacity / Products: Total capacity 40,100 gallons; all diesel fuel. Largest Single Tank: 9,800 gallons Distance from Navigable Water: < ¼ mile NAICS Code: EPA and Coast Guard Discharge Planning Volumes are listed in Section Applicability of EPA Substantial Harm Criteria* 1. Does the facility transfer oil over water to or from vessels and does the facility have a total storage capacity greater than or equal to 42,000 gallons? Yes No * 2. Does the facility have total oil storage capacity greater than or equal to 1 million gallons and, within any storage area, does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard? Yes No 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 such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments, or shutdown a public drinking water intake? Yes No 4. 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 * The YKSD storage tanks are within the community tank farm which has storage capacity greater than 42,000 gallons, therefore it is considered an EPA Substantial Harm Facility /16

10 1.4 TABLE OF CONTENTS Section Page 1.0 INTRODUCTION AND PLAN CONTENT 1.1 FACILITY CONTACTS & EMERGENCY RESPONDERS FACILITY OWNERSHIP / OPERATION / MAINTENANCE FACILITY LOCATION / STORAGE INFORMATION TABLE OF CONTENTS COAST GUARD AND EPA CROSS REFERENCE TABLES RECORD OF REVISIONS LIST OF ACRONYMS EMERGENCY RESPONSE ACTION PLAN 2.1 NOTIFICATION Agency Reporting Emergency Phone Numbers Spill Documentation Requests for Information Role of Government Agencies SPILL MITIGATION PROCEDURES Discharge Planning Volumes Spill Response Procedures Initial Actions - All Spills Emergency Response Checklist Spill Mitigation Procedures Leak, Discharge from Transfer Pipeline to Intermediate Tank Storage Tank Overflow During Marine Delivery Spill at Marine Header or Pipeline During Delivery Tank Failure Facility Response Equipment EPA and CG Response Resource Worksheet FACILITY RESPONSE ACTIVITIES Response Organization / Personnel Responsibility Qualified Individuals Incident Command System Response Contractor Information SENSITIVE AREAS Sensitive Areas and Protection Measures Area Contingency Plan Vulnerability Analysis DISPOSAL PLAN Disposal Options / Requirements HAZARD EVALUATION 3.1 SPILL HISTORY POTENTIAL SPILLS EMERGENCY SHUTDOWN SYSTEMS FIRE SUPPRESSIONS EQUIPMENT EVACUATION PLAN PERSONNEL SAFETY TRAINING AND DRILLS 4.1 OPERATOR TRAINING SPILL RESPONSE TRAINING SPILL DRILLS, EXERCISES COAST GUARD PERSON-IN-CHARGE TRAINING PREP TRAINING FACT SHEETS Appendix APPENDIX 1. FACILITY SPECIFIC INFORMATION 1.1 Facility Description... A Facility Plot Plan... A Valve Identification... A Product Information... A /13

11 APPENDIX continued Appendix 2. LIST OF CONTACTS 2.1 Key Personnel... A Federal, State, Local Officials... A Response Contractors Agreement... A EQUIPMENT LIST AND RECORDS 3.1 Facility Response Equipment... A COMMUNICATIONS PLAN 4.1 Communications Plan / Equipment... A SITE-SPECIFIC SAFETY AND HEALTH PLAN 5.1 Site Safety Plan... A Material Data Safety Sheets... A DOCUMENTATION FORMS 6.1 Spill Report / Notification Form... A Facility Inspections... A Training... A SIMPLIFIED CLEANUP TECHNIQUES... A7-1 Figure LIST OF FIGURES AGENCY REPORTING REQUIREMENTS FACILITY DRAINAGE PATTERNS / POTENTIAL SPILL CONTAINMENT POINTS FACILITY RESPONSE ORGANIZATION INCIDENT COMMAND SYSTEM SENSITIVE AREA PLANNING DISTANCES A1-1. LOCATION MAP... A1-4 A1-2. AREA PLAN... A1-5 A1-3. PIPING PLAN... A /13

12 1.5 COAST GUARD AND EPA CROSS REFERENCES U.S. COAST GUARD FACILITY RESPONSE PLAN REQUIREMENTS 33 CFR PART Section Description Section or page in this Response Plan (a) Introduction / content (a) (1) Facility Information pages 1-1, 1-2, 1-3 (a) (2) Facility Location page 1-3 (a) (3) Contact Names / Address page 1-2 (a) (4) Table of Contents page 1-4 (a) (5) Cross Reference pages 1-6 (a) (6) Record of Changes page 1-8 (b) Emergency Response Plan Section 2.0 (b) (1) (i)(ii) Notification Procedures Sec. 2.1 (b) (2) Spill Mitigation Procedures page Sec (b) (2) (i) Projected Spill Volumes (AMP, MMP, WCD) page (b) (2) (ii) (A-G) Emergency Response Action Sec. 2.2 (b) (2) (iii) List of Equipment & Personnel Responsibilities Sec 2.2.3, Appendix 3 Sec 2.3 (b) (3) Facility's Response Activities Sec. 2.2 / 2.3 (b) (3) (i) Initial action prior to arrival of Q.I. page (b) (3) (ii) Q.I. Responsibility / Authority page (b) (3) (iii)(a-h) Response Organization-ICS Sec. 2.3 (b) (3) (iv)(a-b) Spill Removal Organization Sec , 2.2.3, (b) (3) (v) ICS Job Descriptions (b) (3) (vi)(vii) Dispersant Use / Aerial Tracking n/a (b) (3) (viii)(ix) Mobile Facilities n/a (b) (4) (i) Sensitive Areas consistent w ACP Sec. 2.4 (b) (4) (ii) Identify & Map of Sensitive Areas - Depiction of response actions to protect Figs , Secs. 2.2, 2.4 these areas (b) (4) (iii) Equipment & Personnel to Protect Sensitive Secs. 2.2, 2.3, 2.4, Appendix 3 Areas in WCD (b) (4) (iii)(b)(1)(iii) Calculate Planning Distance. Identify protection areas in planning distance (b) (5) Disposal Plan Sec. 2.5 (c) (1)&(2) Training and Drills Sec. 4.0 (d) Plan Review & Update page 1-8 Secs. 2.4 Figs 2-2-1, (e) Appendices (e) (1) (i) Facility Description Appendix 1 (e) (1) (ii) Type/Number of Vessels Appendix 1.4 (e) (1) (iii) Valve Identification (MTR) Appendix 1.3, Figs. A1-2, A1-3 (e) (1) (iv) Product Information Appendix 1.4 (e) (2) (i)(ii)(iii) List of Contacts including QI's, OSRO's, Appendix 2 officials, agencies (e) (3) (i) Equipment & Personnel to Respond to Secs , , 2.3 Average Most Probable Discharge (e) (3) (ii) (iii) List of major equipment including type, Sec (A)(C) model, dimension, etc. (e) (3) (iii)(b) Equipment - effective daily recovery rates pages , 12 (e) (3) (iii)(d) Spill Scenario w equipment used Secs (e) (3) (iii)(e) Daily capacity storage /disposal capacity pages & , Sec (e) (3) (iii)(f) Communications equipment & frequencies Appendix 4 (e) (3) (iii)(g) Location of Equipment Sec , Fig. A1-2 (e) (4) Communication Plan Appendix 4 (e) (5) Site Safety Plan Appendix 5 (e) (6) List of Acronyms and Definitions Sec /13

13 40 CFR PART SECTION (h) (1) U.S. EPA FACILITY RESPONSE PLAN REQUIREMENTS Description Section in Facility Response Plan Emergency Response Action Plan Section 2.0 (h) (1) (i) Emergency Contacts / Phones 2.1 (h) (1) (ii) Facility Owner Contact Information 1.1 / 1.2 (h) (1) (iii) Reporting / Notification 2.1 (h) (1) (iv) Response Equipment 2.2.3, Appendix 3 (h) (1) (v) Response Personnel 2.3 (h) (1 (vi) Evacuation Plan 3.5, Fig (h) (1) (vii) Containment Measures 2.2.2, Appendix 7 (h) (1) (viii) Facility Diagram Appendix 1, Figs. A1-3 (h) (2) Facility Information (h) (3) Information about Emergency Response 2.0 (h) (3) (i) Response Resources 2.2.3, 2.3, Appendix 3 (h) (3) (ii) Response Contracts (h) (3) (iii) Emergency Phones (h) (3) (iv) Initial Actions (h) (3) (v) Response Capability / Duties (h) (3) (vi) Response Equipment 2.2, 2.2.3, Appendix 3 (h) (3) (vii) Evacuation Plans 3.5 (h) (3) (viii) Diagram of Evacuation Routes Fig (h) (3) (ix) Duties of Response Coordinator (h) (4) Hazard Evaluation 3.0 (h) (5) Tiered Planning Scenarios 2.2 (h) (5) (i) Worst Case (h) (5) (ii) Small Discharge (h) (5) (iii) Medium Discharge (h) (6) Detection Systems Appendix 1 (h) (7) Plan Implementation 2.0 (h) (7) (i) Spill Mitigation Actions 2.2 (h) (7) (ii) Scenario Equipment 2.2, 2.2.3, Appendix 3 (h) (7) (iii) Disposal Plans 2.5 (h) (7) (iv) Containment Measures Appendix 7 (h) (8) Self-Inspection, Training and Meeting Logs Appendix 6 (h) (8) (i) Inspection Records Appendix 6 (h) (8) (ii) Training / Drills 4.0 (h) (8) (iii) Prevention Meetings 4.0 (h) (9) Diagrams Appendix 1 (h) (10) Security Appendix /13

14 1.6 RECORD OF REVISIONS PAGE / SECTION NUMBER(S) REASON FOR REVISION DATE OF REVISION Title page, page 1-2 (Facility Contacts), 1-8 (Record of Revisions), contractor references on pages 1-3, 2-1-2, 2-2-2, 2-2-4, 2-2-5, 2-2-6, , 2-3-1, , 2-3-5, 4-1, 4-2, A6-1 YKSD issued new contract to Frontier Fuel Service (FFS) to provide spill response personnel and expertise at all schools. FFS replaces the previous contractor. The new contract provides the same service as the previous contract. FFS services include on-site maintenance, required inspections and tests, training, and spill response including Qualified Individual responsibilities and authority. Revisions refect new contractor name and phone number. 08/16 EPA Facility Response Plan regulations (40 CFR, Part ) require plans to be reviewed periodically and revised and resubmitted if there is a "facility change that materially may affect the potential for a discharge...". Coast Guard Facility Response Plan regulations (33 CFR, Part ) require annual review. The review is to occur within one month of the anniversary date of the Coast Guard approval of the plan. Further, the Coast Guard regulations state that revisions or amendments are to be submitted by plan holders within 30 days whenever there is: a significant change in the facility configuration that affects information in the plan, a change in the type of oil handled that affects the required response resources, a change in name or capability of the designated spill removal organization, a change in emergency response procedures, and any other changes that significantly affect implementation of the plan, Changes to personnel and telephone number lists do not require approval. If no revisions are required, the completion of the annual review shall still be indicated on the record of revisions page. Facility Response Plans must be reapproved by the EPA and Coast Guard every five years /16

15 1.7 LIST OF ACRONYMS Acronyms pertaining to spill planning and response, which may or may not be used in this plan, include: ACP Area Contingency Plan ADEC Alaska Department of Environmental Conservation API American Petroleum Institute AST Aboveground Storage Tank BBLS Barrels CFR Code of Federal Regulations CHEMTREC National Chemical Transportation Emergency Center CHRIS Chemical Hazards Response Information System COE Corps of Engineers (U.S. Army) COTP Captain of the Port (USCG) CWA Clean Water Act EPA U.S. Environmental Protection Agency EPCRA Emergency Planning and Community Right-to-Know Act FOSC Federal On-Scene Coordinator FR Federal Register FRP Facility Response Plan HAZMAT Hazardous Material ICS Incident Command System LEL Lower Explosive Limit LEPC Local Emergency Planning Committee MSDS Material Safety Data Sheet MSO Marine Safety Office MTR Marine Transportation-Related (facility) NCP National Oil and Hazardous Substances Pollution Contingency Plan NRC National Response Center (USCG) NSF USCG National Strike Force OPA 90 Oil Pollution Act of 1990 (Public Law of 18 Aug 90) OSC On-Scene Coordinator OSHA Occupational Safety and Health Administration OSRO Oil Spill Removal Organization (classified by NSFCC) PIC Person in Charge POL Petroleum-Oil-Lubricant PPE Personal Protective Equipment PREP Preparedness-for-Response Exercise Program (USCG) QI Qualified Individual RA Regional Administrator (EPA) RQ Reportable Quantity (of hazardous substances) SERC State Emergency Response Commission SOSC State On-Scene Coordinator SPCC Spill Prevention, Control and Countermeasures (plan) TLV Threshold Limit Valve TWA Time Weighted Average UEL Upper Explosive Limit UL Underwriters Laboratory USCG U.S. Coast Guard USFWS U.S. Fish and Wildlife Service UST Underground Storage Tank WCD Worst Case Discharge /13

