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JIM BERRY & ASSOCIATES

4540 TIMBERLUX CIRCLE


ANCHORAGE, ALASKA 99516
PHONE / FAX: (907) 345-5426
E-MAIL: jberry@gci.net

August 19, 2016


TO: U.S. Coast Guard – Sector Anchorage U.S. Environmental Protection Agency
Attn: Captain of the Port, Western Alaska Room 537, Federal Building
PO Box 5800 222 W. 7th Avenue, Box #19
JBER, AK 99505-0800 Anchorage, Alaska 99513
WesternAlaskaFacilities@uscg.mil Whittier.Robert@epa.gov

RE: Yukon Koyukuk School District (YKSD)


Kaltag School Oil Storage
Amended Facility Response Plan Submittal
On behalf of the Yukon Koyukuk School District, I submit the enclosed amended Facility Response
Plan (FRP) for its Kaltag School. Kaltag is on the west bank of the Yukon River, 75 miles west of
Galena and 335 miles west of Fairbanks. Geographic coordinates of Kaltag are 64° 20' N, 158° 43' W.
The community tank farm is on Eight Avenue at “A” Street. It is about 800 feet west of the Yukon
River. The School is located about 2,000 feet southwest of the community tank farm.
The amendments solely address the award of a new contract to Frontier Fuel Service (FFS) to provide
spill response personnel and expertise at all schools. There have been no changes to fuel storage tanks
or piping. All revised pages are listed on the Record of Revisions Page (page 1-8) of the FRP.
FFS replaces the previous contractor. The new contract provides the same service as the previous
contract. FFS services include on-site maintenance, required inspections and tests, training, and spill
response including Qualified Individual responsibilities and authority. FFS is a Wasilla based
corporation organized to contract for the operation and maintenance of rural Alaskan bulk fuel storage
facilities.
The existing FRP was approved by the Coast Guard by letter dated August 6, 2013 and by the EPA by
letter dated June 11, 2014. The Coast Guard approved a request for equipment alternative of 250 feet
of sorbent boom by letter August 7, 2013. The approvals are included in the enclosed FRP.
The mailing address, telephone numbers, and contact persons for YKSD fuel storage compliance are:
Yukon Koyukuk School District Contact Person:
4762 Old Airport Way Kerry Boyd, YKSD Superintend of Schools
Fairbanks, Alaska 99709
Phones: District (Fairbanks) (907) 374-9400, School (Kaltag) (907) 534-2204

Please acknowledge receipt of the amended FRP.


It is our understanding this amendment will not affect the current FRP approvals unless further
action is requested by the Coast Guard or EPA.
Please forward all correspondence regarding the Kaltag School to the YKSD address listed above
with a copy to me.
Sincerely,

Jim Berry

cc: Yukon Koyukuk School District, Gale Bourne


Frontier Fuel Service, David Campbell
YUKON KOYUKUK SCHOOL DISTRICT

KALTAG SCHOOL OIL STORAGE


KALTAG, ALASKA

FACILITY RESPONSE PLAN

PREPARED TO SATISFY:

U.S. COAST GUARD & U.S. EPA

RESPONSE PLAN REQUIREMENTS


(1) FWPCA Section 311(j) - (OPA 90)
(2) 33 CFR, Part 154.1030
(3) 40 CFR, Part 112.20

AMENDED
AUGUST 2016
Captain of the Port 510 L Street, Suite 100
United States Coast Guard Anchorage, AK 99501-1946
Western Alaska Staff Symbol: spi
Phone: (907) 271-6700
FAX: (907) 271-6751
WesternAlaskaFacilities@uscg.mil

16611/ANC-K-102
August 6, 2013

Yukon Koyukuk School District


Kaltag School
Attn: Kerry Boyd
4762 Old Airport Way
Fairbanks, AK 99709

Subj: FACILITY RESPONSE PLAN (FRP)

Ref: (a) YKSD Kaltag FRP received June 25, 2013.

Dear Mr. Boyd:

Reference (a) is “Approved” as a substantial harm facility. Your FRP will expire July 24, 2018.
An annual review of the FRP shall be conducted in accordance with Title 33 Code of Federal
Regulations Part 154.1065, and any revisions shall be submitted to the Captain of the Port within
thirty days of the change. If no revisions are required, the facility owner or operator shall
indicate the completion of the annual review on the record of changes page.

This letter must be kept in the front of your FRP for review by Coast Guard personnel during
inspections. Any future correspondence should include your facility’s unique identification
number (ANC-K-102).

Questions or comments concerning your FRP shall be directed to the Facilities Branch at Sector
Anchorage: (907) 271-6700. Submit any revisions to the above address.

