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====== 3.7.2	Oil Spill Prevention Control and Countermeasures Plan ======


Wesleyan University has developed an Oil Spill Prevention Control and Countermeasures plan to comply with state and federal regulations.  This plan will be used to implement preventive measures and in the event of an emergency involving any oil storage facility or tank.  The most recent version of this plan is attached.
 
===== Wesleyan University  =====
===== Oil Spill Prevention Control and Countermeasures Plan =====

 =====



==== 1.0	 Introduction ====

Title 40 of the Code of Federal Regulations in Part 112.7 (40 CFR 112.7) requires that facilities with a potential to discharge oil to a navigable water, and with either an aggregate aboveground oil storage capacity in excess of 1,320 gallons, or one container of oil with a capacity of more than 660 gallons; or underground storage in excess of 42,000 gallons prepare a Spill Prevention, Control, and Countermeasures (SPCC) Plan.  The purpose of the SPCC Plan is to minimize the potential for oil discharge into or upon the navigable waters of the United States and their adjoining shorelines. The definition of oil includes, but is not limited to, fuel oils, vegetable oils, and mineral oil dielectric fluid (MODF) used in oil-bearing electrical equipment. Discharge includes, but is not limited to, the potential to spill, leak, pump, pour, or emit.  Discharge, as defined by the regulations, does not include an oil discharge authorized under a current National Pollutant Discharge Elimination System (NPDES) permit.

This Plan describes the activities conducted by Wesleyan University to comply with SPCC requirements at the campus located in Middletown, Connecticut.  This SPCC Plan was prepared in accordance with 40 CFR 112.7.
==== 1.1	General Information ====

Wesleyan University is a liberal arts University situated in Middletown, Connecticut.  The university was established in 1831 with strong curricula in the physical and biological sciences as well as fine arts.  It is a private boarding facility, with approximately 3,300 students (undergraduate plus graduate).  Students live either in dormitories or in wood frame housing units adjacent to the core campus, many of which are owned and operated by the University.  Faculty and staff members may live in on-campus housing provided by the University. The central campus consists of a number of classroom, laboratory, athletic and administration buildings.  Many of the larger buildings on older portions of the campus are heated by steam produced at a central power plant.  Other buildings and residences are heated by either natural gas or heating oil.  Municipal water and sewer serve the campus and the entire surrounding area.

Oil storage areas and/or oil-bearing equipment at the campus include aboveground storage tanks (ASTs) and underground storage tanks (USTs) used for comfort heating applications, central power plant operations, and maintenance activities; oils and lubricants stored in the Physical Plant, Boathouse and Mill Street Garage; emergency generators with fuel tanks; deep fryers and stored cooking oil in the cafeterias; hydraulic elevators; and electrical transformers at some of the campus buildings.  Locations of oil storage areas and/or oil-bearing equipment are shown of Figures 1-10.  The maps included in Figures 1-10 also include addresses as a reference.  
  * Keep the victim quiet and try to maintain normal body temperature if the area is cool.
  
==== 1.2	Environmental Policy ====
 
Wesleyan University is committed to compliance with applicable environmental laws, regulations, and public policies dealing with the responsible use and preservation of natural resources. Wesleyan University has developed policies for the handling of hazardous and special wastes and the appropriate responses in the event of the release of injurious substances into the environment. It is every employee's responsibility to be aware of and sensitive to the ways that individual activities could impact the environment and to assist in ensuring the highest degree of environmental responsibility that can reasonably be attained.
==== 1.3	Spill Prevention Policy ====

It is the policy of Wesleyan University to conduct operations at the campus in an environmentally safe and responsible manner. To achieve this, Wesleyan University is committed to compliance with local, state, and federal environmental laws and regulations. This policy is intended to be implemented by an active safety program, well-designed and maintained facilities, trained employees, and planning for emergency response.

The SPCC Plan is designed to achieve two goals. The first is to minimize the potential for an oil discharge.  The second is to minimize the threat to the environment and human health in the event of a fire, explosion, or oil discharge.  This SPCC Plan documents the combination of systems and procedures to be used to achieve these goals.  It is the responsibility of all affected employees to be familiar with this SPCC Plan and follow the safety procedures.  In the event of an incident, it is the responsibility of all affected employees to use the emergency response and notification procedures.  These procedures are designed to ensure spills of materials that may pose a threat to human health and the environment are properly reported to appropriate agencies and remediated, as required by law.
==== 1.4	General Response ====
 
Wesleyan University’s general spill response procedures are included in Appendix A of the original document and are included here by reference.  The reporting and cleanup procedures are updated, as necessary (e.g., change in personnel, change of telephone numbers).  Regardless of the spill scenario, the general procedures presented in the flow chart in Figure 11 will be employed by Wesleyan University personnel.  Oil spill report forms needed to document a spill are located in Appendix B of the original document.
==== 1.5	Plan Organization ====

This SPCC Plan is divided into five sections plus Appendices and Attachments.  The Introduction, included in Section 1, discusses the purpose of this Plan, University policy, and general spill response procedures.  Section 2 presents specific information for oil storage tanks and oil-bearing equipment, including location, site description, site security, potential drainage pathways, spill prevention measures, and spill history.  Section 3 describes the spill prevention and response training Wesleyan University employees receive and standard operating procedures.  Descriptions of the inspection and record keeping procedures are in Section 4 and the Professional Engineer’s certification for this Plan is in Section 5.

Appendices to the SPCC Plan include the following and are incorporated by reference only:// 
Appendix A – Oil and Hazardous Material Spill Reporting and Cleanup Procedures; // 
Appendix B – Oil Spill Report Blanks; // 
Appendix C –Corrective Action Recommendations;// 
Appendix D – Monthly Tank System Inspection Checklists;// 
Appendix E – SPCC Plan Annual Review Sheet;// 
Appendix F	Receiving Oil Deliveries;// 
Appendix G	Contractor Emergency Procedures;// 
Appendix H	Draining Of Stormwater From Spill Containment Structures;// 
Appendix I	Containment Calculations;// 
Appendix J	Oil Spill Log Summary;// 
Appendix K	Storage Tank Registration Forms;// 
Appendix L	SPCC Plan Personnel Training List;// 
Appendix M	Cathodic Protection O&M And Survey Reports;// 

Attachments to this plan include the following and are included by reference only:

Attachment 1	Academic and Administrative Buildings Oil Inventory // 
Attachment 2	Undergraduate, Graduate and Faculty Residential Units Oil Inventory // 
Attachment 3	Central Power Plant Oil Inventory// 
Attachment 4	Physical Plant Maintenance Shop/ Mill Street Garage Oil Inventory // 
Attachment 5	Emergency Generators Oil Inventory// 
Attachment 6	Campus Cafeterias Oil Inventory// 
Attachment 7	Hydraulic Elevators Oil Inventory// 
Attachment 8	Electrical Transformers Oil Inventory// 
Attachment 9	Miscellaneous Storage Oil Inventory// 
 
===== 2.0  Oil Storage Areas and Oil-Bearing Equipment =====

Wesleyan University has defined nine principle areas where oil storage exists on campus, which are as follows:
•	Academic and Administrative Buildings,
•	Undergraduate, Graduate and Faculty Residential Units,
•	Central Power Plant
•	Physical Plant Maintenance Shop/ Mill Street Garage,
•	Emergency Generators, 
•	Campus Cafeterias, 
•	Hydraulic Elevators,
•	Electrical Transformers, and
•	Miscellaneous Storage.
Locations of these oil storage areas are shown in Figures 1-10 where the various maps include specific addresses.  Information for the major oil storage areas, including location, site description, oil quantities, site security, potential drainage pathways, spill prevention measures, potential spill scenarios, and spill history are provided separately in the subsections below.  

Wesleyan University has a complex network of various oil and petroleum products stored throughout the campus.  There are 327 comfort heating oil tanks in the Academic and Administrative buildings as well as Undergraduate, Graduate and Faculty residential units.

The Central Power Plant supports the largest individual tank storage capacities.  In addition, the Physical Plant Maintenance Shop and Mill Street Garage have various oil and fuel storage capacities for engine lubrication and fueling, other oil filled equipment, and waste oil.

There are several emergency generators, hydraulic elevators, and electrical transformers located throughout the campus that contain various amounts of oil specific to each unit.  Also included is a listing of cooking oil in the various cafeterias at the university and some campus-wide information on miscellaneous petroleum storage, where oil is stored or contained usually in amounts of one quart to 55 gallons.

URS Corporation has provided Wesleyan University with recommendations and corrective actions to improve the existing spill prevention and containment systems for oil storage areas and oil-bearing equipment.  
2.A	Academic and Administrative Buildings

==== 2.A.1	Site Location ====


The Academic and Administration Buildings include approximately 50 buildings and are located throughout the campus.  The academic buildings consist of the Arts, English, Theatre, Humanities and the Sciences.  The administrative buildings include Admissions, Career Resource Center, Infirmary, and Public Safety.

Within each of these buildings, or directly outside there are numerous oil storage tanks to accommodate the oil use requirements of each area.