16 2.0 EMERGENCY RESPONSE ACTION PLAN 2.1 NOTIFICATION Agency Reporting The School Responsible Person (Site Principal / Head Teacher) responsible for reporting all oil spills that result from School operations to the YKSD Superintendent of Schools in Fairbanks. The Superintendent of Schools is to responsible to ensure all YKSD spills are reported to the required agencies accordance witih regulatory requirements listed below. The Superintendent of Schools phone number is listed on the following page. Direct verbal contact must be made with the agencies. All oil spills to water, and any sudden or cumulative discharge of oil in excess of 55 gallons solely to land is to be reported "as soon as the person (in charge of the facility) has knowledge" of the incident. Spills solely to land in excess of 10 gallons, but 55 gallons or less, are to be reported within 48 hours. Spills in excess of 55 gallons to an "impermeable secondary containment area" are to be reported within 48 hours. The Coast Guard (National Response Center) must also be notified if spilled oil (any sheen) enters, or threatens navigable waters. Notification to the National Response Center satisfies EPA notification requirements. Information to be reported includes (to the extent known): 1. Date/time of discharge 5. Type / amount of discharge 2. Location of discharge 6. Cause of discharge 3. Name of facility 7. Environment damage 4. Name, address, phone of: 8. Cleanup actions taken owner/operator of facility 9. Volume recovered persons causing the discharge 10. Disposal plans NEVER SPECULATE OR GUESS WHEN REPORTING OR DISCUSSING SPILLS. IF SPECIFICS ARE UNKNOWN - STATE SO! REPORT ALL SPILLS TO: ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION PHONE: or NORTHERN AREA RESPONSE TEAM AFTER HOURS PHONE: REPORT MARINE SPILLS TO: U.S. COAST GUARD NATIONAL RESPONSE CTR. (NRC) MARINE SPILLS INCLUDE ANY DISCHARGE (SHEEN) TO ANY WATER, INCLUDING PONDS, SLOUGHS, WETLANDS, MARSHES AND DRAINAGE THERETO - FAILURE TO REPORT MARINE SPILLS TO THE NRC MAY RESULT IN CRIMINAL PENALTIES. WHEN IN DOUBT-REPORT IT! Figure (page 2-1-4) lists agency reporting and documentation requirements. An acceptable spill reporting form is in Appendix /13

17 2.1.2 Emergency Phone Numbers School Phones: DISTRICT (FAIRBANKS.) SCHOOL (KALTAG) Phone: (907) (907) Fax: (907) (907) YKSD Superintendent of Schools: (907) Facility Qualified Individuals: (refer to Section 2.3.2) PRIMARY ALTERNATE Name: Kaltag School Principal David Cambell Title: Principal / Head Teacher Frontier Fuel Service (FSS) Phone: office (907) (907) Alaska Department of Environmental Conservation Northern Area Response Team (Spill Reporting) after hours call....(800) U.S. Coast Guard National Response Center (Spill Reporting)... (800) NRC toll number... (202) Sector Anchorage Office U.S. Environmental Protection Agency Anchorage Local City Water System (City) Volunteer Fire Dept VPSO Council Kaltag Cooperative AVEC Health Clinic Other ADEC Response Equipment (Bethel, Mt. Village, Aniak) / State Troopers (Galena) State Fire Marshall Alaska Div. of Emergency Services Alaska Dept. Fish & Game - Fairbanks U.S. Fish & Wildlife Service -Anchorage State/DNR - Office of History & Archaeology Local Emergency Planning Committee (City) State Emergency Response Comm. / SERC Weather Report Number AK. Rural Comms. System (T.V. alert broadcast contact) AK. Public Radio Network (Radio alert broadcast contact) Alaska area code /16

18 2.1.3 Spill Documentation A written spill report shall be completed for each spill - regardless of magnitude. The spill report is to be maintained for the "life of the facility". A copy of the report is to be submitted to the EPA Regional Administrator if an oil spill occurs of more than 1,000 gallons in a single discharge or more than 42 gallons of oil in each of two discharges occurring within any 12 month period: the discharges being into or upon navigable waters or adjoining shorelines. The Coast Guard and ADEC may also request a copy of the report. The written spill report shall contain, as applicable: 1. Name of facility; 2. Your name; 3. Location of the facility; 4. Maximum storage or handling capacity of the facility and normal daily throughput; 5. Corrective action and countermeasures you have taken, including a description of equipment repairs and replacements; 6. An adequate description of the facility, including maps, flow diagrams, and topographical maps, as necessary; 7. The cause of the discharge, including a failure analysis of the system or subsystem in which the failure occurred; 8. Additional preventive measures you have taken or contemplated to minimize the possibility of recurrence; and 9. Such other information as the EPA Regional Administrator may reasonably require pertinent to the Plan or discharge. An acceptable spill reporting form is in Appendix Requests for Information Facility / School operators, employees, and contractors are not to give any information about a spill to anyone other than the designated on-scene representatives of ADEC, the U.S. Coast Guard, or the U.S. Environmental Protection Agency (EPA). No statements shall be made regarding the following subjects except by the Qualified Individual or Alternate Qualified Individual Liability for spill. Estimates of damage expressed in dollars. Estimates of duration of cleanup. Estimates of cleanup costs. Comments regarding effectiveness of cleanup. Comments regarding appropriateness or effectiveness of public or private involvement Role of Government Agencies The primary government agencies concerned with oil spills are the State of Alaska Department of Environmental Conservation (ADEC), the Federal Environmental Protection Agency (EPA), and the U.S. Coast Guard (USCG). ADEC's responsibility is to monitor and determine "adequacy" of cleanup of spills that impact state lands or water. The EPA has jurisdiction over all inland waters and adjoining shorelines. The Coast Guard is responsible for all navigable water (and tributaries) and adjoining estuaries and shorelines. If a spill response and cleanup effort is not adequate, effective or capable, the Coast Guard, EPA or ADEC will initiate its own cleanup efforts - and recover all costs, and then some, from the responsible parties /13

19 OIL SPILL VERBAL WRITTEN AGENCY SIZE/LOCATION REPORT PHONE REPORT ALASKA DEPT. OF WATER ENVIRONMENTAL ALL SPILLS Immediately ADEC Fairbanks 15 Days CONSERVATION (907) or (ADEC-Fbx.) (800) LAND >55 gal. Immediately Same 15 Days gal. 48 Hours (ADEC-Fbx.) >55 gal. to impervious 48 Hours secondary containment 10 gal. or less None Maintain record & submit to ADEC monthly U.S. COAST GUARD Threat to or entered Immediately National Response Ctr. If Requested coastal or navigable (800) waters. Sheen on water or sludge or emulsion below surface U.S. EPA 1,000 gal. or 2 Report to Coast Guard / Anchorage Office Within 60 days sheens on navigable NRC (above) meets (907) of occurrence. water within 12 requirement Follow 40 CFR, month period from Part 112, facility required to Paragraph have SPCC Plan FIGURE AGENCY REPORTING REQUIREMENTS /13

20 2.2 SPILL MITIGATION PROCEDURES Discharge Planning Volumes The School stores only non-persistent diesel fuel. Appendix 1 of this FRP contains a facility description and tank information. Coast Guard and EPA required discharge planning volumes are as follows: Coast Guard (33 CFR, Part ) Average Most Probable Discharge 19 gals. (lesser of 50 bbls. or 1% of worst case) Maximum Most Probable Discharge 189 gals. (lesser of 1,200 bbls. or 10% of worst case) Worst Case Discharge 1,884 gals. (the worst case discharge volume is the capacity of all piping that can carry oil between the marine transfer manifold (fill point connection) and the non-transportation portion of the facility (first valve in tank farm), plus the potential discharge volume prior to shutdown during maximum transfer.) = volume of 1 ea. 1,000 foot long, 3-inch diameter pipeline = 384 gals. plus 5 minutes to detect and 300 gpm = 1,500 gals. Total = 1,884 gallons EPA (40 CFR, Part (h)(5)) Small Scenario 98 gals. (2,100 gallons or less) Medium Scenario 980 gals. (2,100-36,000 gals. or 10% of largest tank) Large Scenario 9,800 gals. (volume of largest single tank plus capacity of all other tanks without secondary containment) = 9,800 gallons The USCG Average Most Probable Discharge and EPA Small Scenario volume discharge could result for leak or discharge from the transfer pipeline to the School intermediate tank. The USCG Maximum Most Probable Discharge and EPA Medium Scenario volume discharge could result from storage tank overflow during marine delivery. The USCG Worst Case Discharge could result from equipment / pipeline failure or operator error during marine delivery. The EPA Worst Case Discharge could result from storage tank failure due to mechanical failure, vandalism, or a catastrophic natural event. Mitigation actions and response scenarios for the above discharge planning volumes are presented on the following pages /13

21 2.2.2 Spill Response Procedures The following section outlines initial response actions to potential discharges. The actions described are not specifically prescribed procedures, as every spill response will be dependent upon sitespecific variables, and the judgment of the Person(s)-in-Charge (marine transfer), the Qualified Individual(s), and/or the Incident Commander. Spill scenarios and mitigation actions are presented in Section Evacuation plans are in Section 3.5. Figure illustrates evacuation routes. Figure illustrates drainage patterns and potential spill containment sites. Section 2.4 identifies sensitive areas and protection measures. Appendix 7 illustrates spill cleanup techniques. INITIAL ACTIONS - ALL SPILLS SPILL CONTAINMENT AND CLEANUP ACTIVITY WILL NEVER TAKE PRECEDENCE OVER THE SAFETY OF PERSONNEL. DO NOT BEGIN ANY ACTIVITY UNTIL CONDITIONS ARE SAFE FOR WORKERS. 1. Close valves that allow product to flow to the segment of the system causing the spill. Remove sources of ignition. Account for personnel and ensure their safety. 2. Restrict access. If a fire or explosion hazard exists - clear the area. If necessary, alert volunteer fire department and position available firefighting equipment. 3. Attempt to contain a diesel fuel spill - disperse a gasoline spill due to fire, explosion hazard. Prevent or divert spilled oil from approaching structures or draining to any water. Spill response equipment including sorbent material, handtools, a pump and hose, storage containers and support equipment is stored in the School mechanical room. If necessary for terrestrial containment, earthmoving equipment can be mobilized from the City. Additional resources are available from the other tank farm operators and AVEC. Section lists response equipment. 4. The Qualified Individual and/or on-site Incident Commander will conduct a safety assessment and direct cleanup operations. Section describes the School s response organization. 5. The School Site Principal / Head Teacher will notify the YKSD Superintendent of Schools. The Superintendent will ensure all spills are reported to the Alaska Department of Environmental Conservation. If the discharge enters or threatens water, the U.S. Coast Guard (National Response Center) will also be notified. Section 2.1 describes spill reporting requirements. EMERGENCY RESPONSE CHECKLIST Safety PEOPLE IN IMMEDIATE AREA ALERTED - GENERAL ALARM INITIATED VALVES CLOSED - IGNITION SOURCES REMOVED / ISOLATED ALL PERSONNEL SAFE AND ACCOUNTED FOR - SITE SECURITY ESTABLISHED YKSD SUPERINTENDENT AND QUALIFIED INDIVIDUAL NOTIFIED SITE ASSESSMENT CONDUCTED - AREA DEEMED SAFE FOR CLEANUP Response FLOW STOPPED - LEAKS PATCHED / PLUGGED RESPONSE TEAM BRIEFED ON CLEANUP PLANS / PERSONNEL SAFETY DRAINAGE PATHS BLOCKED - CONTAINMENT SITES ESTABLISHED AGENCIES NOTIFIED ON-SITE EQUIPMENT ADEQUATE, OR ADDITIONAL RESOURCES ACTIVATED YKSD RESPONSE CONTRACTOR (Frontier Fuel Service/FFS) ACTIVATED, IF NECESSRY SPILL TRAJECTORY PROJECTED DISPOSAL / RECYCLING PLANS ESTABLISHED DOCUMENTATION METHODS / LOGS IN PLACE Post Response INCIDENT INVESTIGATION INITIATED WRITTEN SPILL REPORT FILED WITH AGENCIES EXPENDED CLEANUP MATERIALS REPLACED CORRECTIVE ACTIONS / IMPROVEMENTS IMPLEMENTED /16

22 Leak / Discharge from Transfer Pipe to School Intermediate Tank (EPA Small Scenario / USCG Average Most Probable Discharge) Procedures are applicable to piping rupture, piping leak both under pressure and not under pressure - 33 CFR Part (b)(2)(ii)(d)&(e). The transfer pipe from the tank farm to the School intermediate tank is welded two inch diameter steel about 2,500 feet in length. The pipe parallels the washeteria pipeline. It is above ground and removed from vehicle driving areas except where it passes under roadways where is protected within an ABS culvert. Fuel is transferred to the intermediate tank by manually starting the transfer pump using controls mounted on the intermediate tank. Valves on tank farm storage tanks and the transfer pipeline isolation valves at the entry/exit to the tank farm are to be closed and locked when transfers are not being conducted. Fuel transfer rate is about 40 gpm. A discharge would be detected by visual observation. 1. Alert the School Site Principal / Head Teacher. The School Site Principal / Head Teacher will notify YKSD Superintendent of Schools. The Superintendent will mobilize necessary off-site resources of YKSD response contractor and/or the District Maintenance Department. 2. Conduct a site safety assessment. Set up safety perimeter as necessary. Use caution tape to restrict access to spill zone. 3. Ensure ADEC is notified of the incident. If the discharge enters or threatens water, also contact the U.S. Coast Guard (National Response Center). 4. Use handtools and materials from School spill kit to contain spilled fuel. Dig trenches and build berms to restrict spill migration. Prevent spilled fuel from migrating toward any open water or drainage channels. Contact the City for use of heavy equipment, if necessary. 5. Remove spilled fuel using the School s portable pump and/or sorbent material. Store recovered fuel and contaminated materials in 55 gallon drums. Ensure drums are stored in an area with adequate secondary containment: on containment pallets or in a diked and lined impound. 6. Conduct damage assessment and establish plans to: 1) remove transfer pipe from service until repaired, 2) temporary use a mobile tank to fill the intermediate tank, 3) repair transfer pipe, and 4) assess for spill zone for contamination as a result of the spill. 7. Arrange for proper disposal or recycling of all recovered fuel/oil, oily sorbents and other oiled debris (Section 2.5) Storage Tank Overflow (USCG Maximum Most Probable Discharge / EPA Medium Scenario) Procedures applicable to tank overfill and/or equipment failure - 33 CFR Part (b)(2)(ii)(b)&(g) The tank farm impound is diked and lined and has net secondary containment volume of approximately 65,000 gallons. Storage tanks are equipped with liquid level gauges. Marine delivery is conducted in accordance with the procedures listed in the School s Marine Transfer Operations Manual. Prior to delivery a Declaration of Inspection is completed and transfer procedures are reviewed with all personnel. During the transfer watchpersons monitor the storage tanks, exposed piping, and header. The watchpersons maintain radio contact with the barge. Marine delivery rate is approximately 300 gpm. It is estimated that equipment failure combined and/or operator error could result in an overflow discharge of up to 1,500 gallons. 1. Immediately alert the barge crew to terminate fuel delivery. 2. Close all valves that allow product flow to the segment of the system causing the spill /16

