1.0 Introduction
Departments storing and using hazardous chemicals are responsible for the safe containment of those materials. Every effort should be made to prevent an accidental spill or release of a hazardous chemical. Personnel should be properly trained, procedures developed, and appropriate emergency equipment provided. Failure to incorporate preventive measures may result in the university becoming liable for emergency management and decontamination expenses associated with a hazardous material release incident. Environmental contamination can bring EPA citations and penalties for the university and individuals. All personnel working with hazardous chemicals at the boiler plant and emergency personnel should be familiar with this plan.
2.0 Scope
These procedures are designed to minimize hazards to human health, property, and the environment from unplanned releases of hazardous chemicals at the Boiler Plant. This plan is in compliance with OSHA's HAZWOPER regulations (1910.120).
3.0 Availability
The plan is kept in the Boiler Plant and in the Safety Office. Copies will be made available to employees within 15 days of a request.
4.0 Major Spills
Initial Response and Notification
1. Any incident which could endanger personnel, property, or the environment should be treated as a major spill. If you are unsure about the severity of the spill or the hazards are unknown, treat it as a major spill. In addition, any fires involving hazardous chemicals or spills that cause any injury such as unconsciousness should be considered a major spill.
2. The following are examples of spills that should be considered major:
| Type of Spill | Amoung | Examples |
| Extremely flammable liquids (flash point <0 F) | > 1 pint | ethyl ether |
| Flammable liquids (flash point <100 F) | > 1 quart | toluene |
| Combustible liquids ( flash point >100 F) | > 1 quart | mineral spirits |
| Highly toxic liquids | > 1 pint | acrylonitrile |
| Toxic liquids | > 1 quart | ammonia |
| Concentrated acids | > 1 gallon | sulfuric acid |
| Concentrated alkalis | > 1 gallon | lye solution |
| Concentrated Hydrofluoric Acid | any amount | Hydrofluoric Acid |
| Poisonous, reactive materials | any amount | cyanides, sulfides |
| Oxidizing agents | > 1 pound | concentrated nitric acid |
| Leaks from gas cylinders | uncontrolled | chlorine, acetylene |
3. Do not attempt to clean up a major spill. Only individuals who have received the 40-hour HAZWOPER training course and are part of an emergency response team should clean up major spills.
4. If flammable or combustible liquids are spilled, immediately turn off all sources of ignition.
5. Evacuate persons in the immediate vicinity of the spill. If occupants in the building are in danger, activate the air horn to evacuate the building. Evacuate to an upwind location for toxic gases. Assemble in a designated area well away from the building. Distances from the building will be determined from the DOT Emergency Response Guidebook based upon the type of spilled material. Individuals trained to at least the first responder operations level (Level II) will determine the evacuation distance.
6. Report the spill to the University Police Department. The Police Department will call the Safety Manager. If appropriate, the Police Department will also call the Vice President for Finance and Administration and the Assistant Vice President for Facilities. If deemed appropriate, the Vice President for Finance and Administration will notify the President.
7. Provide the following information and wait in a safe place for emergency personnel to arrive and direct them to the spill:
8. If you have been properly trained (at least Level III training ) and can do so without putting yourself in danger, don appropriate PPE and attempt to stop the leak or reduce contamination by quickly doing the following:
9. The Safety Office will obtain the MSDS during normal hours if the identity of the spill is known. The Police Department will obtain the MSDS after hours.
10. A Police Officer will proceed to the site and cautiously evaluate the situation while waiting for the Safety Manager. The officer will evacuate the building if there is clear danger to the occupants of the building. If the spill is clearly beyond the capabilities of the university to handle, the Police Officer will immediately call the Radford City Fire Department.
11. The Safety Office and Police Department will evaluate the hazards. The Safety Office will attempt to clean up the spill if it is within the capabilities of university personnel. Safety Office personnel will wear proper personal protective equipment based on the nature of the spill.
12. If the Safety Office cannot handle the spill, they will call the Radford City Fire Department and a spill response contractor.
13. The Safety Office will notify the City of Radford and Pepper's Ferry Treatment Authority as soon as possible, but within four hours, of an accidental discharge into the sanitary sewer system. This notification will include the location, type of waste, concentration and volume, and corrective actions being taken. A written report will be submitted within five days describing the incident and the measures taken to prevent a future occurrence.
Specific Emergency Procedures
1. The Police Director is the Campus Emergency Coordinator and has overall responsibility at the spill site until the arrival of the Fire Chief. The Police Director will ensure that appropriate emergency responders have been called.
2. The Chief of the Radford City Fire Department or his designate will be the initial senior emergency response official at the scene and direct the clean-up operation.
3. Until the arrival of the Fire Chief, the Safety Manager will serve as the Incident Commander for a hazardous chemical spill. The Safety Manager will also serve as the safety official at the site and will be familiar with the emergency plan, facilities, emergency equipment, hazardous materials, storage sites, and records. The Safety Manager has the authority to stop operations that pose an immediate threat to lives, property, or the environment.
4. The following monitoring equipment is available to the Safety Manager to take air samples to assess the spill and determine proper respiratory protection if needed:
5. The Radford City Fire Department in cooperation with university personnel will assess the severity of the spill, level of personal protective equipment needed, and implement appropriate emergency operations. If necessary, assistance will be requested from:
6. An evacuation of a building or the university may be ordered by the Fire Chief or the University Police Director. The evacuation plan for the university is in the Emergency Response Plan. Safe distances from the building will be determined from the ERG based on the material spilled. Safe distances will be determined by an individual trained to at least the first responder operations level (Level II).
7. Site security and crowd control to prevent entry into the hot zone will be provided by the Radford University Police Department.
8. Assistance with university facilities and equipment will be provided by Facilities Management.
9. As other emergency response teams arrive, the most senior emergency response official at the site will be in charge. All emergency responders and operations will be coordinated through this individual.
10. Spills requiring Level A or B protection will be handled by an outside hazardous materials team. SCBAs and chemical resistant suits will be worn. Spills requiring Level C or D protection may be handled by properly trained individuals from the Fire Department or Radford University. Proper PPE will be worn. The Personal Protective Equipment Program for the university is in the Appendices. Operations in hazardous areas will be performed using a buddy system.
11. Victims of a chemical spill will be taken to Radford Community Hospital.
12. Emergency medical treatment will be provided by the Radford Community Hospital EMS squad. First aid for emergency responders will be provided by Radford University Emergency Services (RUEMS).
13. Decontamination of victims, equipment, and emergency responders will be performed under the supervision of the Safety Manager in cooperation with the Fire Department and outside contractors. Individuals performing decontamination will wear proper PPE and be trained in decontamination procedures. PPE will be at the same level or one level below the emergency responders. Decontamination equipment is stored in the paint room next to the Allen Building.
14. The Safety Office will notify the National Response Center if a reportable quantity is released and file a report with the Department of Environmental Quality if required.
15. Immediately after the emergency, the Safety Office will ensure that recovered waste and contaminated materials are properly disposed.
16. Within a week of the incident the Safety Office will contact all parties involved in the incident and critique the emergency response. Necessary changes will be made to the plan.
5.0 Minor Spills
Initial Response and Notification
Specific Emergency Procedures
6.0 Training
7.0 Medical Surveillance
8.0 Drills
9.0 Hazardous Chemicals on site
Aboveground Storage Tanks (ASTs)
Two ASTs are located behind the boiler plant approximately 50 ft from the railroad tracks.