Sincerely,

D. G. BUCHSBAUM
Lieutenant Commander, U. S. Coast Guard
Chief, Inspections Division
By direction

CC: Jim Berry, Jim Berry & Associates


Facility File
Captain of the Port 510 L Street, Suite 100
United States Coast Guard Anchorage, AK 99501-1946
Western Alaska Staff Symbol: sp
Phone: (907) 271-6700
FAX: (907) 271-6751
WesternAlaskaFacilities@uscg.mil

16611/ANC-K-102
August 7, 2013

Yukon Koyukuk School District (YKSD)


Kaltag School
Attn: Kerry Boyd
4162 Old Airport Way
Fairbanks, AK 99709

Dear Mr. Boyd:

I have reviewed your request dated June 25, 2013 to substitute 250 feet of sorbent boom as an
alternative for the 200 feet of containment boom required by Title 33 Code of Federal
Regulations (CFR) Part 154.1040(d) at the YKSD Kaltag fuel storage facility. In accordance
with 33 CFR §154.107(a)(1), I am granting your request with the understanding that purchasing,
maintaining, and deploying containment boom is economically and physically impractical for
your geographic remote facility and the employment of sorbent boom offers a more effective
means of responding to a spill at your facility. Please keep a copy of this letter with your facility
records.

Please direct any questions or comments concerning this alternative to the Sector Anchorage
Facilities Branch at (907) 271-6700.

Sincerely,

S. L. JOHNSON
Commander, U. S. Coast Guard
Chief, Prevention Department
By Direction

Copy: Facility File


Jim Berry, Jim Berry & Associates
1.1 FACILITY CONTACTS & EMERGENCY RESPONDERS
Facility Name: Kaltag School
Street Address: N/A – The community tank farm is on Eight Avenue at “A”
Street. It is about 800 feet west of the Yukon River.
The School is located about 2,000 feet southwest of the
community tank farm.
Borough: None
Mailing Yukon Koyukuk School District
Address: 4762 Old Airport Way
Fairbanks, Alaska 99709
DISTRICT (FAIRBANKS.) SCHOOL (KALTAG)
Phone: (907) 374-9400 (907) 534-2204
Fax: (907) 374-9440 (907) 534-2227
YKSD Superintendent of Schools: (907) 374-9400
Facility Qualified Individuals: (refer to Section 2.3.2)
PRIMARY ALTERNATE
Name: Kaltag School Principal David Campbell
Title: Principal / Head Teacher Frontier Fuel Service (FSS)
Phone: office (907) 534-2204 (907) 494-5444
School Incident Command System Personnel: (refer to Section 2.3.3)
INCIDENT COMMANDER phone*
Kaltag School Site Principal* ...............................................(907) 534-2204
David Campbell, Frontier Fuel Service .................................(907) 494-5444
*Initial Incident Commander until relieved on site by Frontier Fuel Service I.C.
OPERATIONS SECTION CHIEF
Frontier Fuel Service personnel.............................................(907) 494-5444
LOGISTICS SECTION CHIEF
Frontier Fuel Service personnel.............................................(907) 494-5444
Kaltag School personel .........................................................(907) 534-2204
YKSD Fairbanks personnel ...................................................(907) 374-9400
ADMINISTRATION SECTION CHIEF
Frontier Fuel Service personnel.............................................(907) 494-5444
YKSD Fairbanks personnel ...................................................(907) 374-9400
PUBLIC INFORMATION OFFICER
Kerry Boyd, YKSD Fairbanks ............................................ (907) 374-9400
SAFETY OFFICER
David Campbell, Frontier Fuel Service .................................(907) 494-5444
GOVERNMENT LIAISON
Kerry Boyd, YKSD Fairbanks ............................................ (907) 374-9400
School Spill Response Team: (refer to Section 2.3.1)
Kaltag School Site Principal / Head Teacher ...................... (907) 534-2204
Kaltag School Site Maintenance Person ............................. (907) 534-2204
Frontier Fuel Service personnel.............................................(907) 494-5444
YKSD Fairbanks personnel ...................................................(907) 374-9400