23 3. Remove all sources of possible ignition. If a fire or explosion hazard exists, clear the area, and position fire response equipment. 4. Confirm the spill is contained in the tank farm impoundment area. Use sorbents and handtools to limit the area of the spill and amount of contaminated soil within the tank farm. 5. Alert the School Site Principal / Head Teacher. The School Site Principal / Head Teacher will notify YKSD Superintendent of Schools. The Superintendent will mobilize necessary off-site resources of YKSD response contractor and/or the District Maintenance Department. 6. Ensure ADEC is notified of the incident. If the discharge enters or threatens water, the U.S. Coast Guard (National Response Center) will also be notified. 7. If the spill escapes the tank farm impound area, block the drainage paths to prevent product from approaching water or buildings. Predict the direction of flow and dig trenches and build berms to block flow. Earthmoving equipment (backhoes, loaders, dump trucks) is available from the City. Surface drainage surrounding around the tank farm is not well defined. From the east and south sides of the tank farm, surface drainage appears to be the east, towards Eighth Avenue. Drainage from the west and north sides of the tank farm is to the northwest towards undeveloped tundra. Figure illustrates drainage patterns and containment areas. 8. Recovery: Recover spilled fuel with sorbents and/or pumps depending on the volume. If pumps are used, discharge recovered fuel either to empty barrels or to the Schools portable bladder tank. If fuel has been spilled on snow, shovel the contaminated snow into any container with an impermeable lining (dump truck, drums, trash bins, plastic bags, etc.). Determine depth and perimeter of heavily contaminated soil and remove. Store all recovered material in an impervious temporary storage area. 9. In conjunction with ADEC, arrange for proper disposal and/or recycling of all recovered oil, oily sorbents, and other oiled debris. Section 2.5 lists disposal requirements and options Spill at Marine Header or Pipeline During Delivery (USCG Worst Case Discharge) Procedures applicable to failure of manifold, other transfer equipment, or hoses, as appropriate - 33 CFR Part (b)(2)(ii)(a)(g) The marine pipeline is buried three-inch diameter schedule 80, cathodically protected, welded steel about 1,000 feet in length. The receiving header is about 75 feet from the river. Fuel is transferred to the storage tanks by pumps on the barge. During marine delivery transfer personnel maintain constant surveillance of the header, transfer hose, and header. Drip pans are positioned beneath the receiving header and hose connections. Delivery rate is approximately 300 gpm. The Coast Guard worst case discharge planning volume is 1,884 gallons. 1. Alert the nearest barge tankerman to terminate pumping from the barge. Remove or turn off sources of ignition. 2. Close header, pipeline, and storage tank valves. 3. Alert the School Site Principal / Head Teacher. The School Site Principal / Head Teacher will notify YKSD Superintendent of Schools. The Superintendent will mobilize any necessary off-site resources of the YKSD response contractor and/or the District Maintenance Department. 4. Use sorbents and handtools from the School and barge to contain spilled fuel in the immediate area. Dig trenches / berms to prevent oil from entering the river /16

24 5. If spilled fuel enters the river, coordinate the response with the barge crew. All fuel barges are required to maintain spill response equipment, including containment boom, skimmers, and storage containers. If the spill is near the hose or barge, attempt to place the boom around the source. If the spill is large or uncontrollable, identify areas of potential impact and deploy exclusionary and/or diversionary boom. Attempt to recover contained product with the barge skimmer and/or sorbents. 6. Cleanup techniques and/or protection priorities must be established. To establish priorities local considerations must be assessed quickly and accurately. What are: current and developing safety considerations extent of spill and potential environmental/economic damage available manpower/equipment time required to mobilize additional resources the proximity of sensitive areas, probable impact locations, time to impact existing/developing weather & environmental conditions 7. If the spill is on water, work with the barge crew to deploy the barge containment boom in a diversionary or containment configuration. Sheens on water may best be removed with sorbents. 8. The barge crew should arrange for containers or storage tanks to receive the recovered liquids. 9. In conjunction with the vessel person-in-charge arrange for disposal of all recovered oil, oily sorbents, and other oiled debris. Section 2.5 lists disposal requirements and options Tank Failure (EPA Worst Case Scenario) Procedures applicable to tank failure and explosion or fire - 33 CFR Part (b)(2)(ii)(c)(f) 1. Potential location and cause of spill, volume and product spilled The EPA worst case discharge planning volume is 9,800 gallons - the shell capacity of the School s storage tank in the community tank farm. The probability of tank failure or total release is considered to be low. All storage tanks were installed to applicable code requirements, are inspected regularly, and maintained in good condition. The tank farm impound is diked and lined, well designed, and provides impervious secondary containment of approximately 65,000 gallons. 2. Procedures to Stop Discharge / Initial Actions (Notifications) Procedures to stop the discharge would be predicated on the nature of the event. Personnel safety would dictate all actions. Predicated upon circumstances, evacuate all potentially threatened personnel to a designated area (Section 3.5). Conduct no further immediate action if it will jeopardize personnel safety. All actions should be documented in writing. Photographs should also be used to record the incident and cleanup. The initial Incident Commander (School Site Principal / Head Teacher) will conduct a damage assessment and then contact notify the YKSD Superintendent of Schools. The Superintendent will mobilize necessary off-site resources of the YKSD response contractor and/or the District Maintenance Department /16

25 The Superintendent and FSS will activate the School Response Team, and the appropriate components of the YKSD Incident Command System (Section 2.3.3). The necessary local/regional resources may be activated. The Coast Guard and ADEC will be notified. When the spill site is stabilized, and conditions safe for personnel, the Incident Commander will implement the response plan. He/she will organize and brief the Response Team on containment and recovery actions. A site safety plan will be completed (Appendix 5). 3. Fire Prevention and Control Actions Establish a spill zone perimeter and restrict access. In response to threat of explosion or fire: expand the spill zone perimeter. Personnel safety will dictate all actions. Conduct no further response action if it will jeopardize safety. Predicated upon spill location and circumstances, evacuate threatened personnel to a designated area (Section 3.5). Mobilize the volunteer fire department ( ) and School fire suppression equipment. Fire extinguishers are positioned near the entrances to the tank farm, at the intermediate tank, and throughout the School. 4. Direction of Flow / Potential Impact Figure identifies surface drainage patterns and potential containment points. Figure identifies sensitive areas in the vicinity. Section 2.4 describes sensitive habitats. If spilled fuel escapes the tank farm impoundment, it will flow onto surrounding gravel pad. Surface drainage surrounding around the tank farm is not well defined. From the east and south sides of the tank farm, surface drainage appears to be the east, towards Eighth Avenue. Drainage from the west and north sides of the tank farm is to the northwest towards undeveloped tundra. A slough of Kaltag Creek is approximately 375 feet north of the tank farm. The Yukon River is approximately 800 feet east of the tank farm. It is unlikely navigable waters would be impacted by discharge in tank farm area. The impact would be terrestrial contamination of the surrounding streets and tundra. 5. Containment and Control Actions Protection of human and environmentally sensitive areas will be by prompt mechanical response. Initial efforts will be directed at spill containment to restrict the migration of spilled fuel and prevent oil from migrating towards developed areas or entering open water. The following factors should be considered in making decisions about whether to proceed with spill containment and control actions, and if so, to what extent: Safety of all responders. Accessibility for personnel and equipment. Biological and physical characteristics of contaminated shorelines. Will cleanup activities do more damage to sensitive shorelines than leaving the oil to biodegrade naturally. If terrestrial / shoreline containment is deemed feasible, it should be started as soon as practicable to avoid excessive oil penetration into the soil. The primary containment strategy is to contain spilled oil before it reaches any marine or sensitive environment. The containment technique chosen depends upon the situation. The key to any containment effort is to think and plan ahead. Make best use of time and available resources. Containment dikes and trenches may be constructed with handtools and earthmoving equipment. If spilled oil does reach open water, sorbent boom and sweeps should be /16

26 deployed at point of entry. The river current would likely restrict on water response actions and rapidly disperse the refined product. Appendix 7 illustrates containment techniques. School response equipment is stored in the mechanical building at the School. Additional response equipment is stored by the other operators in the community tank farm and AVEC. If spilled fuel does reach the water (during open water), deploy sorbent boom at point of entry. If necessary, request additional resources from the ADEC equipment inventories in Bethel, Mountain Village, and Aniak (Section 2.2.3). 6. Recovery Actions Recover spilled fuel using portable pumps and sorbents from the School spill kit and local / regional sources. For terrestrial spills, direct suction with the pumps may be the initial method of liquid recovery (where volume allows). Effective direct suction recovery generally requires oil to be accumulated in quantities at least ½ inch deep. Spilled oil may be herded to recovery sites with brooms and squeegees. Low pressure water flooding may be implemented when standing product has been recovered. Heavily contaminated soils should be removed to a lined and impervious storage area. Low pressure water flooding may be implemented when standing product has been recovered. Heavily contaminated soils should be removed to a lined and impervious storage area. Sorbent material (sweeps and booms) will be the primary means of recovery of oil that enters open water. A Worksheet to Plan Volume of Response Resources for Worst Case Discharge is presented in Section It demonstrates that the School has access to the adequate resources to meet federal planning requirements. After the spill is contained and pooled product recovered, a site remediation program will likely be required. The Incident Commander will regularly report the cleanup progress and plans to the ADEC and EPA. 7. Recovered Product Transfer and Storage Options Emergency contingency storage is available from four sources: 1) for small spills, the School spill kit includes 3 ea. 85 gallon over drums and 1 ea. 55 gallon open top drum, 2) the School spill kit also includes 1 ea. 1,000 gallon portable fuel bladder tank to meet contingency storage planning requirements, 3) the community tank farm operators are to maintain an empty 10,000 gallon skid-mounted storage tank located next to the tank farm, and 4) in an emergency fuel could be consolidated within the School s four storage tanks to make one tank (7,000 gals.) available for emergency storage. 8. Disposal Options State laws require that the responsible party collect and remove any oil and contaminated debris and/or soil that result from an oil discharge. The Incident Commander, in conjunction with ADEC, will develop an acceptable disposal plan for contaminated material that cannot be recycled or disposed locally. Section 2.5 presents disposal options and requirements /13

27 9. Actions to Protect Sensitive Areas The terrain surrounding the tank has been previously disrupted by commercial development (sewage lagoon), and is not considered environmentally sensitive. Kaltag Creek and the Yukon River are the only habitats in the vicinity that are environmentally sensitive. The actions to protect the creek and river will be mechanical containment of spilled fuel to prevent it from reaching the water. If it is apparent that wildlife may be threatened, alert the U.S. Fish and Wildlife Service and the AK. Dept. of Fish & Game (Section 2.1.2). Project spill trajectory and estimate impact times, and implement wildlife protection strategies. Primary response strategies for wildlife protection emphasize controlling the release and spread of spilled oil at the source to prevent or reduce contamination of potentially affected species and/or their habitat. Primary strategies may include mechanical cleanup and protective booming. In addition, primary response strategies include the removal of oiled debris, particularly contaminated food sources (such as dead wildlife carcasses and oiled vegetation) both in water and on land. Secondary response strategies are to keep potentially affected wildlife away from oiled areas through the use of deterrent techniques. These techniques may include visual methods (placing scarecrows or helium-filled balloons on oiled beaches), auditory methods (firing propane cannons), and other methods (herding wildlife with boats or aircraft). If spilled fuel enters the creek or river, deploy sorbent and containment boom at the point of entry to limit the area of impact. Appendix 7 illustrates boom deployment techniques. The areas of human concern that could be impacted are identified in Section 2.4. They include the several private homes and two City buildings east of the tank farm, and the sewage lagoon northwest of the tank farm. Protective measures would be site evacuation and mechanical containment of the spilled fuel. Section 3.5 is an Evacuation Plan /13

