General Services Facility Spill Prevention Control Countermeasure Plan
The Bodhi Group prepared a Spill Prevention Control and Countermeasure (SPCC) Plan for the Port of San Diego General Services Facility at 1400 Tidelands Avenue in National City, California. The General Services Facility is a 4.8-acre site owned and operated by the Port. The primary function of the facility is to provide support and maintenance services for various Port-owned facilities, including buildings, parks, and marine terminals. The General Services Facility includes administrative offices, rest area, an Auto Shop, a Welding/Machine Shop, a Lube/Grease Storage Room, a Hazardous Materials Storage unit, a Paint Storage unit, a Receiving Area, a Paint Shop area, and areas to store landscaping supplies, tires, and other Port required items. The area outside the building has vehicle parking spaces, an outside storage area, two fuel aboveground storage tanks (ASTs), a fueling area, and a vehicle wash area.
The Bodhi Group:
- Prepared the SPCC Plan comply with the Environmental Protection Agency Oil Pollution Prevention Regulation 40 CFR Part 112, issued under Section 311 of the Federal Water Pollution Control Act.
- Performed an inventory of petroleum and hazardous materials storage containers including 7 interior ASTs, 2 exterior ASTs, and a sump.
- Researched the EPA (and Federal Register, Volume 73, No. 235) definition of a “loading/unloading rack” and determined that it did not apply to the facility fuel transfer area contrary to the observation of a local regulator (this resulted in significant cost savings to the Port).
- Determined that secondary containment for fuel transfer applied.
- Estimated possible discharge volumes and recommended containment and diversionary structures, inspections, tests, and record keeping.