1-2 08/16
1.2 FACILITY OWNERSHIP, OPERATION, MAINTENANCE
The School owner is the State of Alaska, Dept. of Education located at in Juneau, Alaska.
The School operator is the Yukon Koyukuk School District located in Fairbanks, Alaska.
YKSD is responsible for the operation of the fuel system at the Kaltag School. The School fuel
system consists of storage tanks #11, 12, 13, 14 in the community tank farm, the fuel transfer
pipeline to the School, and intermediate tank #IT-1 at the School. Appendix 1 of this FRP
describes and identifies the location of the fuel system components.
In addition, YKSD is responsible to ensure the its tank farm impound and security measures are
maintained and operated in accordance with EPA requirements described in School’s Spill
Prevention Control and Countermeasure Plan (SPCC), and the marine pipeline is maintained in
accordance with Coast Guard requirements described in the School’s Marine Transfer
Operations Manual.
YKSD has contracted Frontier Fuel Service, LLC (FFS) to provide spill prevention, response,
and compliance assistance at all its schools. FFS services include on-site maintenance, required
inspections and tests, training, and spill response including Qualified Individual responsibilities
and authority. LLC is a Wasilla based corporation organized to contract for the operation and
maintenance of rural Alaskan bulk fuel storage facilities.
1.3 FACILITY LOCATION / STORAGE INFORMATION
Kaltag is on the west bank of the Yukon River, 75 miles west of Galena and 335 miles west of
Fairbanks. The tank farm is at Eighth Avenue and A Street. Geographic coordinates of Kaltag
are 64° 20' N, 158° 43' W. The School is located about 2,000 feet southwest of the community
tank farm.
Date of Oil Storage Start-up: 1999 (current tank farm)
Total Number of School Tanks: 4 storage tanks, 1 intermediate tank
Storage Capacity / Products: Total capacity 40,100 gallons; all diesel fuel.
Largest Single Tank: 9,800 gallons
Distance from Navigable Water: < ¼ mile
NAICS Code: 611110
EPA and Coast Guard Discharge Planning Volumes are listed in Section 2.2.1.
Applicability of EPA Substantial Harm Criteria*
1. Does the facility transfer oil over water to or from vessels and does the facility have a total storage
capacity greater than or equal to 42,000 gallons?
Yes ____________ No __________*
2. Does the facility have total oil storage capacity greater than or equal to 1 million gallons and, within
any storage area, does the facility lack secondary containment that is sufficiently large to contain
the capacity of the largest aboveground oil storage tank plus sufficient freeboard?
Yes ____________ No __________
3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the
facility located at a distance such that a discharge from the facility could cause injury to fish and
wildlife and sensitive environments, or shutdown a public drinking water intake?
Yes ____________ No __________
4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has
the facility experienced a reportable oil spill in an amount greater than or equal to 10,000 gallons
within the last 5 years.
Yes ____________ No __________
* The YKSD storage tanks are within the community tank farm which has storage capacity greater than
42,000 gallons, therefore it is considered an EPA Substantial Harm Facility.

1-3 08/16
1.4 TABLE OF CONTENTS

Section Page
1.0 INTRODUCTION AND PLAN CONTENT
1.1 FACILITY CONTACTS & EMERGENCY RESPONDERS ................................................................. 1-2
1.2 FACILITY OWNERSHIP / OPERATION / MAINTENANCE ............................................................... 1-3
1.3 FACILITY LOCATION / STORAGE INFORMATION ......................................................................... 1-3
1.4 TABLE OF CONTENTS .................................................................................................................... 1-4
1.5 COAST GUARD AND EPA CROSS REFERENCE TABLES............................................................. 1-6
1.6 RECORD OF REVISIONS ................................................................................................................ 1-8
1.7 LIST OF ACRONYMS....................................................................................................................... 1-9

2.0 EMERGENCY RESPONSE ACTION PLAN


2.1 NOTIFICATION
2.1.1 Agency Reporting ....................................................................................................... 2-1-1
2.1.2 Emergency Phone Numbers ....................................................................................... 2-1-2
2.1.3 Spill Documentation .................................................................................................... 2-1-3
2.1.4 Requests for Information ............................................................................................. 2-1-3
2.1.5 Role of Government Agencies..................................................................................... 2-1-3
2.2 SPILL MITIGATION PROCEDURES
2.2.1 Discharge Planning Volumes ...................................................................................... 2-2-1
2.2.2 Spill Response Procedures ......................................................................................... 2-2-2
Initial Actions - All Spills .............................................................................................. 2-2-2
Emergency Response Checklist.................................................................................. 2-2-2
Spill Mitigation Procedures
2.2.2.1 Leak, Discharge from Transfer Pipeline to Intermediate Tank .............. 2-2-3
2.2.2.2 Storage Tank Overflow During Marine Delivery ................................... 2-2-3
2.2.2.3 Spill at Marine Header or Pipeline During Delivery .............................. 2-2-4
2.2.2.4 Tank Failure ........................................................................................ 2-2-5
2.2.3 Facility Response Equipment ...................................................................................... 2-2-10
EPA and CG Response Resource Worksheet ............................................................. 2-2-12
2.3 FACILITY RESPONSE ACTIVITIES
2.3.1 Response Organization / Personnel Responsibility ..................................................... 2-3-1
2.3.2 Qualified Individuals .................................................................................................... 2-3-1
2.3.3 Incident Command System ......................................................................................... 2-3-3
2.3.4 Response Contractor Information................................................................................ 2-3-5
2.4 SENSITIVE AREAS
2.4.1 Sensitive Areas and Protection Measures ................................................................... 2-4-1
2.4.2 Area Contingency Plan ............................................................................................... 2-4-2
2.4.3 Vulnerability Analysis .................................................................................................. 2-4-3
2.5 DISPOSAL PLAN
2.5.1 Disposal Options / Requirements ................................................................................ 2-5-1