28 FIGURE IDENTIFIES ENVIRONMENTALLY SENSITIVE AREAS 6 MARINE PIPELINE U.S, SURVEY No I 3. 2 a 8 3 u.s. SURVE'f No s U.S. SURVEY No o roo 200 SCALE IN Fm' XXXXXX U.S. SURY V No SURFACE DRAINAGE PATTERNS CONTAINMENT AREAS (BUILD DIKES I TRENCHES) u.s. SUfN '1' No to U.S. SUIM.Y No. 448S \ ' <D I 8 7 DETAIL: TANK FARM ~+~+ +~' noncxxxxxx: THE ON-SITE INCIDENT COMMANDER WILL DETERMINE THE EVACUATION AREA AND PLAN - THE EVACUATION ROUTE WILL DEPEND ON SPILL: VOLUME, LOCATION, AND WIND DIRECTION. I FOR A DISCHARGE AT THE TANK FARM THE EVACUATION ROUTE AND REASSEMBLY AREA WOULD BE "A" STREET TO THE WEST OR EAST, OR EIGHTH AVE TO THE SOUTH -AND WELL AWAY FROM THE SPill ZONE. SHOULD THE NEARBY HOUSES OR CITY BUILDINGS NEED TO BE EVACUATED THE SCHOOL COULD SERVE AS A REASSEMBLY AREA. SCHOOL PIPELINE U.S. SURVEY ; No AMENDED 2. RlUie 2 1/r" lui --,_ IIIIIIWDif <D fouiid t vr JUMNU~~ tjn>...,.. fqiiid &lr... llod -c> MIRJIIU ~ UGMI'PIU: f- #NY NCMOit IOWitO Si1IIIWII DIM --,GHJI-.OWIIIIDD Dlt'IIIC uc -r-ac.urc _,_ ~ MI.&N'.I.CICIIJIIN ~ C 1115 CU.._.., lis 1G11D CONTAINMENT STRATEGIES If' w Terrastrial Containment- block flowbuild dams, Terrestrial Diversion- divert spill away from buildings, sensitive areas- dig/build fj\ diversion paths and collection area. ~ Marine Containment- deploy boom to contain spill at point of entry into water. Marine Diversion - deploy boom to divert IS" spilt to collection/recovery area. I..:Y Marine Exclusion - deploy boom to exclude/prevent spill from impacting or entering a sensitive area. t ~ t~.l!~ itt U.S. SURVEY No SCHOOL SPILL RESPONSE EQUIPMENT STORED IN MECHANICAL I GENERA TOR BLDG. FIGURE SURFACE DRAINAGE, POTENTIAL CONTAINMENT POINTS & STRATEGIES, EVACUATION ROUTES SCHOOL!I INTERMEDIATE TANK li 2~~ ~~ ~------~----~~~~~~

29 2.2.3 Facility Response Equipment Spill response equipment adequate to satisfy federal planning requirements is maintained by and available to the School. The response equipment is stored in School s mechanical / generator building. All spill response equipment is to be maintained "operable and ready-for-deployment." The initial deployment of response equipment can be made within 30 minutes of determination that the safety of responders will not be jeopardized. A visual examination and inventory of the School response equipment is to be conducted monthly by the School Site Principal / Header Teacher, or designated alternate, as part of the required fuel system inspection. The equipment is to be deployed and tested, in accordance with response drill requirements described in Section 4.0 of this FRP. Equipment maintenance is to be conducted when necessary, and after each deployment exercise to ensure the equipment is operable and compatible. Spill response equipment maintained by, and available to, the School includes: CLASS TYPE / CAPACITY AMOUNT LOCATION SORBENT MATERIAL Pads - 16"x20" 2 ea. bales Schl. mechanical bldg. Rolls 140 x30 2 ea. bales Boom - 4 ea. 10 x4 sections p.bale 7 ea. bales = 280 RECOVERY PUMPS / HOSE Sweeps 100 x19 2 bales = 200 Two inch, portable, gas powered, 1 ea. UL listed centrifugal petroleum pump Marlow Petro-Guard Model 2AM32-P or equal w 2 gpm w two inch camlocks, or comp. Rated at 150 gpm. Discharge hose w 2 camlocks Suction hose w 2 camlocks 100 feet 50 feet STORAGE -CONTINGENCY 95 gal overpack poly drums 3 ea. 285 gals. 55 gal open-top drum 1 ea. 55 gals. 1,000 gal. portable bladder tank 1 ea. 1,000 gals. DEPLOYMENT BOAT skiffs - readily available various Local residents CONTAINMENT - EARTH- MOVING EQUIPMENT PERSONNEL PROTECTIVE GEAR & MISCELLANEOUS Grader, dozer, backhoe, loader, dump truck various Tyvek suits, gloves, goggles 4 ea. sets Tank farm connex boots, hardhats Shovels, rakes, handtools Assorted Garbage/disposal bags 1 roll Fire extinguishers portable 5+ ea. Tank farm, School The School does not rely on response contractors to satisfy federal response equipment planning requirements. It does rely on, by contract, Frontier Fuel Service (FFS) to provide trained responders and ICS personnel. In the event of a major emergency, it is possible that additional technical assistance and support equipment may be obtained from local or regional sources, and/or response contractors. All barges that deliver fuel to the School are required to maintain approved Vessel Response Plans. Equipment on board includes fabric-type containment boom equal to at least three times the length of the vessel, skimmers, and contingency storage containers. The boom is available when fuel is being delivered to the School. Alaska Village Electric Cooperative (AVEC) ( ) operates the Kaltag power plant. In an emergency, response equipment stored at the AVEC plant could be made available including sorbents, portable pumps and hose, storage containers, and support gear. Alaska Dept. of Environmental Conservation ( / ) has positioned 20' connex boxes of spill response equipment at Aniak, Bethel, Mountain Village, and Toksook Bay. The equipment may be activated by a call to ADEC. The equipment generally includes containment boom, pumps, rope mop skimmer, hoses, generator, light stands, portable storage, and extensive support and personnel protective gear. City /16

30 EPA regulations require an evaluation of the likelihood that portions of the worst case discharge planning volume (9,800 gallons) would reach navigable or open water via open channel flow or from sheet flow across land, or be prevented from reaching water when trapped in natural or man-made depressions excluding secondary containment structures. Regulations further state that response resources shall, as appropriate, include containment boom, or sorbent boom, or other methods for containing oil floating on water or to protect shorelines. Evaluation of potential impacts to this site establishes the resources available to the Facility are appropriate based on the following criteria. 1. The tank farm is about 800 feet west of the Yukon River. If spilled fuel escapes the tank farm impound, it would flow onto surrounding gravel pad. Surface drainage surrounding around the tank farm is not well defined. From the east and south sides of the tank farm, surface drainage appears to be the east, towards Eighth Avenue. Drainage from the west and north sides of the tank farm is to the northwest towards undeveloped tundra. A slough of Kaltag Creek is approximately 375 feet north of the tank farm. The impact would be terrestrial contamination of the surrounding streets and tundra. It is very unlikely that any discharge at the tank farm would impact the river or other open water. 2. If spilled fuel does migrate to open water the impact would be a very light sheen. Sorbent boom and sorbent sweeps are effective tools for containing and recovering sheens. Sorbent boom can be transported and deployed with local resources more quickly and easily than fabric boom. Sorbent boom is a better tool for terrestrial containment in both summer and winter conditions than is fabric-type containment boom. 3. Deployment of fabric-type containment boom may present life-safety hazards when the available means of deployment and experience of local responders are realistically considered. 4. The delivery barge is on-site at all times when oil is being transferred in the marine pipeline. All barges that deliver fuel to the School are required to maintain an approved Vessel Response Plan that demonstrates to the State and Coast Guard that, at minimum, it has capability to contain and control at least 15% of its cargo capacity within 48 hours. All barges maintain fabric-type containment boom equal in length to at least three times the overall length of the barge. The containment boom is available for deployment when fuel is being delivered to the community tank farm. EPA & USCG Response Resource Requirements The EPA and Coast Guard Guidelines for Determining and Evaluating Required Response Resources for Facility Response Plans are presented in 40 CFR, Part 112, Appendix E, and 33 CFR, Part 154, Appendix C, respectively. The required resource calculations for the School are presented on the following page /13

31 EPA & USCG Response Resource Requirements - Response Resource Worksheet The EPA worst case discharge planning volume is 9,800 gallons (Section 2.2.1). The Coast Guard worst case discharge planning volume is 1,884 gallons. For planning purposes, the larger volume must be addressed. Response resources must be available to meet the discharge planning volume as follows: Part I - Background Information Step (A) Worst Case Discharge Volume 9,800 gals. Step (B) Oil Group # 1 non-persistent Step (C) Geographic Area Rivers and canals Step (D) Percentages of Oil (D1) % Lost to Natural Dissipation.80 (D2) % Recover Floating Oil.10 (D3) % Oil Onshore.10 Step (E1) On-Water Recovery Step (D2) x Step A 980 gals. 100 Step (E2) On-Shore Recovery Step (D3) x Step A 980 gals. 100 Step (F) Emulsification Factor 1.0 Step (G) On-Water Recovery Resource Mobilization Factor (G1) Tier 1.30 (G2) Tier 2.40 (G3) Tier 3.60 Part II On-Water Recovery Capacity (bbls. 3/ day) (must be maintained within region or contracted for) Step (E1) x Step (F) x Step (G1) Tier 1 (available within 12 hours) 294 gals. Step (E1) x Step (F) x Step (G2) Tier 2 (available within 36 hours) 392 gals. Step (E1) x Step (F) x Step (G3) Tier 3 (available within 60 hours) 588 gals. Available contingency storage capacity must be twice the daily recovery capacity = 1,176 gals. Part III Shoreline Cleanup Volume (bbls. / day) (must be maintained within region or contracted for) Step (E2 x Step F) 980 gals. The School satisfies response resource requirements by having access to the following equipment: Containment Marine sorbent boom 240 feet, sorbent sweeps 200 feet, containment boom on barge Terrestrial Handtools at School earthmoving equipment available from City. Transfer / Recovery Equipment 1 ea. 2 inch transfer pump rated at 150 gpm. Derated capacity = 150 gpm x.2 efficiency factor x 10 hours per day = 18,000 gals. per day Storage overdrums (3 95 gals. ea.) 285 gals. open top drum (1 55 gals.) 55 gals. bladder tank (1 ea. 1,000 gals.) 1,000 gals. total 1,340 gals /13

32 2.3 FACILITY RESPONSE ACTIVITIES Response Organization / Personnel Responsibility YKSD has designated a Qualified Individual and Incident Commander and alternates (Section 1.1). As described below, these individuals shall work together to direct and manage response activities for any discharge resulting from School operations. The Qualified Individual (Q.I.) and Incident Commander (I.C.) shall be immediately notified in the event of any oil spill resulting from School operations - regardless of volume or time! Contact numbers are listed on page 1-2. IN THE EVENT OF AN OIL SPILL THE QUALIFIED INDIVIDUAL / INCIDENT COMMANDER SHALL: IN ACCORDANCE WITH 40 CFR (H)(3)(IX)(A)-(H), THE INCIDENT COMMANDER AND QUALIFIED INDIVIDUAL(S) SHALL BE TRAINED IN, AND BE FAMILIAR WITH THESE DUTIES: 1. Activate internal alarms, assess hazards, ensure safety of personnel (Section 3 & Appendix 5). 2. Activate the School Response Team, implement the spill response plan, and coordinate local resources (Sections 2.2.2, 2.3). Mobilize the necessary off-site resources. 3. Mobilize the necessary components of the Incident Command Management Teams (Section 2.3.3). 4. Report the spill to government agencies, as required by state and federal law (Section 2.1). 5. Monitor the effectiveness of the cleanup and interface with agencies to ensure cleanup efforts are "adequate" (Section 2.1.5). Acts as liaison with government agencies. Acts as initial Public Information Officer and Safety Officer until duties are delegated. 6. Record basic spill information (Section 2.1.3). 7. Ensure recovered oil / contaminated materials are recycled or disposed properly (Section 2.5). 8. Complete and submit required written reports (Section 2.1.3). Pending arrival of the designated Qualified Individual and Incident Commander, the School Site Principal / Head Teacher or senior YKSD person at the site of the spill shall act as the initial on-site Incident Commander. Members of the School Response Team (Section 1.1) will be assigned cleanup duties by the Incident Commander. The School Response Team is comprised of local YKSD personnel, FFS personnel from Wasilla, and YKSD personnel from Fairbanks. YKSD response personnel are to be trained in emergency response, safety, spill response, and this FRP. Team members in conjunction with local resources are adequate to staff a response for seven days. Figure summarizes the School spill response organization. Section 1.1 lists School Response Team members and phone numbers Qualified Individuals In compliance Coast Guard and EPA regulations, YKSD has designated a Qualified Individual (Q.I.) and alternate. Section 1.1 of this plan identifies the current Q.I. and alternate, and provides contact information. This plan serves as the required documentation of the Qualified Individuals, and confirms they meet requirements of Part , and maintain the authority to: activate and engage in contracting with oil spill removal organizations act as a liaison with the predesignated Federal On-Scene Coordinator obligate funds required to carry out response activities /16

33 INITIAL ON-SITE & INITIAL INCIDENT COMMANDER (SCHOOL SITE PRINCIPAL / HEAD TEACHER) YKSD SUPERINTENDENT OF SCHOOLS INCIDENT COMMANDER & QUALIFIED INDIVIDUAL (FFS) SCHOOL INCIDENT MANAGEMENT TEAM (FFS, YKSD) ADEC / EPA / COAST GUARD MONITORS SCHOOL RESPONSE TEAM (YKSD & FFS) LOCAL RESOURCES (YKSD) REGIONAL RESOURCES (YKSD, FFS) FIGURE SCHOOL SPILL RESPONSE ORGANIZATION /16