The two boiler ASTs contain 50,000 gallons each of fuel oil #2. The boiler tanks are double lined and have a pad catchment basin and an oil/water separator. The fueling pad catchment basin also has an oil/water separator. In addition, the tanks have a high-level switch that closes the flow control valve and shuts down the pump when activated. Each tank is surrounded by a secondary containment structure that has a capacity of 55,000 gallons.
Flammable Storage Room
The flammable storage room is located on the west side of the boiler plant adjacent to the main building. The following chemicals are stored in the building:
Chemical Storage Room
The chemical storage room is located in the main building. The following chemicals are stored in this room:
10.0 Spill Control Equipment
The following equipment is available for handling chemical spills:
Safety Office (emergency response van)
Boiler Plant
Introduction
The university produces many waste streams including hazardous waste, spills and leaks, water discharges, obsolete inventory, municipal solid waste, air emissions, energy waste, and evaporative losses. Pollution prevention emphasizes reducing or eliminating these wastes at the source through efficient use or conservation of raw materials and energy. This includes all pollution: hazardous and nonhazardous, across all environmental media (air, water, soil) and from all sources. The second priority is to reuse or recycle generated wastes. As a last resort, pollution should be disposed of in a manner that reduces risk to public health, safety, and the environment. This plan identifies current pollution prevention practices and recommends additional methods to reduce or eliminate wastes generated at the university. It is a written guide used to chart the progress of the program. Pollution preventions can protect the environment, save money, increase productivity, improve public image, create a healthier work environment, and reduce the risk of liability. The plan encourages the purchase of environmentally friendly products and technologies, use of less toxic products and materials, purchase of more products containing recycled materials, promotes efforts to prevent the generation of waste at the source and initiates recycling programs.
Organization
Pollution Prevention Coordinator
The pollution prevention coordinator is responsible for developing a pollution prevention plan for the university, establishing a pollution prevention team, conducting meetings, and ensuring the university is working toward its goal to reduce pollution. The pollution prevention coordinator acts as the key liaison to top management and strives to obtain inter-departmental cooperation and resources on a continuing basis. The Environmental Specialist will serve as the pollution prevention coordinator for the university.
Pollution Prevention Committee
A Pollution Prevention Committee will be organized to oversee the Pollution Prevention Program at the university. The committee will perform the following functions:
Members will include the Environmental Health and Safety Director, Environmental Specialist, Director of Housekeeping, Assistant Director of Facilities Management, and representatives from the Art Department, Chemistry Department, and Purchasing. The Committee will report to the Assistant Vice President of Facilities. Meetings will be held quarterly.
Employee Participation
In order to have an effective pollution prevention program at the university participation and cooperation of employees is essential. Employee support will be solicited through committees, suggestion programs, and training sessions. Employees who suggest pollution prevention measures that prove feasible will be recognized for their contributions. The form of recognition will be determined by the Pollution Prevention Committee.
Training
Ensuring that employees and students are adequately trained in pollution prevention principles is an important element of the pollution prevention program. The goal is to make employees and students aware of waste generation, its impact on the university and the environment, and ways waste can be reduced and pollution prevented. Training will be conducted by the Environmental Specialist and the Environmental Health and Safety Director.
Pollution Prevention Strategies
The overall goal of the Pollution Prevention Program is to significantly reduce the quantity and toxicity of pollution released and waste generated at the university. The following strategies are designed to achieve this goal:
Stationary Source Permit
VDEQ issued a permit of operation on July 29, 1996, to construct and operate five gas/distillate oil-fired boilers, two gas-fired boilers, three emergency diesel generators and three distillate oil storage tanks. This permit supersedes the permit dated January 12, 1979 and April 23, 1995 (as amended February 14, 1996.) The purpose of the permit is to ensure that air emissions from this equipment does not exceed specified limits.
Current Practices
1. Nitrogen oxide (NOx) emissions from boilers 1, 2, and 3 will be reduced by use of low NOx burners with external flue gas recirculation. These three boilers are currently under construction. Nitrogen oxide (NOx) emissions from boilers 4, 5, 7, and 8 (existing) will be controlled by use of low-NOx burners. Boilers 1, 2, 3, 4, and 5 are in the Power Plant. Boilers 7, and 8 are in Dedmon Center. The gap in the numbering sequence occurred because the emergency diesel generator is referenced as #6 in the old permit dated February 14, 1996. The new boilers are more energy efficient and part of the stack gases is returned to the boilers and burned a second time to reduce air emissions. A new permit is under review through VDEQ for a revision or modification for boiler #4 that should include the use of oil as a fuel source besides natural gas.
2. The permit states that air emissions compliance testing for the boilers will be done upon completion of construction, which has not occurred to date. No air emissions testing are required for the three emergency diesel generators and three distillate oil storage tanks. Three different sampling scenarios must be followed to comply with the permit.
a. The emissions testing will consist of Total Suspended Particulate, PM-10, Sulfur
Dioxide, Nitrogen Oxides, Carbon Monoxide, and visible emissions for boilers 1, 2,
and 3 (combined.)
b. The emissions testing will consist of Total Suspended Particulate, PM-10, Sulfur
Dioxide, Nitrogen Oxides, Carbon Monoxide, and visible emissions for boilers 1, 2,
3, 4, and 5 (combined.)
c. The emissions testing will consist of Total Suspended Particulate, Sulfur Dioxide,
Nitrogen Oxides, and visible emissions for boilers 7, and 8 (combined.)
3. The contractors doing the installation will perform the emissions testing. No periodic air emissions testing are required by the permit after the initial test. Emissions of pollutants will be calculated based on fuel consumption.
4. Emissions from the operation of boiler 1, 2, and 3 (combined) shall not exceed the limits specified below:
| Total Suspended Particulate | 3.2 lbs/hr | 0.8 tons/yr |
| PM-10 | 3.2 lbs/hr | 0.8 tons/yr |
| Sulfur Dioxide | 113.7 lbs/hr | 14.0 tons/yr |
| Nitrogen Oxide | 22.5 lbs/hr | 8.6 tons/yr |
| Carbon Monoxide | 22.0 lbs/hr | 8.6 tons/yr |
5. Emissions from the operation of boiler 1, 2, 3, 4, and 5 (combined) shall not exceed the limits specified below:
| Total Suspended Particulate | 3.3 lbs/hr | 0.9 tons/yr |
| PM-10 | 3.3 lbs/hr | 0.9 tons/yr |
| Sulfur Dioxide | 113.7 lbs/hr | 14.0 tons/yr |
| Nitrogen Oxide | 23.9 lbs/hr | 9.7 tons/yr |
| Carbon Monoxide | 23.1 lbs/hr | 10.2 tons/yr |
6. Emissions from the operation of boiler 7 and 8 (combined) shall not exceed the limits specified below:
| Total Suspended Particulate | Nitrogen Oxide | 0.13 tons/yr |
| Sulfur Dioxide | 8.4 lbs/hr | 1.3 tons/yr |
| Nitrogen Oxide | 2.4 lbs/hr | 0.7 tons/yr |
7. Because emissions are under one hundred tons per year, a Title V air permit is not required.
8. After the initial air emissions compliance test, visible emissions shall not exceed 10 percent opacities, except during one six-minute period in any one hour in which visible emissions shall not exceed 20 percent opacity from the #1 boiler stack (associated with boilers 1, 2, and 3) and the #2 boiler stack (associated with boiler 4.) Visible emissions from the #3 boiler stack (associated with boiler 5) and the #4 boiler stack (associated with boilers 7 and 8) shall not exceed 20 percent opacities, except during one six-minute period in any one hour in which visible emissions shall not exceed 60 percent. These conditions apply at all times except during start-up, shutdown, or malfunction. The visible emissions are to be determined by EPA Method 9 in reference to 40 Code of Federal Regulation Part 60, Appendix A. Another condition is the maximum sulfur content of the oil burned in the boilers shall not exceed 0.5 percent by weight per shipment.