3.0 HAZARD EVALUATION


3.1 SPILL HISTORY ............................................................................................................................... 3-1
3.2 POTENTIAL SPILLS ......................................................................................................................... 3-1
3.3 EMERGENCY SHUTDOWN SYSTEMS ........................................................................................... 3-2
3.4 FIRE SUPPRESSIONS EQUIPMENT............................................................................................... 3-2
3.5 EVACUATION PLAN ........................................................................................................................ 3-2
3.6 PERSONNEL SAFETY ..................................................................................................................... 3-3

4.0 TRAINING AND DRILLS


4.1 OPERATOR TRAINING.................................................................................................................... 4-1
4.2 SPILL RESPONSE TRAINING ......................................................................................................... 4-1
4.3 SPILL DRILLS, EXERCISES ............................................................................................................ 4-2
4.4 COAST GUARD PERSON-IN-CHARGE TRAINING ......................................................................... 4-2
4.5 PREP TRAINING FACT SHEETS ..................................................................................................... 4-2

APPENDIX
Appendix
1. FACILITY SPECIFIC INFORMATION
1.1 Facility Description ........................................................................................................................ A1-1
1.2 Facility Plot Plan ........................................................................................................................... A1-4
1.3 Valve Identification ........................................................................................................................ A1-4
1.4 Product Information....................................................................................................................... A1-4

1-4 05/13
APPENDIX continued

Appendix
2. LIST OF CONTACTS
2.1 Key Personnel .............................................................................................................................. A2-1
2.2 Federal, State, Local Officials ....................................................................................................... A2-1
2.3 Response Contractors Agreement ................................................................................................ A2-1

3. EQUIPMENT LIST AND RECORDS


3.1 Facility Response Equipment ........................................................................................................ A3-1

4. COMMUNICATIONS PLAN
4.1 Communications Plan / Equipment ............................................................................................... A4-1

5. SITE-SPECIFIC SAFETY AND HEALTH PLAN


5.1 Site Safety Plan ............................................................................................................................ A5-1
5.2 Material Data Safety Sheets.......................................................................................................... A5-1

6. DOCUMENTATION FORMS
6.1 Spill Report / Notification Form ...................................................................................................... A6-1
6.2 Facility Inspections......................................................................................................................... A6-1
6.3 Training.......................................................................................................................................... A6-1

7. SIMPLIFIED CLEANUP TECHNIQUES ............................................................................................................ A7-1

LIST OF FIGURES

Figure
2-1-1. AGENCY REPORTING REQUIREMENTS ........................................................................................................ 2-1-4
2-2-1. FACILITY DRAINAGE PATTERNS / POTENTIAL SPILL CONTAINMENT POINTS.......................................... 2-2-9
2-3-1. FACILITY RESPONSE ORGANIZATION .......................................................................................................... 2-3-2
2-3-2. INCIDENT COMMAND SYSTEM ...................................................................................................................... 2-3-6
2-4-1. SENSITIVE AREA – PLANNING DISTANCES .................................................................................................. 2-4-4
A1-1. LOCATION MAP ............................................................................................................................................... A1-4
A1-2. AREA PLAN ...................................................................................................................................................... A1-5
A1-3. PIPING PLAN.................................................................................................................................................... A1-6