==== 2.A.2	Site Description ====


Fuels in the Academic and Administration Buildings are typically stored in 275-330 gallon tanks in the basements of these buildings to supply the local heating furnaces for comfort heating to the buildings.  Normally, the Central Power Plant supplies these buildings with steam heat.  However, these local furnaces are usually working during the shut down season of the Central Power Plant, which typically runs from May – August of each year.

The ASTs are constructed of steel, which is compatible with the stored # 2 fuel oil.  There are 29 ASTs located within the Academic and Administration Buildings.  Generally, the tanks are raised on steel legs, which rest directly on the floor of the basement.  Fill ports and vents are located outside the buildings for the local fuel contractor to supply as necessary.  The tanks are normally equipped with visual sight gauges mounted on the top of the tanks.  In addition, the contractor utilizes tank vent whistles while filling to determine how full each tank is.
 
In addition to the ASTs located in the basements, there are several USTs at the university.  These tanks are also steel.  The Academic and Administrative Buildings have an additional fourteen (14) USTs.  There are seven (7) 1000-gallon USTs and four (4) 2000 gallon USTs.  In general these tanks also serve as fuel oil supplies for the local comfort heating furnaces.  There are also three (3) USTs that have an unknown size.  These are located at the Fayerweather Gym, 190 High Street and the Armstrong Annex.  Wesleyan University is addressing each UST and removing and/or replacing any UST as required.  

There is also a fuel dispensing station in the lower level of the Fayerweather Gym building.  The tank is a 275 gallon steel AST that is used by the Stonehedge contractor for use in fueling landscaping maintenance equipment.

==== 2.A.3	Operations ====


Fuels are dispensed from each tank automatically to each respective boiler.  Systems are inspected and maintained periodically by Physical Plant personnel.  The fuel dispensing station is manually operated and always under the supervision of Stonehedge personnel while dispensing fuel.

Fuel oils are delivered to the various locations by Wm. R. Peterson Oil Co. on a routine delivery cycle schedule or when requested by the University.  City Oil delivers diesel fuel.

The drivers of the fuel trucks are responsible for filling the tanks and have been instructed to notify Wesleyan University in the event of an emergency.  Also included in Appendix G of the original document are the contractor emergency procedures in the event a release of oil to the environment occurs.

==== 2.A.4	Site Security ====


The fuel storage areas are located in the basements of each of the respective buildings and serve to prevent unauthorized access to the tanks and equipment.  The USTs are closed and are only opened by authorized personnel.  The fuel dispensing station is inside the building and only used by Stonehedge personnel.  In addition, Wesleyan University officers patrol the campus and surrounding residential areas housing students 24 hours per day, 365 days per year. Security for the fuel storage areas appears adequate to prevent unauthorized access.

==== 2.A.5	Potential Discharge Pathways ====


Tanks that are in the basements of the buildings are considered contained within the building.  However, there are instances where floor drains may exist within the basement areas allowing oil to flow out the existing infrastructure.  The floor may also consist of dirt allowing a path directly to the soil and/or groundwater.  There are instances where there may be walk-out basements and a catastrophic release of oil may exit the building.  Wesleyan University is currently reviewing the condition, location and access to navigable waterways for each AST and determining each disposition.

The existing USTs that have the potential to leak may have an impact to the environment.  Wesleyan University is currently reviewing the condition integrity each UST and determining each disposition.

Where the fuel dispensing AST is located inside the building, and adjacent to the garage door, a large oil spill may reach the trench storm drain located directly outside the garage door.

==== 2.A.6	Spill Containment and Control Measures ====


As noted, generally, tanks that are in the basements of the buildings are considered contained within the building.  Wesleyan University has taken steps where there are floor drains present, to block those drains if feasible.  Where there may be water infiltration issues present, typical protocol is to provide secondary containment for the tank and associated piping where possible.  In addition, if the tank is near an exit doorway to the outdoors, incorporating a berm or slightly raised edge across the door is provided to contain the fuel within the building and prevent a potential release to navigable waters.  This raised edge should be a smooth transition so as not to create a tripping hazard.  ASTs and USTs must be managed in accordance with local, state and federal regulations.
 
While the contractor is filling the tanks, care is provided so that there is continuous surveillance of the filling operation.  The contractor is required to remain at the location until filling is complete.  Drip pans may be incorporated to minimize the possibility of any spill or release to the environment during filling operations.  It is recommended that temporary storm drain covers be used while filling tanks that are in close proximity to the drains and a spill containment kit be available on delivery trucks.

==== 2.A.7	Potential Spill Scenarios ====


There is a potential that a spill event could occur as a result of a failure of one or more of the following: systems, equipment, components, or personnel actions.  Potential spill sources are summarized in Table 2.A.1.

TABLE 2.A.1
POTENTIAL SPILL SCENARIOS

Source	
Type of Failure	
Maximum Spill	
Rate of Flow

Fuel AST	Over-fill	Dependent upon conditions during fill	Varies
	Rupture	Compartment Capacity (330 gallons)	Instantaneous
	Leakage	Compartment Capacity (330 gallons)	Varies

Fuel UST	Over-fill	Dependent upon conditions during fill	Varies
	Rupture	Compartment Capacity (2,000 gallons)	Limited by soil porosity
	Leakage	Compartment Capacity (2,000 gallons)	Varies

Truck Transfer

	Rupture	Truck Capacity (varies)	Instantaneous
	Leakage	Dependent on source of leakage	Varies
==== 2.A.8	History of Spills ====


There have been no records of reportable oil releases at the Academic and Administration Buildings on the Wesleyan University campus. 

==== 2.A.9	Recommendations for Improvements ====


Wesleyan University should consider implementing the improvements listed in Appendix C for the Academic and Administration Buildings.
==== 2.B	Undergraduate, Graduate And Faculty Residential Units ====

==== 2.B.1	Site Location ====


The Undergraduate, Graduate, and Faculty Residential Units are comprised of 256 units and are located throughout the campus.  The residential units are adjacent to the central portion of the campus and are located in the surrounding residential areas.

Within each of these buildings, or directly outside, there are numerous oil storage tanks to accommodate the oil use requirements of each area.

==== 2.B.2	Site Description ====


Fuels are typically stored in 275-330 gallon tanks in the basements of these buildings to supply the local heating furnaces for comfort heating to the buildings.  The Central Power Plant does not supply these buildings with steam heat.  Each residential unit operates independently to provide comfort heating locally.

The ASTs are constructed of steel, which is compatible with the stored # 2 fuel oil.  Some units have more than one tank at each location.  There are 262 ASTs located within the undergraduate, graduate and facility residential units.  Generally, the tanks are raised on steel legs that rest directly on the floor of the basement.  Fill ports and vents are located outside the buildings for the local fuel contractor to supply as necessary.  The tanks are normally equipped with visual sight gages mounted on the top of the tanks.  In addition, the contractor utilizes tank vent whistles to determine how full each tank is.
 
There are several USTs located next to some of the residential units.  These tanks are also steel.  The Undergraduate, Graduate, and Faculty Residential Units have an additional sixty-five (65) USTs.  There is one (1) 275 gallon UST, thirteen (13) 550 gallon USTs, one (1) 800 gallon UST, nineteen (19) 1000 gallon USTs, two (2) 2000 gallon USTs and one (1) 3000 gallon UST.  In general these tanks also serve as fuel oil supplies for the local comfort heating furnaces.  There is one (1) 20,000 gallon UST at the Butterfield University of Letters, and there are also thirteen (13) USTs at various locations that have unknown sizes.  Wesleyan University is addressing each UST and removing and/or replacing any UST as required.  

==== 2.B.3	Operations ====


Fuels are dispensed from the tank automatically to each respective boiler.  Systems are inspected and maintained periodically by Wm. R. Peterson Oil Co. on a contractual basis.  

Fuels are delivered to the various locations by Wm. R. Peterson Oil Co. on a routine delivery cycle schedule or when requested by the University.
 
The drivers of the fuel trucks are responsible for filling the tanks, and have been instructed to notify Wesleyan University in the event of an emergency.  Also included in Appendix G of the original document are the contractor emergency procedures in the event a release of oil to the environment occurs.

==== 2.B.4	Site Security ====


The fuel storage areas are located in the basements of each of the respective buildings that prevent unauthorized access to the tanks and equipment.

The USTs are closed and only are opened by authorized personnel.  In addition, Wesleyan University officers patrol the campus and surrounding residential areas 24 hours per day, 365 days per year. Security for the fuel storage areas appears adequate to prevent unauthorized access.

==== 2.B.5	Potential Discharge Pathways ====


Tanks that are in the basements of the buildings are considered contained within the building.  However, there are instances where floor drains may exist within the basement areas allowing oil to flow out the existing infrastructure.  The floor may also consist of dirt allowing a path directly to the soil and/or groundwater.  There are instances where there may be walk-out basements and a catastrophic release of oil may exit the building.  Wesleyan University is currently reviewing the condition, location and access to navigable waterways for each AST and determining each disposition.