34 2.3.3 Incident Command System The Incident Command System (ICS) is an organized approach to emergency response management. The ICS system has been adopted by the State of Alaska and is being incorporated into private spill response plans nationwide. It identifies functions which may have to be performed in an emergency and establishes common terminology. The ICS concept is built on teamwork and coordination between the public and private sector through all phases of incident management. The basic ICS principles and organization are described below. Principles of Incident Command System The ICS of the responsible party (spiller) is managed by the Incident Commander who is generally the senior official responding to the spill. The government Incident Commander is the predesignated On-Scene Coordinator. The State of Alaska has organized an incident command system designed to monitor spills until such time it is determined the private spill response is not adequate. Should that occur the State may become directly involved in the cleanup. The ICS organization is functionally oriented around five major areas: Command, Planning, Operations, Logistics and Administration. Staffing within the ICS is flexible and based upon the requirements of the incident. The on-site initial Incident Commander is senior operator on-site. For small incidents one person may perform all ICS functions. As required by the situation, the School will mobilize its Incident Management Team including appropriate Function Section Chiefs and Unit Leaders. In the event of a major incident, the School Incident Commander and the On-Scene Coordinators from ADEC and the Coast Guard, and a local representative, will be designated Unified Commanders, and form the Unified Command. In order to expedite spill response decisions and action, the Unified Commanders will have direct access to one another at all times. The basic principles of ICS are: 1. Common terminology for personnel, organizational positions, and operational procedures. Terminology is to be predefined and understood by all participants. 2. Common organizational structure that includes personnel of all participating companies or agencies operating as a unified team. 3. Defined responsibility and authority for accomplishing specific functions. 4. Written action plans to accomplish overall objectives as well as those of each operating unit. 5. Integrated emergency management facilities and communications providing a managed interjurisdictional response. 6. Personnel qualified and trained in the ICS principles, terminology, and implementation. 7. Manageable span of control. Ideally, the span of control of any crisis manager should range from three to seven people. Anticipating change and preparing for it are vital to emergency management, especially during rapid build-up of an organization when good management is complicated by too many reporting elements. 8. Evaluation of Performance following the spill response. Incident Management Team The Incident Management Team will consist of Incident Commander, Section Chiefs for Planning, Operations, Logistics, and Administration, and appropriate staff support. Depending on the magnitude of the incident, one person may fill more than one of these positions. As an incident escalates it may be necessary for the Incident Commander to organize a Command Staff, and for Section Chiefs to assign tasks to Unit Leaders. The following subsections lists duties of the Incident Management Team. Incident Commander The Incident Commander is on-site and responsible for overall management of all spill activities. He directs the Incident Management Team, and approves the ordering and release of resources (contractors and equipment). He approves Incident Action Plans, and communicates with government agencies. As the situation warrants, the Incident Commander may organize a /13

35 Command Staff which may include an Information Officer, Legal Advisor, Safety Officer, and Government Liaison Officer. General duties of the Incident Commander include: 1. Development and implementation of preliminary strategy for the incident immediately following activation. 2. Conducting initial briefings which summarize incident organization, current activities, resources deployed and enroute, and special instructions. 3. Coordination of staff and function activities. 4. Constant monitoring of the spill response and the development of alternative strategies with the Incident Management Team. Planning Section Chief The Planning Section Chief is responsible for collection, evaluation, and dissemination of information regarding the spill response and status of resources. He is responsible for the development of Incident Action Plans which are to be prepared during the course of the spill. Incident Action Plans establish and provide specific objectives, assignments, communication plans, medical plans, transportation plans, and other specific tasks and data. As required by the situation, the Planning Section Chief may appoint Unit Leaders to manage functions such as documentation, resource assessment, demobilization and technical matters. General duties of the Planning Section Chief include: 1. Establishing a planning section at the designated command center immediately following activation. 2. Ascertaining the critical nature of the spill and beginning surveillance and trajectory modeling. Identifying sensitive areas and developing priorities to protect such areas. 3. Documenting and collecting spill data from the inception of the incident through demobilization. 4. Coordinating of damage assessments and establishing monitoring and sampling activities. 5. Tracking personnel, resources, and actions of contractors, and coordinating their activities through Incident Action Plans. Operations Section Chief The Operations Section Chief is responsible for management of all tactical operations directly affecting the spill and implementing the objectives of the Incident Commander and Incident Action Plans. He directs all cleanup activities and coordinates response contractors. Unit leaders may be appointed to monitor field operations. General duties of the Operations Section Chief include: 1. Ascertaining the nature of the incident, evaluating the effectiveness of current actions, and ordering additional resources as needed. 2. Establishing and maintaining staging areas, and projecting resource requirements. 3. Coordinating with the Logistics Section Chief for needed services and support. Logistics Section Chief The Logistics Section Chief arranges support and material needs of the response, including, but not limited to facilities, transportation, supplies, food, fuel, and medical services. Unit Leaders may be designated to administer functions such as communications, security, supply, food, health and social services. General duties of the Logistics Section Chief include: 1. Establishing and maintaining the designated command and response center. 2. Coordinating with the Planning and Operations Section Chiefs and ordering, receiving, storing and processing response equipment, personnel and supplies. Verifying accountability and security of resources. 3. Establishing and maintaining communication networks with command center and field operations. 4. Providing for sanitation and food service for spill work force. 5. Developing medical plans which address medical emergency procedures for the work force /13

36 Administration Section Chief The Administration Section Chief is responsible for all financial and administrative aspects of the spill response, including procurement, clerical support, contracts, compensation, claims, data processing and cost analysis. Management of specific tasks will likely be delegated to Unit Leaders. Duties of the Administration Section Chief include: 1. Protecting the interest of the School in all financial matters. 2. Providing accounting functions including billings, invoice payment, and documentation of labor, materials and services. 3. Establishing and administering vendor contracts and rental agreements. 4. Initiating investigation and documentation of claims. Public Information Officer The Public Information Officer (PIO) manages and distributes information regarding the incident. Duties of the PIO include: 1. Serves as clearing point for dissemination of information. Interfaces with counterparts in the Unified Command, media, appropriate agencies and the community. 2. Coordinates approval of the Unified Command prior to release of information to media. 3. Organizes/conducts Unified Command media briefings, town hall meeting, etc. Works to develop supporting documents (maps, graphs, etc.). 4. Resolves conflicting information and identifies media concerns to the Unified Command. Safety Officer The Safety Officer develops safety plans and assesses hazards and safety conditions on an ongoing basis. Duties of the Safety Officer include: 1. Develops and implements a site safety plan per OSHA requirements. Assesses environments/conditions to determine the level of personal protective equipment (PPE). Works with Unified Command counterparts to insure consistency of safety standards. Has the authority to override decisions made by IC if deemed unsafe. 2. Supervises safety-related activities. Insures response personnel are adequately briefed regarding safe working practices. Insures compliance as necessary to meet OSHA regulations related to worker safety. 3. Establish decontamination procedures and contamination reduction zones for all on-scene personnel and equipment. Government Liaison Officer The Government Liaison Officer serves as the initial point of contact for participating state and local agencies. Duties of the Liaison Officer include: 1. Serves as a buffer to the IC. Receives/coordinates calls from agencies and private response entities offering assistance or requesting information. 2. Identifies public and private response entities concerns regarding the status and effectiveness of response to the incident. 3. Maintains an incident response summary distribution list for public and private response entities information. Figure illustrates the basic components and duties within the ICS system Response Contractor Information YKSD does not rely on response contractors to satisfy federal response equipment planning standards. YKSD has contracted Frontier Fuel Service (FFS) to provide spill response personnel and expertise at all schools. FFS services include on-site maintenance, required inspections and tests, training, and spill response including Qualified Individual responsibilities and authority. FFS is a Wasilla based corporation organized to contract for the operation and maintenance of rural Alaskan bulk fuel storage facilities /16

37 INCIDENT COMMANDER Set Policy, Establishes Objectives Develops Response Strategies Approves Incident Action Plans Commits Funds Coordinates Function, Staff Activities Conducts Briefings, Coordinates with OSC COMMAND STAFF Information Officer - media contact Legal advisor - legal implications Safety Officer - worker health & safety Government Liaison - local agency contact/coordinator PLANNING SECTION CHIEF OPERATIONS SECTION CHIEF LOGISTICS SECTION CHIEF ADMINISTRATION SECTION CHIEF Response planning Provides information to Command Spill surveillance and tracking Identifies sensitive areas Identifies response needs Develops incident action plan Conducts Damage Assessment Monitors contractors Implements action plan Directs field operations Provides information to Command Establishes staging areas Anticipates necessary response Coordinates for needed services and support Monitors contractors Arranges: Communication Security All transportation Equipment and fuel needs Facilities Food Emergency medical services Support services Equipment inspection & maintenance Demobilization/salvage Office management Accounting functions Contracts and rental agreements Staff personnel Claim documentation Data management Response documentation UNIT LEADERS UNIT LEADERS UNIT LEADERS UNIT LEADERS FIGURE INCIDENT COMMAND SYSTEM /13

38 2.4 SENSITIVE AREAS Sensitive Areas and Protection Measures Planning Distances The EPA and Coast Guard "planning distance" for facilities near non-tidal water is the downriver distance that could be impacted at maximum current in 27 and 24 hours respectively. Facilities are to identify resources to protect potentially impacted areas within the required planning distances. Assuming a two-knot current, the EPA planning distance is 62 miles downriver and the Coast Guard planning distance is 55 miles downriver. The creditability of these mandatory planning distances is suspect when applied to small fuel facilities in rural Alaska. Existing regulations do not consider the: (1) comparatively small potential discharge volumes, (2) the distance of the tank farms from navigable water, (3) dispersion rate of refined fuels, and (4) variable currents. Figure illustrates the planning area in the vicinity of the School. Section is a Vulnerability Analysis, prepared in accordance with 40 CFR, Part 112, Appendix F, which identifies potentially threaten areas and protection measures. The Interior Alaska SubArea Contingency for Oil and Hazardous Substance Discharge/Releases identifies sensitive areas, contacts, priority protection areas, and land management maps. The plan is accessible at Maps in the plan are at: Sensitive Areas The terrain surrounding the tank has been previously disrupted by commercial development (sewage lagoon) and is not considered environmentally sensitive. The only environmentally sensitive areas that could realistically be impacted by a discharge from School operations are the Yukon River which is about 800 feet west tank farm and a slough of Kaltag Creek is about 375 feet north of the tank farm. The Rodo River drains to the Yukon River about 3½ miles south of Kaltag, but the chances are remote that a spill from School operations could impact the river. Actions to protect sensitive areas would be terrestrial containment at the spill site. If spilled oil enters open water, the protection measures would be deployment of sorbent boom and sweeps, and activation of additional response resources, as necessary. Kaltag is across the Yukon River from the Innoko National Wildlife Reserve. The entire area is an important breeding and resting spot for migratory waterfowl. No nesting areas or critical habitat are within close proximity to the tank farm or pipelines. If it is apparent that wildlife may be threatened, the U.S. Fish and Wildlife Service and the AK. Dept. of Fish & Game shall be alerted (Section 2.1.2). The primary response strategies for wildlife protection emphasize controlling the release and spread of spilled oil at the source to prevent or reduce contamination of habitat. In addition, initial response strategies include the removal of oiled debris, particularly contaminated food sources (such as dead wildlife carcasses and oiled kelp) both in water and on land. Secondary response strategies are to keep potentially affected wildlife away from oiled areas through the use of deterrent techniques. These techniques may include visual methods (placing scarecrows or helium-filled balloons on oiled beaches), auditory methods (firing propane cannons), and other methods (herding wildlife with boats or aircraft). Kaltag is an Athabascan village with approximately 250 residents. The tank farm is about 800 west of Yukon River, adjacent to several residential structures, city buildings and the sewage lagoon (Figure 2-2-1). "Human populations" that could be impacted by a discharge include persons near the spill location, which could include all people within the vicinity of the tank farm, dispensing station, pipeline, and nearby buildings. Actions to protect human populations would be to establish safety perimeters, and clear or evacuate the area, as described in Section 3.5. Down river human populations that could realistically be impacted are very limited. Other than a few seasonal cabins and fish camps, /13

39 the closest settlement is Grayling more than 100 miles downriver. Attempts will be made to notify all areas and residents if they are threatened by a spill from School operations. No surface "water intakes" could be impacted by a discharge from School operations. The City water supply is from a well / intake located more than a half mile northwest of the tank farm. There are no other wells within at least 300 feet of the tank farm. Protection measures for any area threaten by a discharge will be spill prevention, prompt spill response, terrestrial containment, and appropriate remediation programs of contamination. There are no identified archaeological sites within close proximity of the community tank farm. Questions regarding historical or archaeological sites should be directed to the Alaska Office of History and Archaeology (Section 2.1.2). "Severity of Consequences" of a discharge resulting from tank farm operations would, most likely, be limited to surface contamination. Containment and recovery operations would be initiated upon detection. If necessary, a soil remediation program would be developed in conjunction with agency personnel and consultants. Threaded, Endanger Species No threaded or endangered species inhabit the vicinity around the tank farm. There is no state designated critical habitat or Most Environmentally Sensitive Areas (MESA) in the vicinity Area Contingency Plan This Facility Response Plan is consistent with the State / Federal Unified Plan and the Interior Alaska SubArea Plan for Oil and Hazardous Substance Discharge/Releases. This Plan is to be updated if the Unified or the SubArea Plan are amended to identify additional sensitive areas within a reasonable planning distance from the Facility. The plans are accessible at: /13