1-5 05/13
1.5 COAST GUARD AND EPA CROSS REFERENCES
U.S. COAST GUARD FACILITY RESPONSE PLAN REQUIREMENTS
33 CFR Section or page in this
PART 154.1035 Description Response Plan
Section
(a) Introduction / content
(a) (1) Facility Information pages 1-1, 1-2, 1-3
(a) (2) Facility Location page 1-3
(a) (3) Contact Names / Address page 1-2
(a) (4) Table of Contents page 1-4
(a) (5) Cross Reference pages 1-6
(a) (6) Record of Changes page 1-8
(b) Emergency Response Plan Section 2.0
(b) (1) (i)(ii) Notification Procedures Sec. 2.1
(b) (2) Spill Mitigation Procedures page 2-2-2 – Sec. 2.2.2
(b) (2) (i) Projected Spill Volumes (AMP, MMP, WCD) page 2-2-1
(b) (2) (ii) (A-G) Emergency Response Action Sec. 2.2
(b) (2) (iii) List of Equipment & Sec 2.2.3, Appendix 3
Personnel Responsibilities Sec 2.3
(b) (3) Facility's Response Activities Sec. 2.2 / 2.3
(b) (3) (i) Initial action prior to arrival of Q.I. page 2-3-1
(b) (3) (ii) Q.I. Responsibility / Authority page 2-3-1
(b) (3) (iii)(A-H) Response Organization-ICS Sec. 2.3
(b) (3) (iv)(A-B) Spill Removal Organization Sec. 2.3.4., 2.2.3, 2.3.1
(b) (3) (v) ICS Job Descriptions 2.3.3
(b) (3) (vi)(vii) Dispersant Use / Aerial Tracking n/a
(b) (3) (viii)(ix) Mobile Facilities n/a
(b) (4) (i) Sensitive Areas – consistent w ACP Sec. 2.4
(b) (4) (ii) Identify & Map of Sensitive Areas - Figs. 2-2-1, 2-4-1
Depiction of response actions to protect Secs. 2.2, 2.4
these areas
(b) (4) (iii) Equipment & Personnel to Protect Sensitive Secs. 2.2, 2.3, 2.4, Appendix 3
Areas in WCD
(b) (4) (iii)(B)(1)(iii) Calculate Planning Distance. Identify Secs. 2.4
protection areas in planning distance Figs 2-2-1, 2-4-1
(b) (5) Disposal Plan Sec. 2.5
(c) (1)&(2) Training and Drills Sec. 4.0
(d) Plan Review & Update page 1-8
(e) Appendices
(e) (1) (i) Facility Description Appendix 1
(e) (1) (ii) Type/Number of Vessels Appendix 1.4
(e) (1) (iii) Valve Identification (MTR) Appendix 1.3, Figs. A1-2, A1-3
(e) (1) (iv) Product Information Appendix 1.4
(e) (2) (i)(ii)(iii) List of Contacts including QI's, OSRO's, Appendix 2
officials, agencies
(e) (3) (i) Equipment & Personnel to Respond to Secs. 2.2.2.2, 2.2.2.3, 2.3
Average Most Probable Discharge
(e) (3) (ii) (iii) List of major equipment including type, Sec. 2.2.3
(A)(C) model, dimension, etc.
(e) (3) (iii)(B) Equipment - effective daily recovery rates pages 2-2-10, 12
(e) (3) (iii)(D) Spill Scenario w equipment used Secs. 2.2.2.1 - 4
(e) (3) (iii)(E) Daily capacity storage /disposal capacity pages 2-2-10 & 2-2-12, Sec. 2.5.1
(e) (3) (iii)(F) Communications equipment & frequencies Appendix 4
(e) (3) (iii)(G) Location of Equipment Sec. 2.2.3, Fig. A1-2
(e) (4) Communication Plan Appendix 4
(e) (5) Site Safety Plan Appendix 5
(e) (6) List of Acronyms and Definitions Sec. 1.7

1-6 05/13
U.S. EPA FACILITY RESPONSE PLAN REQUIREMENTS
40 CFR
PART 112.20
Section in Facility
Description
SECTION Response Plan
(h) (1) Emergency Response
Section 2.0
Action Plan
(h) (1) (i) Emergency Contacts / Phones 2.1
(h) (1) (ii) Facility Owner
1.1 / 1.2
Contact Information
(h) (1) (iii) Reporting / Notification 2.1
(h) (1) (iv) Response Equipment 2.2.3, Appendix 3
(h) (1) (v) Response Personnel 2.3
(h) (1 (vi) Evacuation Plan 3.5, Fig. 2-2-1
(h) (1) (vii) Containment Measures 2.2.2, Appendix 7
(h) (1) (viii) Facility Diagram Appendix 1, Figs. A1-3
(h) (2) Facility Information 1.1-1.3
(h) (3) Information about Emergency Response 2.0
(h) (3) (i) Response Resources 2.2.3, 2.3, Appendix 3
(h) (3) (ii) Response Contracts 2.3.4
(h) (3) (iii) Emergency Phones 2.1.2
(h) (3) (iv) Initial Actions 2.2.2
(h) (3) (v) Response Capability / Duties 2.2.3 - 2.3.1
(h) (3) (vi) Response Equipment 2.2, 2.2.3, Appendix 3
(h) (3) (vii) Evacuation Plans 3.5
(h) (3) (viii) Diagram of Evacuation Routes Fig. 2-2-1
(h) (3) (ix) Duties of Response Coordinator 2.3.1
(h) (4) Hazard Evaluation 3.0
(h) (5) Tiered Planning Scenarios 2.2
(h) (5) (i) Worst Case 2.2.2.4
(h) (5) (ii) Small Discharge 2.2.2.1
(h) (5) (iii) Medium Discharge 2.2.2.2
(h) (6) Detection Systems Appendix 1
(h) (7) Plan Implementation 2.0
(h) (7) (i) Spill Mitigation Actions 2.2
(h) (7) (ii) Scenario Equipment 2.2, 2.2.3, Appendix 3
(h) (7) (iii) Disposal Plans 2.5
(h) (7) (iv) Containment Measures 2.2 - Appendix 7
(h) (8) Self-Inspection, Training and Meeting Logs Appendix 6
(h) (8) (i) Inspection Records Appendix 6
(h) (8) (ii) Training / Drills 4.0
(h) (8) (iii) Prevention Meetings 4.0
(h) (9) Diagrams Appendix 1
(h) (10) Security Appendix 1