9. Emissions testing from the boilers will determine if additional actions are necessary. If limits are exceeded, then measures will be taken to modify the process or reduction equipment will be installed such as a scrubber or bag-house to reduce emissions.
10. Visible emissions will be checked by the contractor when construction is completed. The Boiler Plant Supervisor will check visible emissions periodically. VDEQ will also check visible emissions quarterly.
11. The Power Plant produces a quarterly report for fuel consumption that is given to VDEQ. This report is used to detect if a possible fuel leak has occurred, and fuel consumption directly effects air emissions produced.
Recommendations
Fugitive Emissions
Fugitive emissions are caused by volatilization from open vessels, spills, shipping containers, and leaks from pumps, valves and building ventilation systems. Fugitive emissions are not vented or directed through a stack.
Current Practices
Recommendations
Chlorofluorocarbons (CFCs)
Radford University has developed a CFC Plan. The purpose of the plan is to reduce pollutants by reducing emissions of CFCs and HCFCs to the lowest achievable levels during the service, repair, or disposal of appliances at the university. The plan describes the university's preparation for the phaseout of CFCs. Strategies for maintaining, converting, or replacing existing equipment with appliances that use alternative refrigerants are described.
Current Practices
Recommendations
Wastewater
1. Radford University discharges wastewater into the Pepper’s Ferry Regional Wastewater Treatment Authority’s (PFRWTA) sewerage collection and treatment system in accordance with the conditions set forth in the permit issued on April 15, 1996. PFRWTA is a secondary treatment facility.
2. The following limitations and sampling requirements are imposed for Outfall 1 (last manhole on Clement Street at intersection with Adams Street) and Outfall 2 (manhole at Norwood Street and Muse Hall):
| Parameter | Limit | Frequency | Sample Type |
| Flow | 0.100 mgd | Continuous | Meter |
| Temperature | 120 degrees Fahrenheit | Weekly | Grab |
| pH (minimum) | 5.0 (standard pH units) | Weekly | Grab |
| pH (maximum) | 10.5 (standard pH units) | Weekly | Grab |
| BOD5 | 300 mg/l | Monthly | 24-hr composite |
| Total Suspended Solids | 250 mg/l | Monthly | 24-hr composite |
| Oil and grease | 100 mg/l | Monthly | Grab |
| Metals* | Semi-Annual | 24-hr composite |
The university shall not introduce any pollutant into the sanitary sewer system that causes interference with the operation of the Waste Authority.
* = During the months of October and March, sample wastewater discharge for the following toxic metals: Cadmium, Chromium, Copper, Lead, Nickel, Silver, and Zinc.
3. On June 27, 1996, at a meeting between Radford University and the Water/Wastewater Utilities it was decided that Manhole 10 be included in the sampling scheme. Manhole 10 receives wastewater from the entire university. The following limitations and sampling requirements are imposed for Outfall 10 (under the Dedmon Center bridge):
| Parameter | Limit | Frequency | Sample Type |
| Flow | 0.100 mgd | Continuous | Meter |
| Oil and Grease | 100 mg/l | Monthly | Grab |
4. In October of 1993, Radford University performed a baseline survey of wastewater discharge from eight manholes by request of Water/Wastewater Utilities, City of Radford, and the Pepper’s Ferry Regional Wastewater Treatment Authority for 30 volatile organics, 57 toxic organics (acids, bases, neutral compounds), 19 pesticides, and 7 PCBs. Out of the 904 sample analyses, 52 samples had a detectable level, but were well below established guidelines. The remaining 852 sample analyses were below the detection limit.
5. On April 11, 1994, Radford University requested the City of Radford, Water/Wastewater Utilities for a change in the permit for Outfall 3, because of relocation of the Printing Department, a small darkroom, and a freshman Biology laboratory. On May 27, 1994, PFRWTA issued a notice granting permission to terminate the monitoring of Outfall 3. Based on an inspection of the facilities in question, wastewater monitoring was not required at the new facilities.
6. On June 9, 1994, Radford University requested the City of Radford, Water/Wastewater Utilities for a change of the permit. Based on analysis of monitoring between September 1993 and April 1994, Radford University requested the following changes to the Industrial Wastewater Discharge Permit: Outfall 4, Outfall 5, Outfall 6, Outfall 7, and Outfall 8 monitoring be terminated based on historical data that demonstrated levels below permissible limits. Therefore sampling did not justify the expense and manpower required to continue monitoring. On July 2, 1994, the City of Radford and PFRWTA agreed on the termination of monitoring of the above-mentioned outfalls, but to continue sampling of Outfalls 1 and 2.
7. The following strategies were used to reduce oil & grease, BOD, TSS, and TIS from Outfalls 1 & 2:
9. The boiler plant blows down 50-150 gallons of water per day into the sanitary system. Samples taken at the outfall next to the boiler have revealed no problems.
10. Back-flow preventers were installed on the main water lines, main fire protection systems, water coolers, outside spigots, and sinks where chemicals are used.
Recommendations
Water Conservation
Current Practices
Recommendations
Underground Storage Tanks
Current Practices
Recommendations
Above Ground Storage Tanks
Current Practices
Recommendations
Municipal Solid Waste
Current Practices
Recommendations
Hazardous Waste Program
Current Practices
Recommendations
Hazardous Waste Reduction
Alternatives to hazardous waste disposal are needed because of concerns about the environment and the rising cost of land filling and incineration. One strategy that is increasingly being used is to reduce the volume of waste generated. Waste reduction saves money, reduces the amount of hazardous materials in the work place, and decreases the amount of pollutants in the environment. Waste reduction activities include the use of smaller quantities, using less hazardous materials, and the redistribution of surplus chemicals that may become waste. Recognizing the importance of waste reduction, Virginia Hazardous Waste Regulations require that generators take steps to minimize the amount and toxicity of chemical waste.
Current Practices
Recommendations
Toxic Chemicals
Current Practices
Recommendations
The RRRs to waste minimization are reduce, reuse, and recycle. Reduce means to use less, reuse is to use a material again without changing it, and recycle is to put material back into service once it has been changed. The RRRs minimize the amount of waste produced at the university and reduce disposal problems. They are also less polluting, save money, and are more energy efficient than taking new materials from the environment.
Reduce
The best way to practice pollution prevention is to eliminate and minimize the generation of waste through source reduction. To reduce waste output, reducing waste input is necessary. Reducing material input lowers the amount of resources used at the university and reduces the amounts of waste landfilled or recycled.
Current Practices
Recommendations
Reuse
Reusing materials minimizes waste generation and reduces costs.
Current Practices
1. The following types of reuses are currently in place:
Recommendations
Recycling
Recycling is the last stage in the waste minimization process. Recycling uses discarded material as a raw material for producing a new product. The purpose of recycling is to save resources and reduce the solid waste stream leaving the university. Radford University started a voluntary recycling program in 1990 and has recycled approximately 1,500 tons to date.
Current Practices
Recommendations
The purpose of energy conservation is to reduce air pollution produced by the generation of electricity. Energy consumption is a prime source of air pollutants that contribute to acid rain, smog, and global warming. By conserving energy and using more energy-efficient equipment the university can reduce pollution and save money.
Cooling and Heating
Current Practices
Recommendations
Lighting and Appliances
Current Practices
Recommendations
Transportation
Current Practices
Recommendations
To determine potential sources of pollution at the university the following list was generated of possible chemical users, associated waste streams, energy conservation practices, and recyclables.