40 2.4.3 Vulnerability Analysis* Site / Potentially Location / Distance Notification (Section 2.1) Environment Threaten From Facility Containment / Response Y / N (map on following page & Figs , Appdx-1) Measures NOTIFY SITE PRINCIPAL/HEAD TEACHER OF ALL SPILLS 1. water intakes N City water intake is >½ mile NW of tank farm 2. schools N School is 2,000 feet SE of tank farm 3. medical facilities N Clinic is 1,000+ feet SE of tank farm 4. residential area Y several residents on Eight Ave. and evacuate if threatened - establish safety perimeter C St. - across street from tank farm build dikes/trenches to contain spill 5. businesses Y buildings and sewage lagoon evacuate if threatened - establish safety perimeter adjacent to tank farm build dikes/trenches to contain spill 6. wetlands / sensitive areas Y Yukon River 800 feet E of tank farm & block surface flow - deploy boom at point of entry - tundra, Kaltag Creek N&W of tank farm notify agencies - activate additional resources 7. fish and wildlife Y same as above " 8. lakes and streams Y same as above " 9. endangered flora - fauna N 10. recreational areas Y same as above " 11. transportation routes Y nearby roadways and paths block access - evacuate if threatened - establish safety perimeter - build dikes/trenches to contain 12. utilities Y sewage lagoon 13. other - N *source (40 CFR, Part 112, Appendix F) /12

41

42 2.5 DISPOSAL PLAN Disposal Options / Requirements The Qualified Individual / Incident Commander will arrange for the disposal of all recovered oil liquids, oily sorbents and other oiled debris. Disposal and treatment alternatives will be predicated on the volumes and type of material recovered. Permits required for disposal will vary on a case-by-case basis depending on type, volume and condition of the material to be disposed. Road oiling and burning may appear to be the most practical means of disposal, however, permits from ADEC are required for both activities. Failure to obtain a permit prior to road oiling or burning may result in civil penalties. The disposal of material recovered from spill cleanup operations, which cannot be recycled or used locally, will in every case be disposed of in a manner approved by the ADEC, and in compliance with applicable EPA/DOT regulations. If recovered materials are shipped offsite for disposal or treatment, full documentation, including manifests and disposal certifications, is to be maintained on file for a period of three years. Permitted disposal facilities change services and locations frequently. The State/Federal Unified Plan Volume 1, Annex E, Tab B lists contact information for waste disposal contractors that may assist in identifying disposal options. Contractors include Emerald Alaska, PSC Environmental Services, and Alaska Soil Recycling. The Unified Plan is accessible at: If recovered fuel is decanted (to separate water), the discharge of any contaminated waste water must be approved by ADEC. It is likely waste water will have to be analyzed and possibly treated prior to disposal. Alternatives and approvals for disposal of contaminated soil may be more complicated and must be handled on a case-by-case basis. ADEC's Oil and Hazardous Substance Cleanup Standard regulations (18 AAC 75, Article 3) establishes soil cleanup standards depending on site specific conditions and risk based analysis. Final cleanup levels will be determined by the ADEC Contaminated Site (CS) Supervisor or his designee based on site-specific conditions, and "Corrective Action Plan" that must be submitted to ADEC. The collection of all field data (soil samples, etc.) must be conducted by, or immediately overseen by, a qualified, impartial third party. Interim and final reporting of contaminated site date must also be by a third party. Several technologies are currently being developed and tested for treatment of oil contaminated soils, however, data and valid cost/benefit analysis is limited for treatment of refined products in remote Alaska conditions. Possible treatment methods include: Biological Treatment Land farming Chemical Treatment Thermal Destruction Soil Washing. Soil Vapor Extraction Stabilization/solidification /13

43 3.1 SPILL HISTORY 3.0 HAZARD EVALUATION No reportable oil spills (spills to navigable water) have occurred from School operations of the current Facility. Section of this FRP lists spill documentation and report requirements. 3.2 POTENTIAL SPILLS A discharge could result from operator error, equipment failure, vandalism, or catastrophic event. The reasonably expected modes of major failure, rupture or accident in which oil could be spilled are listed below. All storage tanks were installed to applicable code requirements, are inspected regularly, and maintained in good condition. The tank farm impound is diked and lined and provides secondary containment of approximately 65,000 gallons. The intermediate tank at the School is a double wall UL tank with liquid level gauge, float actuated fill-limiting valves and high level shut off switches that stop the transfer pump. All tank filling and transfers are manually initiated and visually monitored. Pump shutdown controls are in close proximity to transfer locations. Both the marine and intermediate tank transfer pipelines are welded steel. Bottom-penetration valves on storage tanks and transfer pipeline isolation valves at the entry/exit to the tank farm are to be closed and locked when transfers are not being conducted. The marine pipeline is buried, cathodically protected, and integrity tested annually. SOURCE POTENTIAL VOLUME RATE OF FLOW DIRECTION OF FLOW STORAGE TANKS TANK LEAK OR FAILURE 9,800 gals. = nominal capacity of largest storage tank. OVERFLOW 1,500 gals.± = assume 5 minutes to detect and shutdown INTERMEDIATE TANK TANK LEAK OR FAILURE 6,000 gals. = nominal capacity of intermediate tank. OVERFLOW 200 gals.± = assume 5 minutes to shutdown Variable Barge transfer rate = 300 gpm± Variable TRANSFER PIPE TO INTERMEDIATE TANK PIPE RUPTURE / FRACTURE DURING TRANSFER MARINE PIPELINE PIPE RUPTURE / FRACTURE DURING TRANSFER 1,500 gals. = assume 30 minutes to detect and shutdown Coast Guard worst case discharge planning volume is 1,884 gals. Tank fill rate = 50 gpm+/- Transfer rate 50+/- gpm. Barge transfer rate = 300 gpm± Spilled oil should be contained in the diked and lined impound. If spilled oil escapes the impound it would drain onto the surrounding gravel pad. Surface drainage surrounding around the tank farm is undefined. From the east and south sides of the tank farm, surface drainage is to be the east, towards Eighth Avenue. Drainage from the west and north sides of the tank farm is to the northwest towards undeveloped tundra. Same as above Oil spilled from a leak or fracture of the primary tank would be contained in the double wall containment structure. If oil escapes the containment structure it would drain to and accumulate around the level gravel pad beneath the tank. Same as above Spilled oil would percolate into the sandy, silty soils and/or migrate with the surface terrain. Pipeline is buried /13

44 3.3 EMERGENCY SHUTDOWN SYSTEMS Delivery of product to the storage tanks is controlled by pumps aboard the barge. Emergency shutdown may be initiated by radio and/or verbal contact to the vessel. During product delivery, shoreside personnel maintain radio contact with vessel personnel. Transfer of product can be terminated within less than 30 seconds of notice. Flow in the marine pipeline is controlled by: (1) check and ball valves the receiving header, (2) ball valves on the pipeline where it enters the tank farm, and (3) ball valves and flex connectors at each tank. Following each barge delivery, the marine delivery pipeline is blown with air to purge the line of fuel. Delivery of product to the intermediate tank is controlled by a centrifugal pump in the community tank farm. Pump shutdown controls are located on the intermediate tank and in the tank farm pump control panel (Appendix 1, Figure A1-3). 3.4 FIRE SUPPRESSION EQUIPMENT Portable fire extinguishers are to be maintained near the access gates to the tank farm and intermediate tank. During marine delivery, a fire extinguisher is to be placed near the marine header. Tanks are to be marked to identify type of fuel contained in the tank, tank capacity, and tank number. No smoking, warning, spill notification are to be posted. The on-site Incident Commander is designated Fire Fighting Coordinator. In the event of potential fire, notification shall be made to the City and volunteer fire department (Section 1.2) in order to coordinate community plans. 3.5 EVACUATION PLAN A significant oil discharge or fire at the community tank farm could warrant area evacuation. The tank farm is on the northwest side of the community removed from most development except for some residential structures to the east and southeast; two City buildings (garage and storage) to the east, and the sewage lagoon to the northwest of the tank farm (Figure 2-2-1). The on-site Incident Commander will determine the immediate need for site evacuation and implement an initial evacuation plan. If evacuation is warranted, it will be initiated by voice. Persons who may be in the spill area will be instructed to evacuate in an upwind direction. If necessary the City and VPSO will be alerted to assist with the evacuation. Personnel will be directed to reassemble for a centralized check-in and evacuation validation (roll-call). The evacuation route and reassembly area would likely A Street to the east or west, or Eighth Avenue to the south; and then well away from the spill zone. Should the nearby houses or City buildings need to be evacuated the School could serve as a reassembly area. When the immediate spill area has been cleared, and based on the circumstances of the event, the Incident Commander will determine if an expanded evacuation or further actions are warranted. If a significant or uncontrolled discharge occurs, the following actions may be implemented: Access to the spill area will be blocked to all unauthorized traffic. Safety perimeters will be established. Only authorized personnel allowed to enter the spill zone. In the event of any major emergency (tank failure/fire) the Alaska Div. of Emergency Services ( ) should be notified to provide coordination with existing community and regional plans /13

45 3.6 PERSONNEL SAFETY Personnel safety is the highest priority in all operations. Under no circumstances will School personnel actively respond to discharges that present an unknown, or hazardous environment, or which may require confined space entry. In response to such events, a qualified response action contractor will be activated. A Material Safety Data Sheets (MSDS) for diesel fuel is in Appendix 5 of this Plan. MSDS's provide physical data, fire, explosion, and reactivity information, spill procedures, and most special precautions. Refer to the MSDS if there are questions regarding safe handling or exposure to diesel fuel. All discharges of petroleum are dangerous to a certain extent. Accumulations of hydrocarbon vapors can have an adverse effect on personnel. The sense of smell is dulled and symptoms of diminished responsibility and dizziness similar to drunkenness, with headaches and eye irritation, are common. High vapor concentrations can cause suffocation, paralysis, and possibly death. Chemical burns may be caused by repeated or continuous contact of the skin with petroleum products, therefore protective clothing should be worn by workers in the spill zone. Protective gear should include rain gear (or other impermeable clothing), rubber boots, impermeable work gloves, and possibly a face mask. Spill responders should never work alone. A zone of safety should be established around the spill, and only persons authorized for cleanup work allowed within this zone. The perimeter of this zone will be predicated on location and magnitude of the incident, however, it should be well beyond vapor, fire, or explosion danger. In accordance with OSHA regulations, a written site safety plan is to be developed for each response to a release of hazardous materials. A copy of an acceptable site safety plan format is contained in Appendix 5 of this Plan /13

46 4.0 TRAINING AND DRILLS 4.1 OPERATOR TRAINING The YKSD Superintendent of Schools is ultimately is accountable for spill prevention and response training at all schools. YKSD has contracted Frontier Fuel Service (FSS) to provide spill prevention, response, and compliance assistance at all schools. FFS services include on-site maintenance, required inspections and tests, training, and spill response including Qualified Individual responsibilities and authority. FFS personnel are to conduct spill prevention and response training at as described below. All School personnel are to be instructed in operations, maintenance, and spill prevention procedures pertinent to their duties. Training is to be provided at the start of employment and at least once a year, thereafter. At minimum, the training should address the following topics. A. Pollution control laws, rules, and regulations B. Fuel Storage Systems: 1. Purpose and application 2. System elements: a. Tanks b. Pumps c. Accessory equipment 3. Operation and maintenance of equipment 4. Fuel transfer procedures C. Spill Prevention and Control: 1. Potential spill sources 2. Procedures to prevent spills 3. Review of control measures: a. Secondary containment b. Safety valves c. Pump shutoff switches D. Emergency response procedures: 1. Initial spill response / notification procedures 2. Personnel safety MSDS review 3. Location and use of emergency phone numbers 4. Location and use of fire extinguishers 5. Location and use of spill cleanup materials 6. Review of facility spill prevention and response plans 7. Local spill response resources 4.2 SPILL RESPONSE TRAINING Members of the School Response Team are to participate in an annual spill response training program that also addresses safety and discharge prevention training. The training program may vary from year to year, however, at minimum, it is to address the following topics: Spill Prevention & Response Plans - Facility Response Plan, SPCC Plan, Operations Manual YKSD Response Organization Incident Command System Potential Spills and Response Actions Discharge Prevention, Operating Procedures Regulatory Requirements - Spill Reporting Health and Safety Considerations If volunteers or casual labors are employed during a spill response, they are to be trained to the applicable OSHA standards listed in 29 CFR Part Qualified Individual Training: In accordance with 40 CFR (h)(3)(ix)(A)-(H), the YKSD Qualified Individual and Alternates are to be trained in implementation of this plan and their duties including: hazard identification, assessment, and communication systems; response mobilization and organization; notification requirements; spill containment and recovery considerations; and coordination of rescue and response actions previously arranged with response personnel /16