1-7 05/13
1.6 RECORD OF REVISIONS

PAGE / SECTION REASON FOR DATE OF


NUMBER(S) REVISION REVISION

Title page, page 1-2 (Facility YKSD issued new contract to Frontier Fuel Service 08/16
Contacts), 1-8 (Record of (FFS) to provide spill response personnel and
Revisions), contractor references expertise at all schools. FFS replaces the previous
on pages 1-3, 2-1-2, 2-2-2, 2-2-4, contractor. The new contract provides the same
2-2-5, 2-2-6, 2-2-10, 2-3-1, 2-3- service as the previous contract. FFS services include
2, 2-3-5, 4-1, 4-2, A6-1 on-site maintenance, required inspections and tests,
training, and spill response including Qualified
Individual responsibilities and authority.
Revisions refect new contractor name and phone
number.

EPA Facility Response Plan regulations (40 CFR, Part 112.20) require plans to be reviewed periodically
and revised and resubmitted if there is a "facility change that materially may affect the potential for a
discharge...".
Coast Guard Facility Response Plan regulations (33 CFR, Part 154.1065) require annual review. The
review is to occur within one month of the anniversary date of the Coast Guard approval of the plan.
Further, the Coast Guard regulations state that revisions or amendments are to be submitted by plan
holders within 30 days whenever there is:
 a significant change in the facility configuration that affects information in the plan,
 a change in the type of oil handled that affects the required response resources,
 a change in name or capability of the designated spill removal organization,
 a change in emergency response procedures, and
 any other changes that significantly affect implementation of the plan,
Changes to personnel and telephone number lists do not require approval.
If no revisions are required, the completion of the annual review shall still be indicated on the record of
revisions page.

Facility Response Plans must be reapproved by the EPA and Coast Guard every five years.

1-8 08/16
1.7 LIST OF ACRONYMS

Acronyms pertaining to spill planning and response, which may or may not be used in
this plan, include:
ACP Area Contingency Plan
ADEC Alaska Department of Environmental Conservation
API American Petroleum Institute
AST Aboveground Storage Tank
BBLS Barrels
CFR Code of Federal Regulations
CHEMTREC National Chemical Transportation Emergency Center
CHRIS Chemical Hazards Response Information System
COE Corps of Engineers (U.S. Army)
COTP Captain of the Port (USCG)
CWA Clean Water Act
EPA U.S. Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
FOSC Federal On-Scene Coordinator
FR Federal Register
FRP Facility Response Plan
HAZMAT Hazardous Material
ICS Incident Command System
LEL Lower Explosive Limit
LEPC Local Emergency Planning Committee
MSDS Material Safety Data Sheet
MSO Marine Safety Office
MTR Marine Transportation-Related (facility)
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NRC National Response Center (USCG)
NSF USCG National Strike Force
OPA 90 Oil Pollution Act of 1990 (Public Law 101-380 of 18 Aug 90)
OSC On-Scene Coordinator
OSHA Occupational Safety and Health Administration
OSRO Oil Spill Removal Organization (classified by NSFCC)
PIC Person in Charge
POL Petroleum-Oil-Lubricant
PPE Personal Protective Equipment
PREP Preparedness-for-Response Exercise Program (USCG)
QI Qualified Individual
RA Regional Administrator (EPA)
RQ Reportable Quantity (of hazardous substances)
SERC State Emergency Response Commission
SOSC State On-Scene Coordinator
SPCC Spill Prevention, Control and Countermeasures (plan)
TLV Threshold Limit Valve
TWA Time Weighted Average
UEL Upper Explosive Limit
UL Underwriters Laboratory
USCG U.S. Coast Guard
USFWS U.S. Fish and Wildlife Service
UST Underground Storage Tank
WCD Worst Case Discharge