All Departments
Art Department
Biology Department
Boiler Plant
Bowling Alley
Campus Card and ID
Carpenter Shop
Central Warehouse
Chemistry Department
Communication Department
Electrical Shop
Food Services
Health Services
Housekeeping
HVAC
Geography Department
Geology Department
Landscaping
Laundry
Mason/Plaster
Material Management
Motor Pool
Nursing Department
Paint Shop
Photocopy
Planning and Construction
Plumbing Shop
Pool
Police Department
Printing Services
Psychology Department
Student Life and Student Newspaper
Steam Tunnels
Theater Department
Assessment Form
The purpose of the assessment form was to determine existing pollution prevention activities in each workplace. This survey formed the basis for identifying pollution prevention opportunities at the university. The following form was disseminated campus-wide:
Pollution Prevention Form
The provisions of House Joint Resolution 453, adopted by the 1995 General Assembly, mandated that Pollution Prevention be created. Subsequently, the Department of Environmental Quality requested that all state agencies comply, which includes Radford University. Pollution Prevention is the way of the future. Pollution Prevention can save money, lower operating costs, improve public image, create a healthier work environment, reduce the risk of liability, and protect the earth for generations to come. Therefore, Radford University’s Environmental Health & Safety Department has established this checklist to evaluate your work area. Please fill out all information as soon as possible and return to Mr. Ross Roberson, P.O. Box 6909. Any questions concerning this mater should be direct toward Mr. Ross Roberson, Environmental Inspector at extension 5855 or Mr. Tom Smithwick, Safety Director at extension 5860. Thank you for your time.
NAME:
DATE:
PHONE:
FACILITY RESPONSIBILITIES:
JOB DESCRIPTION:
Check the chemicals used or wastes generated at your facility:
| acids | air emissions | aluminum | ammonia | anitfreeze |
| asbestos | ballasts | bases | batteries | biological |
| brake fluid | car parts | bardboard | CFOs | clay |
| cleaners | detergents | disinfectants | fertilizers | film |
| fluorescent lights | food waste | fuels | glass | glues |
| grease | heavy metals | herbicides | infectious waste | inks |
| inorganics | mercury | metal waste | mineral spirits | muriatic acid |
| oil | paint | paper | photo chemicals | plastic |
| rags | scrap metal | sheet metal | silver | solvents |
| stains | strippers | toner cartidges | used filters | waste solvent |
| wood |
Are there any other chemicals used or wastes generated not listed above, if so list them?
Check types of recycling currently in practice at your facility?
| aluminum | antifreeze | batteries | cardboard | ballasts |
| film | fluorescent lights | oil | paper | silver |
| mercury |
Are there any other types of recycling currently in practice at your facility, if so list them?
What types of waste reduction is currently in practice at your facility?
What is in the future for your facility for waste reduction?
What types of recycling is in the future at your facility?
The following pollution prevention strategies were developed through inspections and interviews with departmental heads and supervisory personnel.
Art Department
Current Practices
Recommendations
Biology Department
Current Practices
Recommendations
Boiler Plant
Current Practices
Recommendations
Bowling Alley
Current Practices
Recommendation
Carpenter Shop
Current Practices
Recommendations
Chemistry and Physics Department
Current Practices
Recommendations
Communication Sciences and Disorders
Current Practices
Recommendation
Dedmon Center Pool
Current Practices
Recommendations
Electrical Shop
Current Practices
Recommendations
Electronic Machine Repair
Current Practices
Recommendations
Fashion Department
Current Practices
Recommendation
Food Services at Dalton Hall
Current Practices
Recommendations
Food Services at Muse Hall
Current Practices
Recommendations
Geology Department
Current Practices
Recommendation
Health Services
Current Practices
Recommendations
Housekeeping
Current Practices
Recommendations
HVAC Department
Current Practices
Recommendation
Jewelry Department
Current Practices
Recommendations
Landscaping
Current Practices
Recommendations
Mason/Plaster/Paint Department
Current Practices
Recommendations
Motor Pool
Current Practices
Recommendations
Planning and Construction
Current Practices
Recommendation
Plumbing Department/Steam Tunnels
Current Practices
Recommendation
Police Department
Current Practices
Recommendations
Printing Services
Current Practices
Recommendations
Psychology Department
Current Practices
Recommendations
Student Life and Student Newspaper
Current Practices
Recommendations
Theatre Department
Current Practices
Recommendations
Warehouse Services
Current Practices
Recommendations
1.0 Introduction
Chlorofluorocarbons (CFCs) released into the atmosphere can damage the ozone layer that protects the earth from the penetration of harmful ultraviolet radiation. Penetration of ultraviolet light can cause health and environmental concerns including increased incidences of skin cancers and cataracts and damage to crops and marine organisms. This rule is designed to reduce emissions of CFCs and HCFCs to the lowest achievable levels during the service, maintenance, repair, or disposal of appliances at Radford University. This program is in compliance with the refrigerant recycling requirements of Section 608 of the Clen Air Act of 1990, as amended on May 14, 1993, August 19, 1994, November 9, 1994, and July 24, 2003.
2.0 Definitions
Appliance-Any device that uses CFCs or HCFCs as a refrigerant.
High pressure appliance-Any appliance that uses a refrigerant with a boiling point between -50 and 10 C at atmospheric pressure. This includes but is not limited to: R-12, R-22, R-114, R-500, and R-502.
Low pressure appliance-An appliance that uses a refrigerant with a boiling point above 10 C at atmospheric pressure. This includes but is not limited to: R-11, R-113, and R-123.
Major repair-Repair that involves the removal of the compressor, condenser, evaporator, or auxiliary heat exchanger coil.
MVAC-Motor Vehicle Air Conditioner.
Service involving refrigerant-Any service (including repair or maintenance) in which the release of refrigerant from an appliance to the atmosphere can reasonably occur.
Small appliance-Products that are fully manufactured, charged, and hermetically sealed in a factory with 5 pounds or less of refrigerant. This includes refrigerators, freezers, room air conditioners, packaged terminal heat pumps, dehumidifiers, under-the-counter ice makers, vending machines, and drinking water coolers.
Very high pressure appliance-An appliance that uses a refrigerant with a boiling point below -50 C at atmospheric pressure. This includes equipment using R-13 and R-503.
3.0 Responsibilities
4.0 Technician Certification
5.0 Recovery and Recycling Equipment
6.0 Certification by Owners of Recovery/Recycling Equipment
7.0 Refrigerant Sales Restrictions
8.0 Prohibitions on Venting
9.0 Refrigerant Leaks
10.0 Service Practices
1. Before appliances are opened, the refrigerant in either the entire unit or the part to be serviced must be transferred to a system receiver or to a certified recovery/recycling machine.