The existing USTs that have the potential to leak may have an impact to the environment.  Wesleyan University is currently reviewing the condition integrity each UST and determining each disposition.

==== 2.B.6	Spill Containment and Control Measures ====


As noted, generally, tanks that are in the basements of the buildings are considered contained within the building.  Wesleyan University has taken steps where there are floor drains present, to block those drains if feasible.  Where there may be water infiltration issues present, typical protocol is to provide secondary containment for the tank and associated piping where possible.  In addition, if the tank is near an exit doorway to the outdoors, incorporating a berm or slightly raised edge across the door is provided to contain the fuel within the building and prevent a potential release to navigable waters.  The raised edge should be a smooth transition so as not to create a tripping hazard.  ASTs and USTs must be managed in accordance with local, state and federal regulations.

While the contractor is filling the tanks, care is provided so that there is continuous surveillance of the filling operation.  The contractor is required to remain at the location until filling is complete.  Drip pans are also incorporated to minimize the possibility of any spill or release to the environment during filling operations.  It is recommended that temporary storm drain covers be used while filling tanks that are in close proximity to the drains in the event a spill occurs during filling operations.

==== 2.B.7	Potential Spill Scenarios ====


There is a potential that a spill event could occur as a result of a failure of one or more of the following: systems, equipment, components, or personnel actions.  Potential spill sources are summarized in Table 2.B.1.

TABLE 2.B.1
POTENTIAL SPILL SCENARIOS

Source	
Type of Failure	
Maximum Spill	
Rate of Flow

Fuel AST	
Over-fill	
Dependent upon conditions during fill	
Varies
	
Rupture	
Compartment Capacity (330 gallons)	
Instantaneous
	
Leakage	
Compartment Capacity (330 gallons)	
Varies

Fuel UST	
Over-fill	
Dependent upon conditions during fill	
Varies
	
Rupture	
Compartment Capacity (20,000 gallons)	
Limited by soil porosity
	
Leakage	
Compartment Capacity (20,000 gallons)	
Varies

Truck Transfer


	Rupture	Truck Capacity (varies)	Instantaneous
	
Leakage	
Dependent on source of leakage	
Varies


==== 2.B.8	History of Spills ====


There have been no records of reportable oil releases at the Undergraduate, Graduate, and Faculty Residential Units on the Wesleyan University campus. 

==== 2.B.9	Recommendations for Improvements ====


Wesleyan University should consider implementing the improvements listed in Appendix C of the original document for the Undergraduate, Graduate, and Faculty Residential Units.
==== 2.C	Central Power Plant ====

==== 2.C.1	Site Location ====

The Central Power Plant is located on William Street on the east side of the campus.  The plant is situated such that the infrastructure reaches the Academic and Administrative Buildings supplying steam heat.  The plant has three oil tanks associated with the boilers located on the southeast corner of the plant.   The in-plant piping transfers for the USTs are located underground as is the piping for the AST since the power plant operates on a subsurface level.  

Fuel delivery for the power plant tanks is also located on the southeast corner of the plant.

==== 2.C.2	Site Description ====


There are three tanks located at the Central Power Plant that supply oil to the boilers.  There exists two (2) 30, 000 gallon #6 oil USTs and a 6,000 gallon #2 oil AST.  The 6000-gallon AST has a dedicated boiler and two other boilers can utilize the two 30,000 gallon tanks and each tank is alternated approximately each month.

The three USTs are constructed of double walled steel, which is compatible with the stored fuels.  The tanks also have interstitial monitoring for leak detection.  The two (2) 30,000 gallon fuel oil storage tanks were successfully retrofitted with an impressed current cathodic protection system in August of 1998.  The transfer piping travels below ground to the subsurface power plant. 

The 6,000 gallon #2 oil AST also has adequate secondary containment in an enclosed convault tank and the transfer piping travels below ground to the subsurface power plant to one of the dedicated Central Power Plant boilers.

The power plant tanks are equipped with high-level alarms to prevent overfilling and power plant personnel stick the tanks for inventory control each shift.

==== 2.C.3	Operations ====


Central Power Plant operators manage and maintain the plant 24 hours a day throughout the year.  During operation, there is always an operator in the area maintaining the central room, performing the necessary inspections and responding to any alarms.

The #6 fuel oil from the two 30,000 gallon tanks services two boilers and the #2 fuel oil from the 6,000 gallon tank provides oil to a single dedicated boiler.

Buckley Energy Group LTD provides #6 fuel oil to the two (2) 30,000 gallon USTs.  The Wm. R. Peterson Oil Co. provides #2 oil for the 6,000 gallon AST.  Their respective emergency response plans are included in Appendix G of the original document.

The filling operation includes gravity flow into the two 30,000 #6 oil USTs and pressurized #2 oil feeding into the 6000 gallon AST.  The power plant personnel are required to stick each tank each shift prior to filling to ensure there is capacity in the tank.  The tank inventory is noted in the daily logs for the power plant.

==== 2.C.4	Site Security ====


The fuel storage area for the Central Power Plant is operated under the responsibility of the power plant operators.  Unauthorized personnel are not permitted to engage in any activity regarding power plant operations.  In addition, Wesleyan University Public Safety officers patrol the campus 24 hours per day, 365 days per year. Security for the fuel storage area appears adequate to prevent unauthorized access.

==== 2.C.5	Potential Discharge Pathways ====


The 6000-gallon AST is provided with adequate secondary containment in the event that the tank should leak.  The USTs have been recently inspected and appear to be in good condition.  Discharge from the USTs would be directly into the ground.  Generally the #6 fuel oil would not initially travel very far due to its viscosity when it cools.

Approximately 20 feet from the tanks, a catch basin is located on William Street in a southeasterly direction.  

==== 2.C.6	Spill Containment and Control Measures ====

The 6000-gallon AST is a Convault tank provided with adequate secondary containment in the event that the tank should leak.  The two (2) 30,000 gallon fuel oil double wall storage tanks were successfully retrofitted with an impressed current cathodic protection system.  There is interstitial monitoring for leak detection also.

Caution is exercised each time a fuel delivery is in process.  The fuel delivery contractors have emergency response procedures and are required to coordinate with Wesleyan University power plant staff on all delivery schedules.

It is also recommended that the nearby catch basins be covered to prevent oil from reaching the drains in the event there is an oil release while filling the tanks.

==== 2.C.7	Potential Spill Scenarios ====


There is a potential that a spill event could occur as a result of a failure of one or more of the following: systems, equipment, components, or personnel actions.  Potential spill sources are summarized in Table 2.C.1.

TABLE 2.C.1
POTENTIAL SPILL SCENARIOS

Source	
Type of Failure	
Maximum Spill	
Rate of Flow

Fuel AST/UST	
Over-fill	
Dependent upon conditions during fill	
Varies
	
Rupture	
Compartment Capacity (30,000 gallons)	
Instantaneous
	
Leakage	
Compartment Capacity (30,000 gallons)	
Varies

Truck Transfer


	Rupture	Truck Capacity (varies)	Instantaneous
	
Leakage	
Dependent on source of leakage	
Varies


==== 2.C.8	History of Spills ====


There have been no records of reportable oil releases at the Central Power Plant on the Wesleyan University campus. 

==== 2.C.9	Recommendations for Improvements ====


Wesleyan University should consider implementing the improvements listed in Appendix C of the original document for the Central Power Plant.

==== 2.D	Physical Plant Maintenance Shop/Mill Street Garage ====


==== 2.D.1	Site Location ====


The Physical Plant Maintenance Shop is located on 56 Hamlin Street on the east side of the campus.  This shop supports the Wesleyan University infrastructure and crafts requirements for the campus.  The Mill Street Garage is located on the south side of the campus.  Mill Street Garage oil storage activities have been discontinued.  Activities previously conducted at the garage include vehicle maintenance performed by the Wesleyan University fleet staff, and grounds maintenance by Stonehedge contractors.

==== 2.D.2	Site Description ====
 

The Physical Plant has a 275- gallon AST and a 1000 gallon UST for comfort heating for two boilers at this location.

The Mill Street Garage has a 330-gallon comfort heating oil tank and a 275 gallon AST diesel oil fueling tank for equipment operation.  There is also a 275 AST gallon waste oil tank for the disposal of motor and waste oils.  All tanks are constructed of steel and are compatible with the stored oil/fuel.  Currently, contractors have emptied all ASTs at the Mill Street Garage.
 
==== 2.D.3	Operations ====


The Physical Plant is responsible for the operation and maintenance of the Academic, Administrative and Undergraduate wood frame building functions.  All crafts provide the expertise to manage ongoing operations and building functions.  Personnel are occasionally involved in minor oil functions throughout the campus.

The Mill Street Garage operations have been discontinued.  The Mill Street garage conducted a dual function with the Wesleyan Fleet Staff maintaining the university vehicles and the Stonehedge contracting group providing building and grounds maintenance.  Waste oil was produced at the garage during oil changing functions and Stonehedge personnel also conducted fueling of equipment.  These operations have been discontinued.