47 4.3 SPILL DRILLS, EXERCISES The National Preparedness for Response Exercise Program (PREP) is an effort to clarify and coordinate EPA and Coast Guard spill drill requirements. Compliance with the PREP requirements listed below satisfies all spill drill and exercise requirements. To comply with PREP requirements, training must be provided to individuals/positions with specific duties in this plan. YKSD satisfies PREP requirements as follows: PREP REQUIREMENT Qualified Individual Notification Drill quarterly Equipment Deployment Drills - semiannually Spill Management Team Tabletop Exercise - annually Unannounced Drills as requested by EPA or USCG YKSD PROGRAM YKSD has designated FFS the responsibility and authority to serve as Qualified Individual (Q.I.) and alternate for all schools. The purpose of Q.I. Notification Drills is to ensure Q.I. s can be contacted promptly by YKSD School and District personnel in the event of a discharge. FFS will initiate and document quarterly Q.I. Notification Drills with School and YKSD District personnel. The School Response Team is to conduct semiannual equipment deployment drills. The equipment necessary to respond to a small or average most probable discharge (Section 2.2.1) is to be deployed. In accordance with PREP requirements, actual spill response with equipment deployment may satisfy equipment drill requirements. FFS will assist and document required equipment deployment drills. Section Chiefs of the School Incident Command Organization are to participate in an annual Tabletop Exercise, which may be part of the annual spill response training program. FFS will initiate and document quarterly annual Tabletop Exercises with School and YKSD District personnel. School personnel will cooperate with the EPA and/or USCG in conducting unannounced drills and exercises. Triennial Exercise Once every three years the School is to conduct an exercise that tests the entire response plan, including Organizational Design, Operational Response, and Response Support. FFS will initiate and document Triennial Exercises with YKSD personnel. "Fact sheets" that detail the requirements for the above PREP requirements are on the following pages. Appendix 6 contains sample training documentation forms that may be used to satisfy record keeping requirements. Records sufficient to document the required training must be maintained for a period of 5 years, and must be available for inspection upon agency request. 4.4 COAST GUARD PERSON-IN-CHARGE TRAINING To comply with Coast Guard regulations (33 CFR, Part ), the YKSD and vessel persons-incharge of marine transfers must have had a minimum of 48 hours of experience in oil transfer operations, and, at minimum, they must know: (1) The hazards of each product transferred; (2) The rules in 33 CFR, Parts 154 and 156; (3) The facility operating and fuel transfer procedures; (4) The oil barge transfer systems (in general); (5) The oil barge transfer control systems (in general); (6) The facility oil transfer control systems; (7) Oil spill reporting procedures; (8) The facility oil spill contingency plan procedures. In accordance with 33 CFR Part , written certification shall be maintained that each designated person-in-charge has completed the training requirements of Part A sample copy of an acceptable certification form is in Appendix PREP TRAINING FACT SHEETS Refer to the following pages. Q.I. Notification Drill - quarterly Spill Management Team Tabletop Exercise - annually Equipment Deployment Drills - semiannually Unannounced Drills - as requested by the EPA or USCG /16

48 Applicability: - Facility QI NOTIFICATION DRILLS COAST GUARD & EPA REGULATED FACILITIES Frequency: - Quarterly, or routine communication if it occurs on at least a quarterly basis. Initiating Authority: - Company Policy Participating - Facility Personnel, Qualified Individual Elements: Scope: - Exercise communications between facility personnel and Qualified Individual. Objectives: - Contact must be made with a Qualified Individual or designee, as designated in the plan. Certification: - Self Certification Verification: - Verification to be conducted by the appropriate agency during site visits. Records: Retention: - 3 Years (USCG) 5 Years (EPA) Location: - At Facility Evaluation: - Self Evaluation. Credit: - Plan holder may take credit for this exercise in the course of conducting routine business or other drills, provided that the objectives of the drill are met and the drill is properly recorded. Similarly, credit may be received for an actual spill response when these objectives are met and a proper record generated /13

49 SPILL MANAGEMENT TEAM TABLETOP EXERCISE COAST GUARD & EPA REGULATED FACILITIES Applicability: - Frequency: - Annually Facility Spill Management Team Initiating - Company Policy Authority: Participating - Spill Management Team as established in Facility Response Plan. Elements: Scope: - Exercise the Spill Management Team s organization, communication and decision making in managing a spill response. Objectives: - At least one Spill Management Team Tabletop Exercise in a triennial cycle shall involve simulation of a worst case discharge scenario. Certification: - - Exercise the Spill Management Team in a review of: - Knowledge of the response plan - Proper notifications - Communications system - Ability to access OSRO - Coordination of organization/agency personnel with responsibility for spill response - Ability to effectively coordinate spill response activity with National Response System infrastructure - Ability to access information in Area Contingency Plan for location of sensitive areas, resources available within the Area, unique conditions of Area, etc. Self Certification Verification: - Verification to be conducted by responsible oversight agency. Records: Retention: - 3 years (USCG) 5 years (EPA) Location: - At facility Evaluation: - Self evaluation Credit: - Plan holder may take credit for this exercise when conducted in conjunction with other drills as long as all objectives are met and a proper record generated. Likewise, credit may be taken for an actual spill response when these objectives are met and a proper record generated /13

50 EQUIPMENT DEPLOYMENT DRILLS COAST GUARD & EPA REGULATED FACILITIES Applicability: - Frequency: - Semiannually Initiating - Company Policy Authority: Participating - Facility Personnel Elements: Facilities with facility-owned response equipment Scope: - Deploy and operate facility-owned response equipment identified in the response plan. Only a representative sample of each type of equipment or that which is necessary to respond to an EPA defined small discharge, whichever is less, need be deployed. - The remainder of the equipment which is not deployed must be included in a comprehensive training and maintenance program. Credit will be given for deployment conducted during training. The maintenance program must ensure that the equipment is periodically inspected and maintained in good operating condition in accordance with manufacturer s recommendations and best commercial practices. All inspection and maintenance must be documented by the owner. Objectives: - Demonstrate ability of facility personnel to deploy and operate equipment. Certification: - Self Certification Verification: - Verification to be conducted by appropriate oversight agency during periodic site visits. Records: Retention: - 3 Years (USCG) 5 Years (EPA) Location: - At facility. Evaluation: - Self Evaluation. Credit: - Plan holder may take credit for this exercise when conducted in conjunction with other drills as long as all objectives are met and a proper record generated. Likewise, credit may be taken for an actual spill response when these objectives are met and a proper record generated. Note: If a facility with facility-owned equipment also identifies OSRO equipment in their response plan, the OSRO equipment must also be deployed and operated in accordance with the equipment deployment requirements for OSRO owned equipment /13

51 UNANNOUNCED DRILLS COAST GUARD & EPA REGULATED FACILITIES Applicability: - Response Plan holders within the Area Frequency: - A plan holder is not required to participate in a federal government initiated unannounced drill if they have participated in an unannounced federal or state oil spill response drill within the last 36 months. Initiating - USCG, EPA Authority: Participating - Response Plan holders Elements: Scope: - Unannounced exercises to be limited in scope, number and duration. - Unannounced exercises will be limited to a maximum of four exercises per Area per year - Exercises will be limited to a maximum of four hours in duration. - Exercises will involve response to an average most probable discharge scenario. - Exercise will involve equipment deployment to respond to spill scenario. Objectives: - Conduct proper notifications to respond to unannounced scenario of an average most probable discharge. - Demonstrate equipment deployment is: -- timely -- conducted with adequate amount of equipment for scenario -- properly deployed Exercise - The Area Committee will meet annually to discuss details of the Preparation: unannounced exercises to be conducted in the Area for that year. At this annual meeting, the Area Committee will consult with the initiating agency (USCG, EPA, RSPA, MMS) to discuss the scenario development and requirements for each exercise. Certification: - Initiating agency ( USCG, EPA, RSPA, MMS ) Verification: - Initiating agency Records: Retention: - 3 Years ( USCG, RSPA, MMS ) 5 Years ( EPA ) Location: - At facility Evaluation: - Evaluation to be conducted by initiating agency. Credit: - Credit may be taken for an actual spill response when these objectives are met and a proper record generated. Plan holders participating in this exercise may also take credit for notification and equipment deployment exercise /13

52 APPENDIX 1. FACILITY SPECIFIC INFORMATION 1.1 Facility Description... A Facility Plot Plan... A Valve Identification... A Product Information... A LIST OF CONTACTS 2.1 Key Personnel - Qualified Individuals... A Federal, State, Local Officials... A Response Contractors... A EQUIPMENT LIST AND RECORDS 3.1 Facility Response Equipment... A COMMUNICATIONS PLAN 4.1 Communications Plan / Equipment... A SITE-SPECIFIC SAFETY AND HEALTH PLAN 5.1 Site Safety Plan... A Material Data Safety Sheet... A DOCUMENTATION FORMS 6.1 Spill Report / Notification Form... A Facility Inspections... A Training... A SIMPLIFIED CLEANUP TECHNIQUES... A7-1 APPENDIX 05/13

53 APPENDIX 1 FACILITY SPECIFIC INFORMATION 1.1 Facility Description Figure 1 is a location map. Figure 2 is an area plan with tank farm detail. Figure 3 is a piping plan. The Yukon Koyukuk School District ( YKSD ) operates the Kaltag School ( School ) and its related oil storage tanks and piping which supply fuel for school heat and backup power generation. Diesel fuel is the only oil stored in bulk. Total annual fuel throughput is about 18,000 gallons. The School fuel system ( Facility ) consists of four vertical tanks in the community tank farm which provide total nominal storage capacity of 34,100 gallons, and a 2,500 foot pipeline which supplies a 6,000 gallon intermediate tank at the School. The community tank farm also contains fuel storage tanks that are separately owned, operated, and maintained by the City of Kaltag and Kaltag Cooperative. Fuel is delivered to the community tank farm by barge via a 1,000 foot marine pipeline which is individually operated by the three tank farm operators when fuel is being delivered to their respective tanks. The community tank farm, marine pipeline, and the School pipeline and intermediate tank were installed in 1998/9 as part of a State of Alaska bulk fuel upgrade project. The upgrade project included preparation and submittal of a Facility Response Plan ( FRP ) for the community tank farm as a single, co-located, cooperatively operated entity. The 1999 FRP was in place until 2013, at which time YKSD elected to prepare this FRP which specifically covers the School fuel system components and regulatory requirements for which YKSD is responsible. The School receives fuel by marine delivery normally once. There is no dock, therefore the barge beaches or anchors near shore and extends its hose to the marine pipeline fill point connection (header). All School fuel is transferred by pipeline to the intermediate tank at the School. Pipeline transfers to the intermediate tank at the School generally occur once a month. No marine fueling is conducted from the Facility. Bulk Storage Tanks / Secondary Containment The School bulk fuel storage consists of the following tanks: TANK NO. LOCATION DIAMETER X HGHT-LENGTH VERTICAL / HORIZONTAL PRODUCT REHAB OR INITIAL SERVICE DATE CAPACITY (GALS) ST-11 TANK FARM 9.5 x V DIESEL 1998/9 7,300 ST x ,100 ST x ,800 ST x ,900 Tank Farm Total: 34,100 IT-1 SCHOOL 7 x 17 H DIESEL 1998/9 6,000 School Total 40,100 The original date of purchase and/or service of the vertical tanks are unknown. In 1998 they were relocated from existing local service and entirely refurbished. Each vertical tank was drained, cleaned, and visually inspected, internally and externally, for evidence of corrosion and for weld integrity. Necessary repairs were made and new appurtenances installed. The tanks A1-1 05/13

54 were sandblasted and painted. The intermediate tank package was purchased and installed in The four vertical tanks are BIA type tanks that are equipped with normal and emergency vents, water draw valves, three-inch fill connections, and gauges. They are positioned on treated timbers on grade. The 6,000-gallon intermediate tank at the School is a horizontal, double wall, skid mounted UL tank. It is equipped with liquid level gauge, float actuated fill-limiting valves and high level shut off switches that stop the transfer pump. The vertical tanks are within the community tank farm which is a diked and lined impound approximately 85 x 65. It is surrounded by an earthen dike approximately two-feet high. The impound floor and dike walls are covered with a fuel resistant liner that is covered with gravel. The net capacity of the impound is approximately 65,000-gallons, which provides containment for the contents of the largest tank plus more than 12-inches of freeboard for precipitation. Drainage within the impound is to a collection sump at the southeast corner of the tank farm. Accumulated storm water is removed from the sump with a hand or portable pump. Secondary containment for the intermediate tank at the School is provided by its double wall structure and redundant overfill protection devices. All transfers to the intermediate tank are manually initiated and visually monitored by an operator who has direct access to pump shutdown controls. Marine Pipeline, Fill / Distribution Piping, Transfer Pipe to Intermediate Tank Fuel is delivered to the School storage tanks via a three-inch marine pipeline that extends about 1,000 feet from the tank farm to a marine fill point header located about 75 feet from the river. The pipe is buried, schedule 80, welded steel that is coated and cathodically protected with magnesium anodes. The marine header is a capped camlock fitting with three-inch check and ball valves. A steel, two-barrel drip pan (spill box) is positioned beneath the header. The header is protected by steel bollards. Within the tank farm the fill and distribution pipelines pass through ball valves located where the piping enters/exists the impound. The valves are used to isolate each pipeline that is not in service. Tank farm piping is two and three-inch schedule 40, black steel. Joints are welded, except for flanged and threaded joints that connect to valves and pumps. The tank farm piping is equipped with steel flex connectors, pressure relief valves, check valves, and strainers. The storage tank fill/withdrawal connections are three-inch ball valves. Piping is secured with pipe straps to steel and timber supports. The transfer pipe from the tank farm to the School intermediate tank is welded two inch diameter steel about 2,500 feet in length. The pipe parallels the washeteria pipeline. It is above ground, except where it passes under roadways, where it is protected within an ABS culvert. Fuel is transferred to the intermediate tank by manually starting the transfer pump using controls mounted on the intermediate tank. The pipe is located away from vehicle driving areas except for the road crossings where it is buried in a carrier pipe. Security The School may receive, or transfer seven days a week. Normally transfers from the tank farm to the intermediate tank occur once a month. School personnel normally observe the intermediate tank during daily routine duties. The tank farm is normally observed daily by the other tank farm operators who conduct dispensing operations from tank farm. At least once a A1-2 05/13