2. Persons opening equipment, except small appliances and MVACs, must evacuate the unit to the following levels (in inches of mercury vacuum relative to standard atmospheric pressure of 29.9 inches of Hg):
| Type of Appliance | Recovery/recycling equipment manufactured before 11/15/93 | Recovery/recycling equipment manufactured after 11/15/93 |
| HCFC-22, containing less than 200 lbs | 0 | 0 |
| HCFC-22, containing 200 lbs or more | 4 | 10 |
| Other high pressure units, less than 200 lbs (CFC-12, -500, -502, -114) | 4 | 10 |
| Other high pressure units, 200 lbs or greater(CFC-12, -500, -502, -114) | 5 | 15 |
| Very high pressure units (CFC-13, -503) | 0 | 0 |
| Low pressure units (CFC-11, HCFC-123 | 25 | 25 mm Hg absolute |
3. Persons who simply add refrigerants to top-off appliances are not required to evacuate the systems.
4. The following exceptions to evacuation requiements are allowed:
a. If evacuation to the above levels is not possible due to leaks or the refrigerant would be substantially contaminated, the technician opening the appliance must:
b. If the repair is not major and evacuation to the atmosphere is not performed after repair, the appliance must:
5. Technicians evacuating small appliances such as household refrigerators and window air conditioners must:
11.0 Reclamation Requirements
12.0 Disposal of Appliances
13.0 Disposal of Refrigerants, Oils,. and Containers
14.0 Recordkeeping
15.0 Enforcement
1.0 Introduction
Purpose
The purpose of this Spill Prevention Control and Countermeasure/Oil Discharge Contingency (SPCC/ODC) Plan is to provide university personnel with information and guidance necessary to prevent oil and fuel discharges and to safely and properly respond to a spill incident, should one occur. This document has been formatted to meet both Federal requirements for SPCC Plans as specified in 40 CFR Part 112 and Virginia requirements for ODC Plans as specified in 9 VAC 25-91-10 et seq. The SPCC/ODC Plan also addresses the Virginia requirements for pollution prevention for aboveground storage tank (AST) systems.
Implementation
Spill prevention measures are to be implemented to reduce the likelihood of a harmful petroleum release to the environment. Spill response procedures are to be implemented to prevent and control any discharges of oil that should occur in accordance with Federal and State regulations. Harmful discharges of oil are prohibited by 40 CFR Part 110.9. Article 11 of the Virginia Water Quality Regulations require that all oil spills be contained and remediated.
Regulatory Background and Applicability
In December 1973, the United States Environmental Protection Agency (EPA) promulgated regulations which established procedures, methods, and equipment to prevent the discharge of oil from non-transportation-related facilities into or upon the navigable waters of the United States. These regulations, which are contained in 40 CFR Part 112, were issued pursuant to Section 311(j)(1)(c) of the Federal Water Pollution Control Act (as amended). These regulations require facilities to develop and implement a SPCC plan if any of the following apply:
In January 1992, Virginia Regulation 680-14-07 - Oil Discharge Contingency Plans and Administrative Fees For Approval became effective. This regulation was rescinded and subsequently reissued as part of 9 VAC25-91-10 et seq. The regulation establishes state requirements for the development of ODC Plans to protect the environment as well as public health and safety. These plans must establish procedures to prevent, detect, and respond to a worst-case discharge of petroleum from a University. These regulations apply to all facilities in Virginia with an aggregate above ground petroleum storage capacity in excess of 25,000 gallons.
Definitions
Spill Event-A discharge of oil, as defined in 40 CFR Part 110.1, which includes, but is not limited to, any spilling, leaking, pumping, pouring, emitting, emptying, or dumping (40 CFR Part 110, Section 110.1).
Harmful Discharge-Discharge of such quantities of oil to navigable waters or shorelines which (a) violates applicable water quality standards, or (b) causes a film or sheen upon or discoloration of the surface of the water or beneath the surface of the water or upon adjoining shorelines (40 CFR Part 110, Section 110.3). Harmful discharges of oil are prohibited by 40 CFR Part 110.9.
Reportable Quantity–A reportable quantity represents the minimum quantity of material spilled that must be reported to a regulatory agency when released. Federal and sate definitions of reportable quantities for oil releases are as follows:
Sheen-An iridescent appearance on a water surface (40 CFR Part 110, Section 110.1).
Sludge-An aggregate of oil and any other matter of any kind in any form other than dredged spoil having a combined specific gravity equivalent to or greater than water (40 CFR Part 110, Section 110.1).
Navigable Water-Navigable waters are defined in 40 CFR Part 116.2 as "waters of the United States, including territorial seas," including but not limited to the following:
Emergency Levels–The Radford University Emergency Operations Plan defines three levels of emergency situations as summarized below:
Emergency Event Level 1 is normally a minor or isolated event that can be responded to or quickly resolved by campus police, regional law enforcement, and or fire department using internal resources or limited external assistance.
Emergency Event Level 2 are events or emergencies that have or may have the potential to affect all or part of the RU campus and may require assistance from off campus agencies such as fire department, police, city, state, or federal departments.
Emergency Event Level 3 may be classified as a campus, regional, state, or national emergency that affects the campus and surrounding community and has the capacity to threaten or adversely affect life, health, and or property on or near the Radford University Campus.
Certifications
Facility
This Spill Prevention Control and Countermeasure and Oil Discharge Contingency (SPCC/ODC) Plan shall be implemented to commit staff and resources to prevent, control, and counteract the effects of spills or discharges of oil or oil products in order to minimize hazards to human health and the environment. This SPCC/ODC Plan has been prepared in accordance with 40 CFR Part 112 - Oil Pollution Prevention and 9 VAC 25-91-10 et seq. - Facility and Aboveground Storage Tank (AST) Regulation. This Plan shall, as required by law, be made available to the Regional Administrator or his duly authorized representative during normal working hours. I am at a management level with authority to commit the resources necessary to implement this plan and hereby approve it.
Signature:
Date:
Name: Jorge Coartney
Title: Director, Facilities Operations
Engineer
I hereby certify that I have examined the facility, and, being familiar with the provisions of 40 CFR Part 112, attest that this SPCC/ODC Plan has been prepared in accordance with good engineering practices.
Signature:
Date:
Name: Ian D. Shaw, P.E.
Virginia Registration No. 034023
2.0 Facility Information
General Facility Information
Facility Name: Radford University
Mailing Address: P.O. Box 6909
Radford, Virginia 24142
Street Address: 501 Stockton Street
Radford, Virginia 24142
Owner/Operator: Radford University/Commonwealth of Virginia
Phone Number: (540) 831-7790
University Normal Working Hours: Typically 24-hours a day, seven days a week. Actual manned hours at the Boiler Plant, Dedmon Center, and Facilities Management varies based upon system demand.
Contact Name: Safety Director
Location
The university is located within the City of Radford, Virginia. The Boiler Plant is located off E. Main St (U.S. Route 11) between the street and the Norfolk Southern Railway Company tracks. The Dedmon Center is located at the end of University Drive to the north of E. Main St. Both the Boiler Plant and Dedmon Center are located on flat land to the south of the New River that comprises a portion of the river’s flood plain. Both facilities are situated above the 100-year flood level.
Description
Radford University operates AST systems at three areas: the Boiler Plant, the Dedmon Center, and the Facilities Management area. An Underground Storage Tank (UST) system is also operated at the Facilities Management area.
Boiler Plant
Two 50,000-gallon aboveground No. 2 fuel oil tanks (tank #1 closest to building, & tank #2) are located at the Boiler Plant.
The Boiler Plant occupies a small area between E. Main St., the University Street Bridge, and Norfolk Southern Railway Company tracks/right-of-way. Boilers at the facility are used to generate steam for heating, cooking, and various other operations at the University. Natural gas is the primary boiler fuel. However, No. 2 fuel oil is stored at the facility as back up boiler fuel and as fuel for an emergency generator. The Boiler Plant has two oil/water separators which treat storm water runoff from the AST system prior to discharge to a storm drainage ditch. One separator is associated with the tank truck unloading area and the other is associated with the tank and piping secondary containment systems.
Dedmon Center
A 10,000-gallon aboveground No. 2 fuel oil tank (tank #3) is located at the Dedmon Center. The Dedmon Center is situated on flat land along the bank of the New River amid various athletic fields. A natural gas fired boiler system is present at the Dedmon Center for heating. As with the Boiler Plant, No. 2 fuel oil is stored as a back up boiler fuel and as fuel for two emergency generators.