1-9 05/13
2.0 EMERGENCY RESPONSE ACTION PLAN
2.1 NOTIFICATION
2.1.1 Agency Reporting
The School Responsible Person (Site Principal / Head Teacher) responsible for reporting all oil
spills that result from School operations to the YKSD Superintendent of Schools in Fairbanks.
The Superintendent of Schools is to responsible to ensure all YKSD spills are reported to the
required agencies accordance witih regulatory requirements listed below.
• The Superintendent of Schools phone number is listed on the following page.
Direct verbal contact must be made with the agencies.
All oil spills to water, and any sudden or cumulative discharge of oil in excess of 55 gallons
solely to land is to be reported "as soon as the person (in charge of the facility) has knowledge"
of the incident. Spills solely to land in excess of 10 gallons, but 55 gallons or less, are to be
reported within 48 hours. Spills in excess of 55 gallons to an "impermeable secondary
containment area" are to be reported within 48 hours.
The Coast Guard (National Response Center) must also be notified if spilled oil (any sheen)
enters, or threatens navigable waters. Notification to the National Response Center satisfies EPA
notification requirements.
Information to be reported includes (to the extent known):
1. Date/time of discharge 5. Type / amount of discharge
2. Location of discharge 6. Cause of discharge
3. Name of facility 7. Environment damage
4. Name, address, phone of: 8. Cleanup actions taken
• owner/operator of facility 9. Volume recovered
• persons causing the discharge 10. Disposal plans
NEVER SPECULATE OR GUESS WHEN REPORTING OR DISCUSSING SPILLS.
IF SPECIFICS ARE UNKNOWN - STATE SO!

REPORT ALL SPILLS TO:


ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION
PHONE: 451-2121 - NORTHERN AREA RESPONSE TEAM
or 800-478-9300 - AFTER HOURS

REPORT MARINE SPILLS TO:


U.S. COAST GUARD

PHONE: 800-424-8802 - NATIONAL RESPONSE CTR. (NRC)


MARINE SPILLS INCLUDE ANY DISCHARGE (SHEEN) TO ANY WATER, INCLUDING
PONDS, SLOUGHS, WETLANDS, MARSHES AND DRAINAGE THERETO - FAILURE TO
REPORT MARINE SPILLS TO THE NRC MAY RESULT IN CRIMINAL PENALTIES.
WHEN IN DOUBT-REPORT IT!
• Figure 2-1-1 (page 2-1-4) lists agency reporting and documentation requirements.
• An acceptable spill reporting form is in Appendix 6.

2-1-1 05/13
2.1.2 Emergency Phone Numbers
School Phones:
DISTRICT (FAIRBANKS.) SCHOOL (KALTAG)
Phone: (907) 374-9400 (907) 534-2204
Fax: (907) 374-9440 (907) 534-2227

YKSD Superintendent of Schools: (907) 374-9400


Facility Qualified Individuals: (refer to Section 2.3.2)
PRIMARY ALTERNATE
Name: Kaltag School Principal David Cambell
Title: Principal / Head Teacher Frontier Fuel Service (FSS)
Phone: office (907) 534-2204 (907) 494-5444

Alaska Department of Environmental Conservation


Northern Area Response Team (Spill Reporting) .......................... 451-2121
after hours call ................................................................... .(800) 478-9300
U.S. Coast Guard
National Response Center (Spill Reporting) ........................... (800) 424-8802
NRC toll number ..................................................................... (202) 267-2675
Sector Anchorage Office ................................................................ 428-4200
U.S. Environmental Protection Agency
Anchorage ...................................................................................... 271-5083
Local
City .................................................................................................... 534-2301
Water System (City).......................................................................... 534-2212
Volunteer Fire Dept .......................................................................... 534-2251
VPSO ................................................................................................ 534-9921
Council .............................................................................................. 534-2224
Kaltag Cooperative............................................................................ 534-2235
AVEC ............................................................................................... 534-2251
Health Clinic ..................................................................................... 534-2209
Other
ADEC Response Equipment (Bethel, Mt. Village, Aniak) .............. 269-7648 / 269-7500
State Troopers (Galena) ................................................................... 656-1233
State Fire Marshall ........................................................................... 269-5482
Alaska Div. of Emergency Services................................................. 428-7000
Alaska Dept. Fish & Game - Fairbanks ........................................... 459-7285
U.S. Fish & Wildlife Service -Anchorage........................................ 786-3519
State/DNR - Office of History & Archaeology ................................ 269-8715
Local Emergency Planning Committee (City) ................................. 534-2301
State Emergency Response Comm. / SERC .................................... 465-5050
Weather Report Number .................................................................. 458-3700
AK. Rural Comms. System–(T.V. alert broadcast contact) ...... 888-840-0013
AK. Public Radio Network–(Radio alert broadcast contact) ........... 277-2776