==== 2.D.4	Site Security ====


Doors to the shop and garage are closed and locked when Physical Plant personnel, Wesleyan Fleet Staff and Stonehedge contractors are not on duty.  The Mill Street Garage is also surrounded by a locked fence area and has an alarm system.  In addition, Wesleyan University Public Safety officers patrol the Physical Plant Maintenance Shop, Mill Street Garage and campus 24 hours per day, 365 days per year.  The Middletown Police Department also patrols the area surrounding the Mill Street Garage property.  Security for the Physical Plant Maintenance Shop and Mill Street garage appears adequate to prevent unauthorized access.

Lighting in the area provides adequate illumination to observe potential leaks of the stored oil.

==== 2.D.5	Potential Discharge Pathways ====

The basement in the Physical Plant contains the 275-gallon heating tank.  A catastrophic release could result in oil discharging down the floor drain.  Otherwise, the oil would be contained within the basement.  Also included in the Physical Plant is a 1,000 gallon UST.  A leak from this UST would go directly to the soil.

As previously noted, operations at Mill Street Garage have been discontinued.  The Mill Street Garage currently has three empty ASTs.  Inside the garage, there is a 330-gallon AST where oil, if present could discharge to a floor drain near by.  This tank is empty and currently out of service.

Directly outside, there is a 275-gallon AST inside a containment area used for waste oil. There is a roof awning covering the tank and containment area.  This tank is currently empty and out of service.

Outside the Mill Street Garage building is a fuel oil dispensing station.  The 275-gallon AST is inside surrounding containment and also has small roof covering the unit.  There is a catch basin located approximately 10 feet from the structure and a small stream is also located approximately 20 feet behind the structure.  This tank is empty and currently out of service.

During contractor fuel delivery, if a spill were to occur, local soil areas, small local stream and storm drains may be impacted.  

The existing UST that have the potential to leak may have an impact to the environment.  Wesleyan University is currently reviewing the condition integrity each UST and determining each disposition.

==== 2.D.6	Spill Containment and Control Measures ====


Generally, tanks inside the buildings are considered contained within the building.  Wesleyan University has taken steps where there are floor drains present, to block those drains if feasible.  Where there may be water infiltration issues present, typical protocol is to provide secondary containment for the tank and associated piping where possible.  In addition, if the tank is near an exit doorway to the outdoors, incorporating a berm or slightly raised edge across the door is provided to contain the fuel within the building and prevent a potential release to navigable waters.  The raised edge should be a smooth transition so as not to create a tripping hazard.

While the contractor is filling the tanks, care is provided so that there is continuous surveillance of the filling operation particularly around the fuel dispensing area and small stream.  The contractor is required to remain at the location until filling is complete.  Drip pans are also incorporated to minimize the possibility of any spill or release to the environment during filling operations.  It is recommended that temporary storm drain covers be used while filling tanks that are in close proximity to the drains.

 
==== 2.D.7	Potential Spill Scenarios ====


There is a potential that a spill event could occur as a result of a failure of one or more of the following: systems, equipment, components, or personnel actions.  Potential spill sources are summarized below.

TABLE 2.D.1
POTENTIAL SPILL SCENARIOS

Source	
Type of Failure	
Maximum Spill	
Rate of Flow

Waste oil & fuel AST	
Over-fill	
Dependent upon conditions during fill	
Varies
	
Rupture	
Compartment Capacity (330 gallons)	
Instantaneous
	
Leakage	
Compartment Capacity (330 gallons)	
Varies

Fuel UST	
Over-fill	
Dependent upon conditions during fill	
Varies
	
Rupture	
Compartment Capacity (1,000 gallons)	
Limited by soil porosity
	
Leakage	
Compartment Capacity (1,000 gallons)	
Varies

Truck Transfer


	Rupture	Truck Capacity (varies)	Instantaneous
	
Leakage	
Dependent on source of leakage	
Varies

==== 2.D.8	History of Spills ====


There have been no records of reportable oil releases at the Physical Plant Maintenance Shop and Mill Street Garage on the Wesleyan University campus. 

==== 2.D.9	Recommendations for Improvements ====


Wesleyan University should consider implementing the improvements listed in Appendix C of the original document for the Physical Plant Maintenance Shop and Mill Street Garage.

 
==== 2.E	Emergency Generators ====


==== 2.E.1	Site Location ====


The Wesleyan University diesel operated emergency generators are located in the following campus areas:  

•	William Street Hi/Lo Rise
•	Freeman Athletic Center
•	Central Power Plant

The William Street Hi/Lo Rise generator is located on the east side of the campus.  The generator and fuel tank are located inside the building in a secure room.  

The Freeman Athletic Center is located on the southwest corner of the campus and has an emergency generator located inside an enclosure east of the facility.  There are also two fuel tanks inside another enclosure that provide the fuel source for the emergency generator.

The Central Power Plant has an emergency generator located inside the power plant and is fueled by the 550 gallon UST.

==== 2.E.2	Site Description ====
 

The generators at the William Street Hi/Lo Rise, Freeman Athletic Center and Central Power Plant are diesel-powered systems.  There is a single separate 275-gallon AST that provides fuel to the emergency generator at the William Street Hi/Lo Rise.  

The generator at the Freeman Athletic Center has two (2) 275-gallon ASTs that provide fuel to the single emergency generator at this location.

The Central Power Plant operates with a 550 gallon UST.  All of the above tanks are constructed of steel and are compatible with the stored fuel.

==== 2.E.3	Operations ====


The emergency generators are used to provide electrical power to the William Street Hi/Lo Rise and Freeman Athletic Center should normal electrical distribution be disrupted.  Fuel is delivered to the generator by Wm. R. Peterson Oil Co. using tank trucks, when requested by the University.  Drivers of the fuel trucks are responsible for filling the tank, and have been instructed to notify Wesleyan University in the event of an emergency.  

Routine maintenance is performed by the Physical Plant for each of the generators.  This maintenance includes periodic starting and testing, oil changes and lubrication.

==== 2.E.4	Site Security ====


The generator's protective structures are kept closed and locked when Physical Plant personnel are not present.  Each generator is located in a separate enclosure enabling only authorized personnel entry.  In addition, Wesleyan University Public Safety officers patrol the campus 24 hours per day, 365 days per year.  Security for the emergency generators appears adequate to prevent unauthorized access.  Adequate illumination to deter vandalism and observe potential leaks is provided by University lighting.  

==== 2.E.5	Potential Discharge Pathways ====


There is a room in the William Street Hi/Lo Rise that contains the 275-gallon tank for the emergency generator.  A catastrophic release could result in oil discharging down the floor drain.  Otherwise, the oil would be contained within the room.  The Freeman Athletic Center also has two ASTs inside an enclosure adjacent to the building where oil generally would be contained within the building.  Also included in the Central Power Plant is a 550 gallon UST.  A leak from this UST system would go directly into the soil.

During contractor fuel delivery if a spill were to occur, local soil areas and storm drains may be impacted.  

==== 2.E.6	Spill Containment and Control Measures ====

As noted, generally, tanks that are inside the building are considered contained within the building.  Wesleyan University has taken steps where there are floor drains present, to block those drains if feasible.  Where there may be water infiltration issues present, typical protocol is to provide secondary containment for the tank and associated piping where possible.  In addition, if the tank is near an exit doorway to the outdoors, incorporating a berm or slightly raised edge across the door is provided to contain the fuel within the building and prevent a potential release to navigable waters.  The raised edge should be a smooth transition so as not to create a tripping hazard.

While the contractor is filling the tanks, care is provided so that there is continuous surveillance of the filling operation by the driver.  The contractor is required to remain at the location until filling is complete.  Drip pans are also incorporated to minimize the possibility of any spill or release to the environment during filling operations.  

 
==== 2.E.7	Potential Spill Scenarios ====

There is a potential that a spill event could occur as a result of a failure of one or more of the following: systems, equipment, components, or personnel actions.  Potential spill sources are summarized below.

TABLE 2.E.1
POTENTIAL SPILL SCENARIOS

Source	
Type of Failure	
Maximum Spill	
Rate of Flow

Fuel Tank	
Over-fill	
Dependent upon conditions during fill	
Varies
	
Rupture	
Compartment Capacity (275 gallons)	
Instantaneous
	
Leakage	
Compartment Capacity (275 gallons)	
Varies

Fuel UST	
Over-fill	
Dependent upon conditions during fill	
Varies
	
Rupture	
Compartment Capacity (550 gallons)	
Limited by soil porosity
	
Leakage	
Compartment Capacity (550 gallons)	
Varies

Truck Transfer


	
Rupture	
Truck Capacity (varies)
	
Instantaneous
	
Leakage	
Dependent on source of leakage	
Varies


==== 2.E.8	History of Spills ====


There have been no records of reportable releases at the emergency generators on the Wesleyan University campus.

==== 2.E.9	Recommendations for Improvements ====


Wesleyan University should consider implementing the improvements listed in Appendix C of the original document for the emergency generators noted above.
 