Facilities Management
A 2,000-gallon aboveground diesel fuel tank (tank #4), a 500-gallon aboveground used oil tank (tank #5), and a 10,000 gallon underground gasoline tank are located at Facilities Management. The Facilities Management area is located on a bank above the New River floodplain.
Total Oil Storage
Aboveground: 112,500 gallons
Underground: 10,000 gallons
Spill History
No reportable spills have occurred at the university within the past year.
3.0 Responsibilities
Boiler Plant
The Boiler Plant operators are responsible for the day to day operation and maintenance of the oil storage tank systems at the Boiler Plant and Dedmon Center. These tasks include routine inspections; maintenance of the tanks, piping, and containment systems; coordination of fuel deliveries; and initial response to spill events as appropriate.
Motor Pool
Motor Pool personnel are responsible for the day to day operation and maintenance of the oil storage tank systems at the Facilities Management Area. These tasks include routine inspections; maintenance of the tanks, piping, and containment systems; coordination of fuel deliveries; and initial response to spill events as appropriate.
Safety Director
The Safety Director is responsible for coordinating training efforts, coordinating periodic reviews/updates to the SPCC/ODC Plan, notifying regulatory agencies as required, serving as liaison between internal departments and external agencies, and coordinating waste disposal.
Campus Police
Any major spill will be reported to the university police dispatcher. A police officer will confirm the spill while waiting for the Safety Director to arrive.
Emergency Coordinator (EC)
The University Emergency Coordinator, serving as the Incident Commander should a release occur, is responsible for emergency actions and notifies outside agencies for assistance. The EC will also initiate the Emergency Operations plan and call members of the Emergency Operations Center if necessary.
Facilities Management
Facilities Management will provide and coordinate the resources to assist in operation and maintenance of the storage tank systems and to respond to a spill event as circumstances require.
Notifications
The following individuals are authorized to make required notifications and to implement containment and clean up actions and to ensure that response actions are undertaken in accordance with applicable Federal, state and local requirements.
Regulatory Notifications and Waste Disposal
Primary: Safety Director
Office: 540-831-7790
Coordinator of Emergency Actions and Outside Agencies/Contractors
Primary: Todd Branscome, Emergency Coordinator
Office: 540-831-7155
Alternate 1: Colleen Roberts, RU Chief of Police
Office (24hr): 540-831-5500
Alternate 2: Larry Brown, Captain
Office (24hr): 540-831-5500
4.0 Facility Assessment
Spill Scenarios and Worst Case Discharge
There are several circumstances that could potentially lead to oil spills at Radford University. Appendix A summarizes possible spill scenarios resulting from equipment failure, worst-case spill volumes, and the location to which the spill would likely drain. Most spill situations will result from leaks at valves, pipe connections, etc. and will typically involve a relatively small quantity of product released. However, a catastrophic tank failure could result in the release of a large quantity of oil that could impact human health, physical property, and the environment. Both the volume of the material spilled and the location to which the spilled material flows determine the actual severity of spill.
As shown in Appendix A, the worst-case discharge for the Boiler House is a rupture of one of the two 50,000 gallon tanks at the Boiler Plant. Based upon a sloshing factor of 22-percent, the actual volume potentially escaping containment would be 11,000 gallons. The worst case discharge associated with tank filling is assumed to be 2,000 gallons based upon the use of tanker trailers with a single compartment volume not exceeding 2,000 gallons. However, the most typical release that could occur during transfer would involve small quantities when hoses are connected/disconnected. The bulk of any material spilled during transfer would be contained at the transfer areas or in spill containment buckets on the tanks.
Evaluation of Containment and Diversion Structures
Appendix A also provides a description the containment and diversionary structures for the potential equipment failures described in the previous section. In accordance with 40 CFR 112.7 (d) university management has determined that use of the containment and diversionary structures will be capable of controlling typical spill events. Should a spill occur that escapes a containment system, the spill response measures specified in this plan will be implemented to minimize any impacts.
Facility Drainage
Boiler Plant
Any spilled material or runoff from the Boiler Plant ASTs will flow to a storm water drainage ditch approximately 50 feet to the north of the ASTs. Spills could reach the ditch by the following scenarios:
Dedmon Center
Any spilled material or runoff from the Dedmon Center AST will flow to the storm drain system for the Dedmon Center Complex as listed below:
Facilities Management
Any spilled material or runoff from the Facilities Management area will flow into two curb inlets (north and south of the tanks) and on to a storm water detention basin located north of the facility. This basin discharges to a ditch on the north side of Stockton Street and flows approximately 1800 feet through a sediment control basin to the New River.
Bulk Storage Tanks
The aboveground oil tanks at Radford University are constructed of steel and are compatible with the products they store and the conditions of storage. The tanks meet the requirements of UL 142 and the general requirements of NFPA 30. All aboveground storage tanks are equipped with secondary containment structure to control spilled material as listed in Table 1. The underground storage tank at the Facilities Management area is constructed of fiberglass and meets regulatory requirements for underground fuel tanks. Each tank is also equipped with various fail-safe devices as listed in Table 1.
Dikes
Drainage of rainwater from the AST dikes is performed using the following procedures:
Transfer Operations and Pumping
Fuel oil is transferred from the Boiler Plant and Dedmon Center ASTs to the boilers and emergency generators via aboveground steel pipe systems. All supply lines are operated on suction from fuel pumps on the various pieces of equipment. A containment system is provided for the Boiler Plant piping which directs any oil leaks to the tank containment oil/water separator system. Fuel is transferred from the Facilities Management gasoline, diesel, and oil tanks as follows
General guidelines used by the university are as follows:
Tanker Unloading Rack
The tanker unloading racks at both the Boiler Plant and Dedmon Center consist of a single nozzle located adjacent to the product transfer pump and the AST(s). The product transfer pumps are also used to transfer fuel from the tankers to the AST(s).
At the Boiler Plant the tankers park on a concrete apron that is sloped to a sump. The sump drain is closed while transfer is in progress. The transfer pump and related equipment is constructed on a steel skid with spill containment that drains back to the tanker apron.
Tanker trucks park in a service area at the Dedmon Center that slopes to a trench drain. A slide gate is placed into the drain outlet prior to transfer. The transfer pump and nozzle is located within a small concrete berm within the main AST containment dike.
Tanker trucks park adjacent to the Diesel Fuel AST and Gasoline UST during filling. Both tanks are equipped with spill containment and overfill protection systems.
During transfer warning signs or traffic cones are placed around the tanker to prevent vehicle departure before complete disconnection of transfer lines. Additionally, all drains and outlets on the tanker are checked prior to line disconnection to avoid spills.
Natural Resources at Risk
An evaluation of sensitive areas in the vicinity of Radford University was performed by reviewing the USGS quadrangle and information on natural resources and historic areas provided by the Virginia Department of Game and Inland Fisheries, Virginia Department of Conservation and Recreation, and the Virginia Department of Historic Resources. The location of any water intake stations located along the New River was confirmed, as well as public and/or private wells. A summary of this information is provided below.
The New River is located to the north of Radford University and flows within ±1/4-mile of the various oil storage tanks. Various natural resources and municipal services that could be affected by a spill are associated with the New River. The Department of Conservation and Recreation's Division of Natural Heritage reported that one endangered species; the Virginia fringed mountain snail (Polygyriscus virginianus), and two species of concern, the green floater (Lasmigona subviridis) and the hellbender (Cryptobranchus alleganiensis) are documented within the vicinity of Radford University. The Virginia fringed mountain snail habitat is generally restricted to limestone fragments mixed with clay soil. The green floater, a freshwater mussel, and the hellbender, an aquatic salamander, have been documented in the New River. A specific habitat location for these species near Radford University has not been documented.