55 month, the School Site Principal / Head Teacher, or designated alternate, is to conduct and document a thorough visual inspection of the entire School fuel system. Any fuel system discrepancies, leaks or potential discharge, or items which are in need of maintenance are to be reported to the YKSD Director of Facilities and Maintenance or the Maintenance Mechanic in Fairbanks. Leak detection is by visual monitoring or inventory discrepancy. There are no automated leak detection systems in the School fuel system.. An eight-foot high chain-link fence, topped with barbed wire surrounds the community tank farm. The intermediate tank and its transfer pump control panel are also enclosed by chain link fence. All entrance gates to fuel storage areas are to be closed and locked when the area is unattended. Bottom-penetration valves on storage tanks and transfer pipeline isolation valves at the entry/exit to the tank farm are to be closed and locked when transfers are not being conducted. Two pole mounted area lights illuminate the tank farm. Area lighting at the School provide some illuminate of the intermediate tank. Portable fire extinguishers are positioned at the entrance gates to the tank farm and intermediate tanks. Tanks are to be marked to identify type of fuel contained in the tank, tank capacity, and tank number. No smoking, warning, spill notification are to be posted. School spill response equipment is maintained in mechanical/generator room. Additional spill response equipment is to be maintained at the tank farm by the City and Kaltag Cooperative. AVEC also maintains spill response equipment at its power plant. In addition to this Facility Response Plan, the School also maintains a marine transfer Operations Manual, as required by the Coast Guard, and a Spill Prevention Control and Countermeasure Plan (SPCC) as required by the EPA. Tank inspection and testing procedures are addressed in the SPCC Plan. 1.2 Facility Plot Plan - Figure 2, page A Valve Identification - Figure 3, page A Product Information Diesel fuel is the product stored in bulk. A Material Safety Data Sheet (MSDS) for diesel fuel is in Appendix 5 of this FRP. Fuel is delivered to the tank farm normally once a year in tank barges that normally range in capacity to about 5,000 barrels and 150 feet in length. Only one barge at a time can deliver fuel to the tank farm. No marine transfers are conducted from the tank farm. A1-3 05/13

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L' 2 j iei ~ ;\ ~-, j,a, : j / j / j I 0 :w I, -, ~ Ni I /' //..., ',,! i l l f t i ~~-~ ~ ~ 1 u: rn '\ '\ ', I I I I /Ztll i ~ -I, ~ j /' ' : 2 j j I 1 j 9./') l_ 10 ~--, 1 r; -;~: u s SURVEY ~ i l! 4 I L...-; L..!.-l 1 \\ "' l,/ ;, : i t i...-~\v i 9 t I : f-7\7 i '\ No U ~! / ', ~'f., / j :,, U.S. SURVEY I,tSl_~' I! \.!_) \:. ~ ' ' ' ' ', I j I ', N 4485 I,./_;:..,- ' '-J..")t:l'' ' L '1.- '~ I j..., o. I..,... _..,...! 8 l 7 i :e--r -JlL./,_ '...! t :,... "'.. _ ; I : : "'smffi~.. --~.,, ', "Jot! i ', i r r..--<... i r l lt...j'j ~ ;,/ ~"--- \,, Jo l 3 i ', : 1 : -..., :1 : / ;---- ', ' I (...,., / I!...f i 1 I 1: 3 /,/ F~'\,,, I 2 I' If! /j Ill / ' '. ' J j '... I i I Q! f u.s. SURVEY i./.,,, }:, j I J;r:~ j '..:!.J i: No AMENDED /:! /.....,...., 1 ~~ ,! 2 'fl,/,._'-. '.,. j jc;; I lj /; // ~- '-f~'-<, : ;! I; 1./ / ' -~~,, I i I 2 /1 j::...,;.<\.. I 1.. j' I ~I r--. '- '- :v,..- f.%\ j, I~ I : / ' '::/' ' I I' : I - ' ' '.kat: '-....! d' / "" ;.) -" 1 i -~ r:v-- ir ~ '-'.i\ 1 y r.r-- 5- _ : 1,[. '-... / ~- / r LlL:J :,..,... '~..., /~l / 0! 3 \ 1 -~j i\1 ""'-..._ ',..fov f4 l 4 ' \, FJ! H ""-' &"<..._ / ,,l---.L J 2fL----- ~"1\,... "=. 't:.,j ~ SJRE.EI,!.~.----.I ",,JI T J f7\ I,... 10' is Ill"- ~ : ' H -::...: _. I U.S. SURVEY 1.;. ; jscttool No AMENDED '1 '1 m U.S. SURVEY : TRACT A.. ~ w No. 3772!- I ~~:~ ~~~ ~~I SAFETY AND ~~ : ill ~ 8 SPILL RESPONSE l, '1'1: : s...{ c. ~ :(( ~ \ U.S. SURVEY No <D ~ i j j j 1 i!! i I GOES UNDER / =~ MATE ~OCAnpN n~ F=FE.:===---- Jl 1 ~r;o ;;; -~--==rr==--========r:======rt:======:f' f== t===l't=====-- ""'- ~ -'F'' ~ 1 I. l u.s. SURIIEY I No I : i 7 9 ' i ~~~ I ~! ' I I i i./e---f-oh/e_-qhje---1 I o,.1. ~I j 'i' r I 1 J! ll ~~ lit : \ l' 87,2' 11 I I II II.1 ~ I v v. i! i j LEGEND FOUND 2 1/2" I!IIJI BRASS CAP IIONLINENT FOUND 1 1/2" ALIMNUW CN' FOUND ~/II IRON ROO -(> POWER POLE <>* IJQfT POL E- OUY ANCHOR IIOU.NID SliiUUTE DISH - OH/E - lmrhcad EL C'IlUC IJNE --*"-- CIWN LINK FENCE --F'--~lK j ---F--- UNDERGROUND FUEL 1..1 LOCATION APPROXII:IIlTE J [ ASS CIJ..VEIIT, ~ NOTED I DETAIL: TANK FARM SCALE: 1" = 20' FIGURE 2. AREA PLAN I TANK FARM DETAIL ~ ' NOTES 1. The purpose of this survey is to locate the Consolidated Tonk Farm, the Dispenser Station, lrlorine Header, Washeteria/Power Plant Pipeline and the School Pipeline. 2. The underground pipeline from the Worine Header to the Con.olidated Tonk Form, os shown, is for grophlccll purpoaee only, exact location unknown. STATE OF ALASKA, DIVISION OF ENERGY AS-BUILT OF KALTAG BULK FUEL UPGRADES E~ l ~===e:q:u::ip:m:e:n:t==~~--~ ~~ ~I:i 9~!5 11.1<:< j~ ~~d~aa~w~n~~~=~~a2~----~w~.o~.~n~o:~~99 --t-ot ~

58 TO SCHOOL -----/1-- TO WASHET RIA ~OR 6 ATO MARINE HEADER I MECHANICAL SYMBOLS T PIPE aru C110N ---o ElBOW TURHED DO~ TOE OF DIKE ~TO DISPENSER --o ELBOW TURHED UP 1~1 f1dja.e C(lji C1Ql /FENCE ON TOP OF DIKE DISPENSING STATION rn==s--~\ i. L- r;f;! PRESSURE Rn.EF VN..VE N aleci( VN..VE 101 IIAU. YN..VE ~~~ SOlB«XD VN..VE ~ SlRIHR []] FLOW WEIER / 110:1 TANK /13 \ ~ SCHOOL 9800 GALLON It OIL TANK /14 SCHOOL 8900 GALLON /1 OIL CAI.ILOCK 1-1/2" MAlE ~ "--- ~ -~ak<sump J"-. TANK /2 CITY 15,000 GALLON /1 OIL ~ L...<:-11-l~J TYP!J!. ~ - TANK /8 CITY 8000 GALLON /1 OIL ~ 1101 I I I I I I I I I I I TANK /4 \ KALTAG COOP 7900 GALLON DIESEL TANK /5 KALTAG COOP 8900 GALLON GASOLINE.-YIOI!-11-:>---- J..., L.!J!. ~~ -c...j i!i r,vii'-'ir-!'- ~ +-J TANK /75 i J-1 ~ 3900 GALLON DIESEL (!,1 f'miit!@d CAJfALK 4e LAODER i ~t! 11. I trt r TANK /1 KALTAG COOP 25,000 GALLON GASOLINE TANK /9 KALTAG COOP 17,500 GALLON ~101 D/ES L TANK /10 KALTAG COOP 12,500 GALLON DIESEL ~ l b f \ J-l HIOI h p ~101 h ~ :==6 THE AREA SUBJECT TO COAST GUARD JURISDICTION IS THE MARINE TRANSFER AREA (PIPELINE AND HOSE) BEl\'VEEN THE VESSEL, OR WHERE THE VESSEL MOORS, AND THE FIRST MANIFOLD OR SHUTOFF VALVE ON THE PIPELINE ENCOUNTERED AFTER THE PIPELINE ENTERS ~E SECONDARY CONTAINME T AREA AROUND THE 8.LK STORAGE TANKS. EPA JURISDICTION EXTENes HINLAND" FROM THE FIRST VALVE IN THE TANK FARM.. I ( (6) VERTICAL. / BALL VALVE'S.../"' ~ ( ~~ 00 iii -o ~=r= ~~T ~1--tt. I 1 I I I ~0101: lk 'c i l/ ts: 1 I 1- TOE OF DIKE E~ HAND PUMP 0 E_NLJ~R~ED PIPING PLAN ~ (!) ~ c-.i 8 ~ I w "' It: ~ w ~ ~ C) TA~~ -~ ARM PIPING PLAN FIGU.,:.:.~ SCALE. 1 - PIN~ ~e~ PI c _i PLAN olil::c ~g~ A1--7 I I -RE 3. STATE OF ALASKA DIVISION OF ENERGY, KALTAG TANK FARM UPGRADE TANK FARM PIPING PLAN ~ 5 DRAWN BY: KK W.O. No: n.g:< I

59 APPENDIX 2 LIST OF CONTACTS 2.1 Key Personnel - Qualified Individuals Refer to Section page Federal, State, Local Officials Refer to Section page Response Contractors Refer to Section A2-1 05/13

60 APPENDIX 3 EQUIPMENT LIST AND RECORDS Section lists response equipment maintained at, and available to, the School. The operational status of all identified equipment is "ready for deployment." The equipment is to be inspected and inventoried monthly. It can be deployed with 30 minutes of notice to proceed. The equipment is adequate to respond to the average most probable discharge and to meet tier 1, 2 and 3 planning requirements. A Worksheet to Plan Volume of Response Resources for Worst Case Discharge is presented in Section A3-1 05/13

61 APPENDIX 4 COMMUNICATIONS PLAN 4.1 Communications Plan / Equipment The Incident Commander is responsible for setting up communications during a spill event. Verbal communication among cleanup personnel will be adequate in most cases. Communications with the Coast Guard, EPA, ADEC and others will be initiated and maintained by telephone. A log of all communications with agencies should be maintained. The log should include, at minimum the date and time, the person and agency contacted, and topics discussed. During marine delivery, a minimum of two radio handsets will be used for communication between vessel and facility personnel. Radio communication will be maintained continuously throughout all phases of the transfer operation. By agreement with the fuel supplier, the vessel, not the School, provides the required radios during marine transfers. Radios used during marine transfers are to be intrinsically safe and meet Class I, Division I, Group D standards. Coordination with Federal On-scene Coordinator (FOSC) Following initial agency notification, the Incident Commander will initiate necessary procedures to ensure communications and coordination of the actions with the predesignated Federal On-Scene Coordination (FOSC). These procedures may include but are not limited to the following: establishing open, continuous communications; identifying types of information that will be relayed to the FOSC (i.e. projected plans, accomplishments, complications); soliciting comments and recommendations from the FOSC, as well as resolving differences; and, having the FOSC attend and participate in spill management team meetings. A4-1 05/13

62 APPENDIX 5 SITE SAFETY PLAN 5.1 Site Safety Plan Section 3.0 presents information on spill history, potential spills, emergency shutdown systems, fire suppression equipment, evacuation plans, and personnel safety. In the event of a discharge, the Incident Commander on-site will serve as the initial safety officer. If determined necessary, an experienced safety specialist may be activated from the Public Health Service or contractors. In accordance with OSHA requirements (29 CFR, Part ), an incident specific safety plan will be developed for each hazardous substance release. An acceptable format for the safety plan is presented on the following page. 5.2 Material Safety Data Sheets A Material Data Safety Sheets (MSDS) for diesel fuel is included in this Appendix, following the Site Safety Plan. A5-1 05/13

63 INITIAL SITE SAFETY PLAN MINI SITE SAFETY PLAN FOR: DATE: PROJECT MANAGER: SITE SAFETY OFFICER: FOREMAN: CREW: SITE CHARACTERIZATION: SAFETY HAZARD(S): PRODUCT(S): CONCENTRATION: CHEMICAL(S): CONCENTRATION: PEL: PEL: WORK PLAN/SITE ACTIVITIES PLANNED: HEALTH EFFECTS & SYMPTOMS: PERSONAL PROTECTION REQUIRED?: LEVEL: SITE ZONES ESTABLISHED (ATTACH SITE MAP)? WHY? DECONTAMINATION REQUIRED? WHY? TRAINING REQUIRED: PHYSICAL EXAMS REQUIRED: CONTINGENCY PLAN: EMERGENCY NUMBERS: AMBULANCE: AIR MONITORING TO BE DONE: HOSPITAL: INTERVAL: SAFETY RULES AND SAFETY PLAN READY: DATE PREPARED: PLAN EXPIRES:

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