==== 2.F	Campus Cafeterias ====
 
==== 2.F.1	Site Location ====


There are seven Campus Cafeterias located throughout the university.  The locations are noted below:

•	McConaughy Hall
•	Davenport Campus Center
•	Butterfield A
•	Butterfield C
•	Downey Hall
•	Church Street
•	Westwings Restaurant
•	Neon Deli
•	Infirmary Kitchen

==== 2.F.2	Site Description ====
 

Vegetable oil, including salad oil and oil for deep fryers, is stored and used in the Campus Cafeterias.  Most kitchens have concrete block walls and a tile floor.  Oil is stored in individual containers (2.5- to 4-gallon capacity each).  Typically, ten 35-pound (approximately 4-gallon) containers of oil for the deep fryers and small quantity (approximately 2.5-gallon) containers of salad oil are stored in the kitchen.

Deep fryers are located at McConaughy Hall and Davenport Campus Center.  In addition at these two locations, a 55-gallon drum of used cooking oil is stored on the cafeteria loading dock.  The deep fryers and 55-gallon drums are constructed of steel and are compatible with the stored oil.

==== 2.F.3	Operations ====


Food preparation is subcontracted to a food handling service that is responsible for oil use in the cafeterias.  Oil is primarily used in deep fryers used for food preparation on campus. Salad oil is consumed on campus as part of meals prepared in the cafeterias.  

Oil in the deep fryers is changed regularly and the used oil is disposed in the used oil drums on the loading dock.  Used oil is removed from the facility by contractors and shipped for recycling.  Oil deliveries and removal are made on an as-needed basis, when the Kitchen Manager calls for a delivery or removal.  Some oil and grease is disposed during cleaning of dishes and equipment that is performed in the kitchen as part of the food preparation.  

==== 2.F.4	Site Security ====


Doors to the kitchens are closed and locked when kitchen personnel are not on campus.  Lighting in the kitchen provides adequate illumination to observe potential oil leaks. Security for the cafeterias appears adequate to prevent unauthorized access.

Wesleyan University Public Safety officers, who patrol the campus 24 hours per day, 365 days per year, provide adequate security for the used oil drums at the loading dock.  The loading dock has adequate illumination to deter vandalism and observe potential leaks.

==== 2.F.5	Potential Discharge Pathways ====

The kitchens are located inside each of there respective buildings and protected from the weather.  The kitchen floors are sloped, so spills are directed into floor drains connected to the local sewer system.  Kitchen sinks are also connected to the sewer system.  

Runoff from the loading dock is directed to a catch basin located in the center of the parking/maneuvering area. Runoff collected in the catch basin enters the campus stormwater management system. 

==== 2.F.6	Spill Containment and Control Measures ====

In general, there are small amounts of oil in the cafeteria areas.  The kitchen walls and floor are adequate to contain potential small spills.  The kitchen has a tile floor, which is sloped to direct spills to floor drains.  

 
==== 2.F.7	Potential Spill Scenarios ====

There is a potential that a spill event could occur as a result of a failure of one or more of the following: systems, equipment, components, or personnel actions.  Potential spill sources are summarized below.

TABLE 2.F.1
POTENTIAL SPILL SCENARIOS

Source	
Type of Failure	
Maximum Spill	
Rate of Flow

Kitchen 	
Over-fill	Less than 1 gallon	
Varies
	
Rupture	
Container Capacity (less than 10 gallons)	
Instantaneous
	
Leakage	
Container Capacity (less than 10 gallons)	
Varies

Loading Dock


	
Rupture	
Drum Capacity 
(55 gallons)	
Instantaneous
	
Leakage	
Drum Capacity 
(55 gallons)	
Varies


==== 2.F.8	History of Spills ====

There have been no records of reportable oil releases at Campus Cafeterias on the Wesleyan University campus. 

==== 2.F.9	Recommendations for Improvements ====

Wesleyan University should consider implementing the improvements listed in Appendix C of the original document for the Campus Cafeterias.

==== 2.G	Hydraulic Elevators ====

==== 2.G.1	Site Location ====

Hydraulic elevators, which circulate oil in a piston to raise and lower the passenger compartment, are located in the following campus buildings:

•	William Street Hi/Lo Rise
•	Davenport Campus Center
•	Olin Library (old)
•	Olin Library (new)
•	Judd Hall
•	CFA Music
•	Public Affairs Center
•	Atwater Lab
•	Fayerweather Gym
•	Freeman Athletic Center
•	CFA Gallery
•	CFA Theater
•	Admissions Building
•	Fisk Hall
•	Park/Washington Street
•	McConaughy Chair

==== 2.G.2	Site Description ====
 
At each hydraulic elevator, the piston is located at the base of the elevator shaft and extends into the ground below the base of the shaft.  The hydraulic pump and oil reservoir for each elevator is located in a ground floor room (the control room) adjacent to the shaft.  The floor of the control room and the elevator shaft are reinforced concrete; the hydraulic piston is seamless steel pipe. 

Approximately 145-150 gallons of oil are stored in each elevator reservoir.  To raise the elevator’s passenger compartment, oil is pumped into the piston.  Oil is returned to the reservoir to lower the passenger compartment.  The reservoir and pump are connected to the piston by hydraulic hose lines.  

==== 2.G.3	Operations ====

Wesleyan University contracts with a local elevator service company for the maintenance and repair of the elevators. The pump, reservoir, and piston of each elevator is a closed system, so regular oil filling is not required.  Typical maintenance operations may include changing hydraulic fluid and hydraulic lines.

==== 2.G.4	Site Security ====

Doors to the control rooms are closed and locked when Physical Plant personnel or subcontracted maintenance personnel are not present.  Key-operated controls limit access to the elevator shafts, and keys are only issued to authorized personnel.  Security for these sites appears adequate to prevent unauthorized access.

Lighting in the control rooms provides adequate illumination to observe potential oil leaks.

==== 2.G.5	Potential Discharge Pathways ====

Elevator shafts and control rooms are completely enclosed in the respective buildings and not exposed to precipitation or runoff.  Potential spills would be contained in the control rooms, elevator shafts, and/or adjacent rooms or corridors.  As required, Wesleyan University has a contractor that maintains the elevators and pumps any residual materials at regular intervals.

The one exception is the elevator system at the CFA Theatre.  The Stage operates two pistons from a reservoir source to raise the stage.  This is a large enclosure and there exists an occasional water infiltration issue.  There is a sump pump that discharges water to the storm or sanitary sewer and is currently being investigated by Wesleyan.

==== 2.G.6	Spill Containment and Control Measures ====

Control rooms, elevator shafts, and/or adjacent rooms or corridors provide adequate containment for potential spills.  

The CFA Theatre has incorporated an additional piston oil containment system due to the sump pump activity to prevent oil from reaching the sump.

==== 2.G.7	Potential Spill Scenarios ====

There is a potential that a spill event could occur as a result of a failure of one or more of the following: systems, equipment, components, or personnel actions.  Potential spill sources are summarized below.
 

TABLE 2.G.1
POTENTIAL SPILL SCENARIOS

Source	
Type of Failure	
Maximum Spill	
Rate of Flow

Hydraulic Pump and Reservoir	
Over-fill	
Dependent upon conditions during fill	
Varies
	
Rupture	
Reservoir Capacity (150 gallons)	
Instantaneous
	
Leakage	
Reservoir Capacity (150 gallons)	
Varies


==== 2.G.8	History of Spills ====

There have been no records of reportable oil releases at the hydraulic elevators on the Wesleyan University campus. 

==== 2.G.9	Recommendations for Improvements ====

Wesleyan University should consider implementing the improvements listed in Appendix C of the original document for the hydraulic elevators. 

==== 2.H	Electrical Transformers ====

==== 2.H.1	Site Location ====

Transformers with mineral oil dielectric fluid (MODF) are located at or near the following campus buildings:

•	Foss A 
•	Foss B 
•	Foss C
•	Judd Hall
•	North College 
•	Foss 9 
•	Foss 7 
•	McConaughy Hall 
•	Vine Street Substation 

There are multiple transformers with multiple oil capacities at these locations.

==== 2.H.2	Site Description ====
 
Generally, transformers located inside buildings are locked in the electrical equipment rooms.  These include all those transformers listed above with the exception of the Vine Street Substation.  The equipment rooms also have concrete floors. 

The outdoor transformers located at the Vine Street Substation are inside weatherproof structures and set on concrete pads.  The area around the transformers is a fenced and locked enclosure to restrict access.  There is crushed stone surrounding the two large transformers to allow for drainage.  There is a storm drain also inside the fenced area.

There are numerous sizes and quantities of oil storage in the transformers listed above.  Foss A and Foss B locations each have three transformers containing 23 gallons each of MODF.  Foss C has three transformers with 30 gallons each.  Judd Hall has three transformers containing approximately 55 gallons each.  North College has two larger transformers containing approximately 163 gallons each.  Foss 9, Foss 7 and McConaughy Hall each have three transformers and each contain 37, 27 and 39 gallons respectively.  The largest transformers are located at the Vine Street substation where there are two transformers each containing 775 gallons of MODF.