The Department of Historic Resources (DHR) reported numerous archaeological sites near Radford University. There are six identified archaeological sites in the vicinity of the Facilities Management Area and the Dedmon Center. There are another 10 archaeological sites along the New River within five river miles of Radford University.
According to the Montgomery County Health Department, the City of Radford is supplied by a public water system. A file search conducted by the Health Department identified no other public or private water supply wells that would be impacted by an oil release from the University. Water intakes for both the City of Radford and the Blacksburg, Christiansburg, VPI Water Authority are located on the New River. The City of Radford water intake is located greater than two miles upstream of Radford University. A pumping station is located near Radford University; however, the pumping station nor the water intake would be influenced by a release from the facility. Based on the Virginia Water Quality Standards, the section of the New River that a discharge from the facility would enter is the New River Basin Section 2b. The Blacksburg, Christiansburg, VPI Water Authority water intake is located approximately 4.3 miles downstream from Radford University.
Based on recent subsurface site investigations, site reconnaissance, and the United States Geological Society (USGS) topographical map for the site, depth to groundwater is estimated to be approximately 25-50 ft below grade. No open conduits to groundwater exist and the soils generally have a surface layer of dark brown and brown loam and subsoil of yellowish red clay that extends to a depth approximately five feet below ground surface. Based on the relative impermeability for the surface soils in the area and the short response time (60-min.) for the spill response contractor (LCM) to recover any released product, groundwater impact from a release should be negligible.
As noted, there are natural and municipal resources that may be influenced in the event of a release at Radford University. The spill response actions outlined in this plan will be implemented in an effort to prevent oil from reaching the New River and to minimize any impact to the New River and its resources should a release to the river occur.
5.0 Prevention and Preparedness
Material Handling
Material handling procedures have been implemented to reduce the likelihood of a spill during product transfer operations. The following is a portion of the University’s standard operating procedure for the receipt of fuel oil at the Boiler Plant and Dedmon Center.
The same general procedure is used at the Facilities Management Area. However, fuel is either pumped/discharged directly from the tanker to the diesel fuel and gasoline tanks or directly pumped from the used oil tank by a used oil hauler. Any material spilled during transfer will be contained and collected.
Inspections, Testing and Records
Routine inspection, testing, and preventive maintenance procedures have been implemented at the Boiler Plant and Dedmon Center to identify potential problem situations before a release can occur. University personnel will review and document the inspection of the oil storage tanks and equipment using the forms located in Appendix B and as described below. Boiler Plant personnel will keep completed forms on file for a minimum of five (5) years.
Inspections
The following daily and weekly inspections will be performed at the Radford University oil storage tanks. While inspecting, assure there is sufficient light to view all sides of the equipment. Any problems identified during the inspection shall be noted in the comment section of the form along with measures taken to correct the problem.
Daily Inspection: A brief visual inspection of the tank systems including the tanks, containment, pipes, valves, and transfer areas will be performed each day that the areas are manned. The Facilities Management UST will be inspected to the extent possible by checking manways and adjacent groundsurface. These daily observations will prevent an oil spill or leak from going unnoticed and will aid in identification of potential equipment failures. A record of these inspections will be noted on the Daily Inspection Form (PDF).
Weekly Inspection: All tank system components will be inspected more thoroughly on a weekly basis using the Weekly Inspection Checklist (PDF).
Testing
In addition to daily and weekly visual inspections, periodic integrity testing of the aboveground tank and piping systems is required. Tank integrity testing consisting of visual inspections and/or non-destructive shell thickness testing are required. A formal visual inspection and/or non-destructive inspection should be performed every 5 years. Inspection and/or testing procedures should follow those outlined in American Petroleum Institute (API) standard 653, Tank Inspection, Repair, Alteration, and Reconstruction or similar testing protocols. Such testing procedures could include thorough internal inspections, external inspections, and/or ultrasonic shell thickness testing.
The Facilities Management area UST is subject to leak detection testing as required by UST regulations. Pipeline pressure testing is also required at five-year intervals in accordance with the general provisions of NFPA 30. That is, the lines shall be subject to a hydrostatic test at 150-percent of the maximum working pressure or a pneumatic test at 110-percent of the maximum working pressure.
Preventive Maintenance
In the event that defects are detected during the course of the above inspections/testing or if an oil discharge is detected facility personnel will:
Recordkeeping
All inspection forms, and testing results will be kept on file at the Boiler Plant for a minimum of five (5) years.
Leak Detection
Radford University has implemented a leak detection-monitoring program for its oil storage tanks to detect any potential release to groundwater. As all aboveground tanks and piping are off the ground surface, the daily visual inspection program will also serve as the leak detection-monitoring program at these facilities. As previously noted, a leak detection-monitoring program has been implemented for the Facilities Management UST system as required by UST regulations.
Note: As all aboveground tanks and associated piping are off the ground surface, no inventory
records for the ASTs are required to be kept and reconciled for pollution prevention
purposes.
Security
The oil storage facilities are well lit including all product transfer areas, and the bulk storage tanks. Starter controls on pumps in non-operating or standby status are locked or electrically isolated in the off position. The Radford University Police Department periodically patrols the facilities and Boiler Plant and Facilities Management personnel will report unauthorized entry or suspicious activity to the University Police. As an additional security measure, a camera system monitors the storage tanks at the Boiler Plant.
Training
Those personnel who may be involved in an oil spill prevention and response have received appropriate training as listed below:
In addition to the above training, Facility Management personnel including the Safety Manager and Boiler Plant personnel will review the SPCC/ODC Plan on at least an annual basis. This training will include a review of the spill prevention, notification, and response procedures included in the plan, a review of any spill incidents during the past year, and review of any changes in the SPCC/ODC Plan.
Response Exercises
Periodic announced and unannounced emergency response exercises will be performed as part of the spill preparedness program. These exercises present an emergency response scenario and challenge the participants to respond using the concepts developed during the training process. Outside of a real emergency, a simulated emergency is the most effective process for evaluating the emergency response plan. The objectives and purposes of these exercises include the following:
The various types of exercises conducted include communications drills, tabletop exercises, and full-scale response exercises (involving public agencies as appropriate). These drills may be unannounced and will be designed to evaluate the ability of personnel to complete the following:
Plan Review
Internal Reviews
The SPCC/ODC Plan must be periodically reviewed and amended in accordance with Federal and State Regulations. The plan must be amended whenever a significant change at the Boiler Plant, Facilities Management, or Dedmon Center occurs. Significant changes may include the following:
At a minimum the following review frequency shall be followed:
Any amendment to the SPCC/ODC Plan for physical changes to the facility or improved spill controls as noted above must be certified by a registered professional engineer.
Regulatory Agency Reviews
Environmental Protection Agency (EPA) reserves the right to amend the SPCC/ODC Plan and DEQ reserves the right to modify/deny approval of the Plan as described below.
6.0 Spill Response
Notification of Release
University Personnel
Level 1 Emergency
Level 2-3 Emergencies
Regulatory Agencies
Local Police and Fire Department
Radford University has an agreement with the City of Radford Fire Department that the Fire Department will assist the University in spill response activities when needed. Under such circumstances the Chief of the Radford City Fire Department will serve as the senior response official directing the response effort. The Radford City Police Department may also be notified of significant spills that cannot be controlled by University Personnel. The City of Radford Fire and/or Police Department spills local police and fire department should be notified if any of the following criteria are met:
Norfolk Southern Railway Company
The Norfolk Southern Railway Company (NS), Virginia Division Chief Dispatcher (540-981-4739) shall be notified of any spills that reach the railroad right-of-way and/or when response actions carry over to the right-of-way. The Chief Dispatcher can then direct and control train traffic as needed to facilitate response actions.