==== 2.H.3	Operations ====

Transformers are sealed units that contain MODF for cooling and insulating purposes.  Occasional maintenance of the transformer may be required, and is performed by electrical subcontractors.

==== 2.H.4	Site Security ====

For transformers inside buildings, doors to the electrical rooms are kept closed and locked when Physical Plant personnel or subcontractors are not present.  Weatherproof cabinets provide security for the outdoor transformers.  Access doors of the cabinets are kept closed and locked, except when the transformers are being serviced.  In addition, Wesleyan University Public Safety officers patrol the campus 24 hours per day, 365 days per year.  Security for the transformer sites appears adequate to prevent unauthorized access.

==== 2.H.5	Potential Discharge Pathways ====

Runoff from outdoor transformers located at the Vine Street Substation can flow towards the catch basin located within the fenced area, as shown in FIGURE 4, and can enter the city stormwater system.

Transformers located in electrical equipment rooms inside buildings are completely enclosed in the respective buildings and not exposed to precipitation or runoff.  Potential spills would be contained in the electrical equipment rooms, and/or adjacent rooms or corridors.  There also exist berms along the doorways to prevent a release to the environment with the exception of North College where a release may go out the door, however, there is not a storm drain located nearby.

The only exceptions are the three transformers located at Judd Hall.  There is a floor drain and sump inside the building due to water infiltration.  

==== 2.H.6	Spill Containment and Control Measures ====

The transformers located in Judd Hall have been exposed to moisture over the years and are in need of replacement.  One of the transformers had developed a small leak that is being repaired.  The release consisted of a few oil drops, was confined inside the building and was not considered a reportable event.  These transformers will be replaced, mounted on raised pads and placed in secondary containment in order to avoid any moisture conditions that exist in the room and allow the sump to remove the existing water.

Electrical equipment rooms and/or adjacent rooms or corridors provide adequate containment for potential spills from transformers located inside buildings.  The two transformers located outside at the Vine Street Substation have a catch basins within the enclosure to ensure no water accumulates in this high energy area.  The substation is inspected frequently by the Physical Plant to prevent potential leaks or spills entering the stormwater system.  In the event of a power outage at a Campus building or buildings, which may be due to a transformer malfunction, qualified Physical Plant personnel shall assess the condition of the transformer and be prepared to handle a potential spill.  Wesleyan is currently reviewing alternatives for secondary containment for the Vine Street substation as noted in Appendix C of the original document. 
 
==== 2.H.7	Potential Spill Scenarios ====

There is a potential that a spill event could occur as a result of a failure of one or more of the following: systems, equipment, components, or personnel actions.  Potential spill sources are summarized below.

TABLE 2.H.1
POTENTIAL SPILL SCENARIOS

Source	
Type of Failure	
Maximum Spill	
Rate of Flow
Transformer 	
Over-fill	
Dependent upon conditions during fill	
Varies
	
Rupture	
Transformer Capacity (less than 775 gallons)	
Instantaneous
	
Leakage	
Transformer Capacity (less than 775 gallons)	
Varies


==== 2.H.8	History of Spills ====

There have been no records of reportable oil releases at transformers on the Wesleyan University campus. 

==== 2.H.9	Recommendations for Improvements ====

Wesleyan University should consider implementing the improvements listed in Appendix C of the original document for the Campus electrical transformers.

==== 2.I	Miscellaneous Storage ====
 
==== 2.I.1	Site Location ====

Wesleyan University has several other miscellaneous storage areas throughout the campus.  These items include:

•	CFA-B (and gasoline UST)
•	Mill Street Garage
•	Vacuum Pumps
•	Air Compressors
•	Walk-Out Refrigerators
•	Parts Washers (Power Plant/Science Tower)
•	Freeman Athletic Center-Hockey Mech Space
•	Science Center - Mech Space
•	Misc. Gasoline Storage (255 Pine St/Boathouse)
•	Science Center Machine Shop
•	Trash Compactors

The Boat House contains small quantities of fuel and oil and gasoline lubricants.  The center for the Arts area has an abandoned UST to be scheduled for removal.  Located in several areas of the University are approximately 20 local air compressors.  In addition, primarily in the Science Center but also in other areas, there are approximately 30 vacuum pumps.

There exist approximately 20 trash compactors throughout the campus.  The University has two parts washers, located in the central power plant and Science Center.  There are two walk-in refrigerator/freezer units located in the Davenport Campus Center and McConaughy Hall.  The Science Center has a hazardous waste storage area that contains 55-gallon drum of waste oil.

==== 2.I.2	Site Description ====
 
There is a 500 gallon abandoned steel UST outside the Center for the Arts building.  This used to service an emergency generator that was removed.  The various air compressors located throughout the campus typically have a gallon or less of oil in each unit.  The vacuum pumps also have a gallon or less of oil storage capacity.

The trash compactors typically operate a hydraulic system with 10 gallons or less of hydraulic oil in the system.  The parts washer in the power plant uses approximately 55 gallons of kerosene and the parts washer in the Science Center use approximately 25 gallons of cleaning solvent.

The walk-in refrigerator/Freezers have approximately 10 gallons of oil in each system.  The Science Center typically has one 55-gallon drum of waste oil in the hazardous waste storage area.

==== 2.I.3	Operations ====

Due to the wide variety of operations, each specific area noted above has a localized impact.  In general, quantities of oil stored in each operation are generally small.

==== 2.I.4	Site Security ====

Generally, the area where the miscellaneous oil storage is utilized is the responsibility of the area using the equipment.  In addition Wesleyan University Public Safety officers, who patrol the campus 24 hours per day, 365 days per year, provide adequate security for the miscellaneous storage noted above.  The general campus area has adequate illumination to deter vandalism and observe potential leaks.

==== 2.I.5	Potential Discharge Pathways ====

Miscellaneous oil storage areas that are inside and under cover are considered contained within the building.  However, there are instances where floor drains may exist within the basement areas allowing oil to flow out the existing infrastructure.  The floor may also consist of dirt allowing a path directly to the soil and/or groundwater.  There are instances where there may be walk-out basements and a catastrophic release of oil may exit the building.

The existing USTs that have the potential to leak may have an impact to the environment.  Wesleyan University is currently reviewing the condition integrity each UST and determining each disposition.

The trash compactors are located outside throughout the campus.  A leak could possibly travel along the pavement to the nearest catch basin.  In addition, stormwater could also convey oil contaminants if a small release were to occur.

==== 2.I.6	Spill Containment and Control Measures ====

As noted, generally, tanks that are inside the buildings and in the basements are considered contained within the building.  Wesleyan University has taken steps where there are floor drains present, to block those drains if feasible.  Where there may be water infiltration issues present, typical protocol is to provide secondary containment for the tank and associated piping where possible.  In addition, if the tank is near an exit doorway to the outdoors, incorporating a berm or slightly raised edge across the door is provided to contain the fuel within the building and prevent a potential release to navigable waters.  The raised edge should be a smooth transition so as not to create a tripping hazard.

Equipment that is stored outside must have secondary containment or inspected frequently to prevent the release of oil to the environment.  Secondary containment structures exposed to precipitation must be drained as noted in Appendix H of the original document.

 
==== 2.I.7	Potential Spill Scenarios ====

There is a potential that a spill event could occur as a result of a failure of one or more of the following: systems, equipment, components, or personnel actions.  Potential spill sources are summarized below.

TABLE 2.I.1
POTENTIAL SPILL SCENARIOS

Source	
Type of Failure	
Maximum Spill	
Rate of Flow

Equipment & Drum Storage	
Over-fill	Less than 1 gallon	
Varies
	
Rupture	
Container Capacity (less than 500 gallons)	
Instantaneous
	
Leakage	
Container Capacity (less than 500 gallons)	
Varies

==== 2.I.8	History of Spills ====

There have been no records of reportable oil releases at the miscellaneous storage areas listed above on the Wesleyan University campus. 

==== 2.I.9	Recommendations for Improvements ====

Wesleyan University should consider implementing the improvements listed in Appendix C of the original document for the miscellaneous storage areas listed above.

===== 3.0	Training And Standard Operating Procedures =====
==== 3.1	Training ====
 Training is provided to the Wesleyan University Physical Plant, Public Safety, Chemistry, Athletics and Kitchen personnel involved with operations and maintenance of oil storage and/or oil-bearing equipment.  This training is conducted while on-the-job under the direct supervision of the Director of Physical Plant or designated experienced personnel.  Training for newly hired personnel includes:
•	Instructions in proper oil transfer operations (e.g., filling tanks, dispensing fuel).
•	Familiarizations with the location of fire fighting equipment and their operations.
•	Instruction in the proper gauging techniques for tanks.
•	Instruction in conducting Campus inspections. 
•	Familiarization with Campus operations, including operation and maintenance of equipment to detect or prevent discharges of oil.
•	Training in general maintenance schedules and procedures.
•	Training in applicable pollution control laws, rules and regulations. 
•	Review of the SPCC Plan.
Employees also receive annual oil spill prevention and response training as applicable to their job responsibilities, which includes techniques to prevent or recognize existing or potential oil spills and the appropriate notification required in the event of an oil spill.  In addition, annual training will review material covered in the new-hire training and highlight and describe known spill events or failures, malfunctioning components, and recently developed precautionary measures.  
Through training, Wesleyan University personnel are made aware that care and good judgement are the best means of preventing a fuel spill, inspections can identify leaks, and leaks must be controlled and repaired as soon as practicable.  Facility personnel are instructed to:
•	Exercise care in the delivery of products.
•	Never leave oil transfers unattended.
•	Monitor the product levels in storage tanks and report tank levels, as required.
•	As a general rule, do not wait for problems to occur.  Anticipate problems and take precautionary measures to prevent them.
In addition to the annual training, Wesleyan University will hold meetings periodically to brief personnel on current and pending regulations.  Also, as new operations require procedure modifications, employees will be familiarized with the new procedures prior to implementation.  This training will be conducted by the Director of Physical Plant or designated experienced personnel, who will be responsible for determining that each employee understands the new operations procedures.
Training requirements are based on the duties and function to be performed by each employee.  The designated accountable person for oil pollution control will ensure that the appropriate personnel complete the training requirements.  Training will be provided by qualified instructors in accordance with state and federal training requirements.  
==== 3.2	SPCC Related Trainings ====
Initial and review/refresher training relative to the content of the SPCC Plan will be provided to affected employees.  In addition, any major changes in requirements or procedures involving oil will immediately be brought to the attention of the affected personnel prior to implementing the changes.   
All personnel that are involved in oil storage, handling and spill response will be provided with the “initial” training.  Topics discussed in the training session will include the following:
•	Pertinent topics from OSHA 1910.38, Employee Emergency Action Plan training including:
1.	Emergency escape procedures and route assignments;
2.	Procedures to account for all employees;
3.	Rescue and medical duties for those who are to perform them;
4.	The preferred means of reporting fires and other emergencies;
5.	The names of individuals to contact for more information or explanations of duties under the Plan.
•	Pertinent topics from the OSHA Hazard Communication Standard (29 CFR 1910.120) training including:
1.	Characteristics and detection methods for oils used at the facility.
2.	Physical and health hazards of oils used. 
3.	Explanation of the labeling system and material safety data sheets.
•	Law and regulations requiring the SPCC Plan;
•	Spill detection methods;
•	Alarm and communication system operation;
•	Incident response procedures and cleanup activities;
•	Amendments to the SPCC Plan;
•	Delivery and dispensing procedures;
•	Inspection and record keeping procedures;
•	Operation and maintenance of equipment to prevent the accidental discharge of oil;
•	Applicable pollution control regulations; and
•	New regulations concerning oil spill prevention.
The review/refresher training will be conducted at least every three years after the SPCC Plan has been reviewed, updated, and re-certified as necessary by a Professional Engineer.  It will also be conducted when changes are such that personnel need the additional training, or if a reportable spill event occurs.
==== 3.3	SPCC Responses to Incidental Releases ====

Based on the level of preparedness Wesleyan University will incorporate into its spill response program, some employees will be required to respond to a spill of oil as follows:
•	Employees may stop a leak at the source only if the spill would be considered an “incidental release” under 29 CFR 1910.120 and only if the spill is located in the employees’ work area.
•	Employees may contain a spill that is incidental in the employees’ work area.
•	Employees will call for help.
•	Employees may cleanup the spilled oil if the spill could be considered an “incidental release” and only if the spill is located in an employee’s work area.  
Employees who will participate in incidental release response and all other employees regularly working with or around oils who are likely to witness or discover an oil spill will be given awareness training.  Generally, this training is approximately two hour or less based on the complexities of each area.  To satisfy the awareness training requirement, employees must have sufficient specific training or have had sufficient experience to objectively demonstrate competency in the following areas: 
•	An understanding of what oil is, and the risks associated with an incident.
•	An understanding of the potential outcomes associated with an emergency created when oil is present.
•	The ability to recognize the presence of oil in an emergency.
•	The ability to identify the type of oil.
•	The ability to realize the need for additional resources, and to make appropriate notifications. 
•	Hands-on experience with the U.S. DOT’s Emergency Response Handbook.
•	Familiarity with OSHA Standard 1910.120.
•	Knowledge of how to respond to an oil release.
•	Understanding of expected hazards such as fire, explosion, confined space, powered equipment, walking-working, etc.
•	Awareness of the competencies covered in the National Fire Protection Association’s Standard No. 472, “Professional Competence of Responders to Hazardous Materials Incidents”.
===== 3.4	SPCC Emergency Response to Hazardous Material Release =====
•	Currently, Wesleyan University does not have a formal spill response team and at the present time relies on the local fire department and spill response contractors to assist should a significant spill occurs on campus.  It is Wesleyan University’s intent to have 5-7 key individuals trained to the 24 hour HAZMAT Technician level for preparedness to spill event.  Employees who will participate in emergency response to a hazardous material release will be given at least 24 hours of Hazardous Materials Technician training. To satisfy the 24-hour training requirement, employees must have sufficient specific training or have had sufficient experience to objectively demonstrate competency in the following areas:
•	Know how to implement the Wesleyan University Emergency Response Plan.
•	Know the classification, identification and verification of known and unknown materials by using field survey instruments and equipment.
•	Be able to function within an assigned role in the Incident Command System.
•	Know how to select and use proper specialized chemical equipment provided to the Hazardous Material Technician.
•	Understand hazard and risk assessment techniques.
•	Be able to perform advance control, containment, and/or confinement operations within the capabilities, resources, and personal protective equipment available to the unit.
•	Understand and implement decontamination procedures.
•	Understand termination procedures.
•	Understand basic chemical and toxicological terminology and behavior.
Training records for Wesleyan University Physical Plant supervisors and maintenance personnel are kept in the personnel training files at 186 College Street.  
==== 3.5	Standard Operating Procedures ====
 Physical Plant supervisors and maintenance personnel shall be instructed in the standard operating procedures for spill prevention listed below:

1.	During maintenance operations involving the transfer of oil, qualified Physical Plant personnel are present to continuously monitor the operation.

2.	When conducting any maintenance activities involving the transfer of oil, absorbent pads are readily available and drip pans are in place. Oil drips are promptly cleaned up with absorbent materials.

3.	Oil-contaminated material from the cleanup of a spill is collected into drums or large plastic bags provided in spill kits.  Oil-contaminated debris is stored in a secure area, typically within the fenced parking area at the Physical Plant Building, until it is picked up for disposal as a hazardous waste.

4.	In the event of a release, see Section 1.4, Spill Response Procedures Flowchart, for a quick reference or Spill Notification List and Response Procedures found in Appendix A of this plan for detailed procedures.

5.	Personnel inspect oil-bearing equipment for leaks, corrosion, cracks, bad seals, discoloration, or other signs of distress before using.

6.	Whenever equipment is undergoing major maintenance, verify that any alarm systems in place related to oil levels in larger pieces of equipment are functioning properly.

7.	Monthly visual inspections of the Physical Plant fuel storage and garage fuel dispensing area and emergency generators shall be conducted by Physical Plant personnel for those areas listed in Section 2.  Inspections include observation of the equipment, containment measures, tank alarms, spill kits, and note whether obvious leaks and/or damage are apparent or not.  Monthly inspections are recorded on the inspection checklist form in Appendix D.  Deficiencies are noted and corrected as soon as prudently practicable.  These inspection records are maintained at the Physical Plant Building for a minimum of three years.

8.	The designated individual accountable for oil spill prevention is required to review this plan and ensure "oil spill preparedness" on an annual basis.  The designated individual shall review the material contained in this Plan, and sign and date the review form in Appendix E after the review is complete.  A copy of this form shall be kept in the SPCC Plan file at the Wesleyan University Physical Plant for a minimum of three years.