Emergency Response Contractors
General Spill Response Procedures
A suggested procedure for response to a spill event is presented below. Personnel responding to a spill will assess the release prior to the start of any response action. Refer to the MSDS for proper material handling equipment, materials, and procedures. Aggressive actions such as attempting to stop the flow or cleanup procedures will be performed by properly trained individuals. Individuals at the university with proper training include Safety Office and Boiler Plant personnel.
The university maintains personal protective equipment (PPE) and spill response equipment at several locations on campus. Those facility personnel trained for response actions have been trained in the use of PPE and spill response equipment.
Specific Spill Response Scenarios
Spills Limited to Ground Surface
General
Boiler Plant
Dedmon Center
Facilities Management
Oil Spills to Storm Drains, Ditches, or Surface Water Bodies
General
Boiler Plant
Dedmon Center
Facilities Management Area
Incident Termination
The emergency is terminated when the situation is manageable, and there is no longer a discharge or threatened discharge of any materials. Termination of the incident will be made by the Emergency Coordinator at the university in consultation with the Safety Director. The magnitude and duration of emergency response will depend on a variety of factors including the quantity of material released, the extent of the impact, and threat to property, human health, and the environment. Follow up cleanup measures may be required by federal, state, and/or local government agencies to address impacted soil, surface water, shorelines; and/or groundwater.
Disposal
All wastes generated during response activities must be recovered and reused or otherwise disposed of in accordance with federal, state, and local regulations. The Safety Office will handle the recovery and disposal of hazardous materials. General guidelines for handling typical waste streams generated during response activities are listed below. DEQ can be consulted as necessary for additional guidance. There is no time restriction for on-site staging of non-hazardous petroleum wastes. However, these materials should be removed as soon as practical. Any hazardous wastes generated typically must be removed from the site within 180 days.
Post Discharge Review
Within two weeks of a spill incident, a formal review will be performed with the Safety Director, Police Director, and appropriate University staff. This post discharge review will be conducted to evaluate the cause of the spill, the success and/or failure of the response measures utilized and to identify possible actions to prevent recurrence. Information resulting from this review will be used to improve and/or update the Plan if needed. A Hazardous Materials Incident Report (Appendix B) will be completed at this time and will document the spill and countermeasures taken. The form will be maintained on file at the Safety Office and the appropriate facility for five years.
Boiler Plant
50,000 gal #2 Fuel Oil ASTs
Description/ Secondary Containment: Horizontal, cylindrical, double-walled steel ASTs with steel saddles. Tanks are situated in separate concrete containment dikes with capacities of 60,000 gallons. Each dike is drained with a normally closed valve (PIV) through an oil/water separator.
Fail Safe Devices: Each tank is equipped with a level gauge and high level alarm.
Description of Discharge: Tank overfill, slow line/valve leaks, or failure of tank/lines.
Max. Vol./Rate of Discharge: 50,000 gallon gradual to instantaneous discharge with 11,000 gallons escaping the dike.
Spill Direction: Spilled material will flow into grate inlets feeding into a storm drainage ditch or directly to the ditch
Fuel Oil Unloading Area
Description/ Secondary Containment: Concrete area sloped to sump that is closed during transfer with a volume of 1200 gallons. Transfer pumps are located on a steel skid that drains to the unloading area.
Fail Safe Devices: The transfer system includes an automatic high level shut off.
Description of Discharge: Transfer hose/piping leak or failure of transfer equipment/tanker.
Max. Vol./Rate of Discharge: 2000 gallons gradual to instantaneous discharge with up to 1000 gallons escaping containment.
Spill Direction: Spilled material will flow into grate inlets feeding into a storm drainage ditch.
Dedmon Center
10,000 gal. #2 Fuel Oil AST
Description/ Secondary Containment: Horizontal, cylindrical, steel AST with steel saddles. Tank is situated in concrete containment dike with a capacity of 12,000 gallons. The dike is drained with a normally closed valve.
Fail Safe Devices: Each tank is equipped with a level gauge and high level alarm.
Description of Discharge: Tank overfill, slow line/valve leaks, or failure of tank/lines.
Max. Vol./Rate of Discharge: 10,000 gallon gradual to instantaneous discharge with 2200 gallons escaping containment.
Spill Direction: Southeast to trench drain to storm sewer or east to curb inlet to storm sewer.
Facilities Management
10,000 gal. Gasoline UST
Description/ Secondary Containment: Double-walled fiberglass tank.
Fail Safe Devices: Tank is equipped with overfill protection, spill containment basin, and leak detection system.
Description of Discharge: Tank overfilling.
Max. Vol./Rate of Discharge: 50 gallons instantaneous.
Spill Direction: To curb inlets, to detention basin, to New River.
2,000 gal. Diesel Fuel AST
Description/ Secondary Containment: Horizontal, cylindrical, double-walled, steel AST with integral secondary containment dike mounted on steel skids.
Fail Safe Devices: Tank is equipped with a level gauge and overfill protection system.
Description of Discharge: Tank overfill, slow line/valve leaks, or failure of tank/lines.
Max. Vol./Rate of Discharge: 2,000 gallons gradual to instantaneous with up to 440 gallons escaping containment.
Spill Direction: To curb inlets, to detention basin, to New River.
500 gal. Used Oil AST
Description/ Secondary Containment: Horizontal, rectangular, double-walled steel AST with steel skids.
Fail Safe Devices: Tank liquid level is visible during filling.
Description of Discharge: Tank overfill, slow line/valve leaks, or failure of tank/lines.
Max. Vol./Rate of Discharge: 500 gallons gradual to instantaneous.
Spill Direction: To curb inlets, to detention basin, to New River.
Oil Transfer Area
Description/ Secondary Containment: Paved areas adjacent to tanks.
Fail Safe Devices: Diesel fuel tanks equipped with overfill protection and spill prevention equipment.
Description of Discharge: Transfer hose/piping leak or failure of transfer equipment/tanker.
Max. Vol./Rate of Discharge: 2000 gallons gradual to instantaneous discharge with up to 1000 gallons escaping containment.
Spill Direction: To curb inlets, to detention basin, to New River.
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| Agency/Organization | Telephone Number | Person Contacted | Date/Time | Initials |
| Fire Department/Rescue Squad | 911 | |||
| Department of Emergency Management | (800) 468-8892 | |||
| DEQ West Central Regional Office | (540) 562-6700 | |||
| National Response Center | (800) 424-8802 | |||
| EPA Region III | (800)-438-2474 | |||
| Emergency Response Contractor: LCM Corporation | (800) 774-5583 | |||
| Local Emergency Plan Commission (LEPC) | (540) 731-3617 | |||
| Public Water Supply | N/A | |||
| New River Valley Medical Center | (540) 731-2000 | |||
| Natural Resources Downstream: | New River | |||
| Wildlife Refuge: | N/A | |||
| Norfolk Southern Railway | 540-981-4739 | |||
| Park: | N/A |
The person performing notifications during a discharge should be prepared to give the facility name, phone number, facility location (street address or directions), city or county, name of person in charge, facility mailing address, estimate of the volume discharged, type of product, source of discharge, name of the water body affected or threatened, weather conditions, any injuries, or evacuations, and what emergency containment has been undertaken.
Please see the PDF of the Daily Inspection Form.
Please see the PDF of the Weekly Inspection Form.