==== 3.5.1	Physical Plant Maintenance Shop (Additional Operating Procedures) ====
1.	Store drums and containers with fuel, grease, or oil in the Shop building.  Do not store these materials outdoors.
2.	Store drums and containers with fuel, grease, or oil in areas that provide secondary containment.  Secondary containment capacity shall be equal to or greater than the capacity of the largest oil storage container in the area.  Secondary containment currently in use at the Shop includes poly-racks for drummed products, containment pallets for used oil drums, and flammable materials cabinets for smaller containers.
3.	Drums and containers shall be placed into the proper containment as soon as prudently practicable after delivery.  
4.	When transferring or draining oil or coolants, all necessary precautions shall be used, including drain buckets and drip pans, to avoid spills.
5.	The Maintenance Shop shall be operated as follows:
•	Keep aisles and exits free of obstructions;
•	Keep access to fire extinguishers clear; and
•	Keep fire extinguisher locations well marked.
6.	The diesel fuel and gasoline compartments of the fuel AST shall be manually checked (i.e., dip stick measurement) prior to ordering fuels, and the quantities compared with the inventory.
7.	Physical Plant personnel shall be present during diesel fuel and gasoline deliveries to the fuel ASTs in excess of 330 gallons.
8.	When fueling vehicles or equipment, do not leave dispensing nozzles unattended.  Nozzles should not be equipped with automatic fill capabilities.
==== 3.6	Structural Control Considerations ====
Described in this section is the “system” of structural and non-structural controls that will be used to prevent a discharge or minimize the potential for a discharge of oil in harmful quantities into or onto the navigable waters of the United States and their adjoining shoreline.  The system will consist of:
•	Structural controls;
•	Storage tank regulations compliance;
•	Facility security measures;
•	Personnel training regarding the facilities available and the procedures established to prevent oil spills and subsequent discharges.
•	Routine inspections and recordkeeping;
•	Operating procedures that are specifically designed to minimize the potential for a release of oil; and
•	Routine SPCC Plan effectiveness reviews and amendments.
In addition to this system of structural and non-structural controls, two other means will be used to achieve the goals of the SPCC Plan.  These are routine SPCC Plan effectiveness reviews with related plan amendments and a “strong spill contingency plan.” Through adherence to these considerations, University staff will maintain the SPCC Plan up-to-date and assure its continued effectiveness.
A “strong spill contingency plan” is also referenced in this SPCC Plan.  This has been done because 40 CFR Part 112.7(d) allows that, if the installation of structures or equipment to prevent the discharge of oil to navigable waters is not practical, a strong spill contingency plan can be used.  Even though structural and non-structural measures that can be effective much of the time will be used, a strong spill contingency plan in accordance with 40 CFR Part 112.7 will be used as well.  The guidelines for the preparation and implementation of a SPCC Plan (40 CFR Part 112.7) require the use of “appropriate containment and/or diversionary structures or equipment to prevent oil from reaching a navigable water course.”  Structural controls that are mentioned for consideration for onshore facilities include:
•	Dikes, berms or retaining walls;
•	Curbing;
•	Culverting, gutters or other drainage systems;
•	Weirs, booms or other barriers;
•	Spill diversion ponds;
•	Retention ponds; and
•	Sorbent material.
Structural controls are in place and functioning for many oil storage activities.  These structural controls include curbing, secondary containment, high level alarms, etc.
==== 3.7	Tank System Regulations Compliance ====
The following is a summary of some requirements that apply directly or indirectly to ASTs and USTs:
•	EPA’s SPCC program under the Clean Water Act applies to ASTs that may discharge petroleum products into U.S. navigable waters or adjoining shorelines;
•	The National Pollutant Discharge Elimination System (NPDES) stormwater permitting regulations under the Clean Water Act cover industrial activities that could involve ASTs.
•	The air toxics provisions of the 1990 Clean Air Act amendments require lower routine emissions from certain ASTs and seek to prevent accidental releases of extremely hazardous substances.
•	ASTs are also regulated under the Occupational Safety and Health Act.  The Occupational Safety and Health Administration (OSHA) sets standards for the design, construction, and testing of vessels storing flammable and combustible liquids in the workplace.  In addition, Section 126 of the 1985 Superfund Amendments and Reauthorization Act (SARA), directs OSHA to adopt standards to protect employees engaged in hazardous waste operations and emergency response.  OSHA requires container labeling and the preparation of Material Data Safety Sheets (MSDS) to ensure that hazards are communicated to workers.
===== 4.0	Inspections And Reviews =====
==== 4.1	Designated Accountable Person And Emergency Coordinator ====
 The designated accountable person responsible for oil spill prevention and implementing the SPCC Plan is the Associate Director of Student Life Facilities.  Wesleyan University’s designated accountable person is required to review this Plan and assure oil spill preparedness annually.  Record of the annual review is kept with the Plan.  Duties of the designated accountable person also include reviewing and maintaining inspection records for oil-bearing equipment and storage areas. 
Control and cleanup of oil spills is the responsibility of the Physical Plant Emergency Coordinator (EC).  The primary EC is the Director of Public Safety.  Alternate ECs for Wesleyan University are listed in Appendix A of the original document.  Appendix A includes telephone numbers for the designated accountable person, EC, and Alternate ECs in the spill notification list.  
The EC is the central authority for emergency response procedures during an incident.  Should an incident occur, the EC will establish a command post at the scene of the incident or other appropriate location.  The EC will direct appropriate Wesleyan University personnel and outside support as necessary to respond to the incident, and will yield authority to the Fire Chief, as appropriate.  The EC has the authority to commit the necessary resources to adequately respond to incidents that may occur to protect human health and the environment.
==== 4.2	Inspections ====
Physical Plant personnel conduct monthly visual inspections of oil-bearing equipment, oil storage areas, and spill containment measures for storage in excess of 330 gallons on the campus.  Personnel observe oil-bearing equipment or ASTs, containment measures, lighting, and fencing and note whether obvious leaks and/or damage are apparent, and prioritize actions and/or repairs that may be required.  Monthly inspections are recorded on the inspection checklist forms included in Appendix D of the original document, and deficiencies are noted.  Deficiencies are prioritized and corrected as soon as practicable.  The monthly inspection forms are maintained at the Physical Plant Building for a minimum of three years.
==== 4.3	Record Keeping ====
Records or clear photocopies of originals regarding the oil storage areas and oil-bearing equipment covered by this SPCC Plan shall be kept at the Physical Plant, under the supervision of the Physical Plant Special Projects Manager, the individual tasked with campus-wide regulatory compliance documentation maintenance.  Records shall be maintained for as long as the specific oil storage area or piece of equipment is in operation or for three years after the University is no longer required to have an SPCC Plan.  Records that are kept include:
•	A copy of the current SPCC Plan;
•	Copies or originals of documentation that shows when the SPCC Plan was reviewed and the outcome of each review; and
•	Copies or originals of monthly inspection forms.
Wesleyan University Physical Plant keeps the following records:
•	The Oil Spill Correspondence is included in Appendix J.  Copies of telephone logs/records documenting a notification to the U.S. Environmental Protection Agency (EPA) National Response Center and State of Connecticut Department of Environmental Protection (DEP) and other agencies as required by a reportable spill (maintained on file as long as the facility is subject to the regulation).  Also included in Appendix J are completed spill reports, agency written correspondence, and the spill log summary that provides the historical spills.  The spill log summary includes information on date of release, date reported to authorities, product released and quantities, location of release, response actions, reports filed and authority contacted;
•	List of personnel that received initial assignment training on pertinent aspects of the SPCC Plan and their responsibilities and duties, including date of training and instructor's name;
•	List of personnel that received review/refresher training including the date of the training and instructor's name; and
•	Copies or originals of Wesleyan University’s Oil Spill Report Forms.
==== 4.4	SPCC Plan Amendments And Reviews ====
The SPCC Plan will be amended whenever there is a change in the design, operation, or maintenance of the facility that affects the potential for a discharge to occur.  Any amendments will be implemented within six months after the change at the facility.  In addition, the SPCC Plan will be reviewed at least every three years from the date of initial implementation (i.e., date of SPCC Plan certification by a Professional Engineer).  If this review indicates that additional field-proven and effective prevention measures are necessary, these measures will be implemented and the SPCC Plan will be so amended within six months of the review.  Following any technical amendments (i.e., non-administrative changes), the revised SPCC Plan will be certified by a Professional Engineer.

The Plan will also be updated to reflect minor changes that do not significantly affect the potential for a discharge to occur, such as changes in telephone numbers or addresses for responsible personnel.  These updates will not be certified by a Professional Engineer, but will be distributed to all recipients of the plan.

The SPCC Plan will also be amended if there are two discharges of oil in harmful amounts that violate applicable water quality standards or cause a film or sheen (40 CFR 110) to the navigable waters of the United States within a 12-month period or if such a discharge involves over 1,000 gallons of oil.  The regulations allow that the EPA Regional Administrator will review the SPCC Plan and may require amendments to be made. Within 60 days of the event triggering the review, Wesleyan University will submit to the EPA Regional Administrator and the Connecticut DEP the following information:
•	Name and location of the facility;
•	Name(s) of the owner or operator;
•	Date and year of initial facility operation;
•	Maximum oil storage capacity;
•	Description of the campus including topographical maps and other drawings;
•	Complete copy of the SPCC Plan;
•	Cause of the spill(s) including a failure analysis;
•	Corrective actions and/or countermeasures taken;
•	Additional preventive measures taken or contemplated to prevent a recurrence;
•	Amendment made to the Plan to avoid the recurrence of discharges of oil; and
•	Other information that may be reasonably required to review the Plan or the incidents.
After reviewing the above information and any comments received from the Connecticut DEP, the EPA Regional Administrator may notify the facility of any proposed amendments to the SPCC Plan necessary to prevent or contain future discharges.  Wesleyan University will respond to the proposed amendment within 30 days from receipt of the proposal.  The EPA Regional Administrator will either rescind the proposal or require that the amendment be made.  The amendment will become effective 30 days after issue and must be implemented within six months.  Any required amendment may be appealed to the Administrator of the EPA.
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