Alaska area code - 907

2-1-2 08/16
2.1.3 Spill Documentation
A written spill report shall be completed for each spill - regardless of magnitude. The spill
report is to be maintained for the "life of the facility". A copy of the report is to be submitted to
the EPA Regional Administrator if an oil spill occurs of more than 1,000 gallons in a single
discharge or more than 42 gallons of oil in each of two discharges occurring within any 12
month period: the discharges being into or upon navigable waters or adjoining shorelines. The
Coast Guard and ADEC may also request a copy of the report.
The written spill report shall contain, as applicable:
1. Name of facility;
2. Your name;
3. Location of the facility;
4. Maximum storage or handling capacity of the facility and normal daily throughput;
5. Corrective action and countermeasures you have taken, including a description of
equipment repairs and replacements;
6. An adequate description of the facility, including maps, flow diagrams, and topographical
maps, as necessary;
7. The cause of the discharge, including a failure analysis of the system or subsystem in which
the failure occurred;
8. Additional preventive measures you have taken or contemplated to minimize the possibility
of recurrence; and
9. Such other information as the EPA Regional Administrator may reasonably require
pertinent to the Plan or discharge.
• An acceptable spill reporting form is in Appendix 6.

2.1.4 Requests for Information


Facility / School operators, employees, and contractors are not to give any information about a
spill to anyone other than the designated on-scene representatives of ADEC, the U.S. Coast
Guard, or the U.S. Environmental Protection Agency (EPA). No statements shall be made
regarding the following subjects except by the Qualified Individual or Alternate Qualified
Individual
• Liability for spill.
• Estimates of damage expressed in dollars.
• Estimates of duration of cleanup.
• Estimates of cleanup costs.
• Comments regarding effectiveness of cleanup.
• Comments regarding appropriateness or effectiveness of public or private
involvement.

2.1.5 Role of Government Agencies


The primary government agencies concerned with oil spills are the State of Alaska Department
of Environmental Conservation (ADEC), the Federal Environmental Protection Agency (EPA),
and the U.S. Coast Guard (USCG).
ADEC's responsibility is to monitor and determine "adequacy" of cleanup of spills that impact
state lands or water. The EPA has jurisdiction over all inland waters and adjoining shorelines.
The Coast Guard is responsible for all navigable water (and tributaries) and adjoining estuaries
and shorelines.
If a spill response and cleanup effort is not adequate, effective or capable, the Coast Guard, EPA
or ADEC will initiate its own cleanup efforts - and recover all costs, and then some, from the
responsible parties.

2-1-3 05/13
OIL SPILL VERBAL WRITTEN
AGENCY SIZE/LOCATION REPORT PHONE REPORT

ALASKA DEPT. OF WATER


ENVIRONMENTAL ALL SPILLS Immediately ADEC Fairbanks 15 Days
CONSERVATION (907) 451-2121 or (ADEC-Fbx.)
(800) 478-9300

LAND
>55 gal. Immediately Same 15 Days
10 - 55 gal. 48 Hours (ADEC-Fbx.)
>55 gal. to impervious 48 Hours
secondary containment
10 gal. or less None Maintain record &
submit to ADEC
monthly

U.S. COAST GUARD Threat to or entered Immediately National Response Ctr. If Requested
coastal or navigable (800) 424-8802
waters. Sheen on
water or sludge or
emulsion below surface

U.S. EPA 1,000 gal. or 2 Report to Coast Guard / Anchorage Office Within 60 days
sheens on navigable NRC (above) meets (907) 271-5083 of occurrence.
water within 12 requirement Follow 40 CFR,
month period from Part 112,
facility required to Paragraph 112.4
have SPCC Plan

FIGURE 2-1-1. AGENCY REPORTING REQUIREMENTS

2-1-4 05/13
2.2 SPILL MITIGATION PROCEDURES

2.2.1 Discharge Planning Volumes


The School stores only non-persistent diesel fuel. Appendix 1 of this FRP contains a facility
description and tank information.

Coast Guard and EPA required discharge planning volumes are as follows:
Coast Guard (33 CFR, Part 154.1020-29)
• Average Most Probable Discharge 19 gals.
(lesser of 50 bbls. or 1% of worst case)
• Maximum Most Probable Discharge 189 gals.
(lesser of 1,200 bbls. or 10% of worst case)
• Worst Case Discharge 1,884 gals.
(the worst case discharge volume is the capacity of all piping
that can carry oil between the marine transfer manifold (fill
point connection) and the non-transportation portion of the
facility (first valve in tank farm), plus the potential discharge
volume prior to shutdown during maximum transfer.) =
volume of 1 ea. 1,000 foot long, 3-inch diameter pipeline =
384 gals. plus 5 minutes to detect and shutdown @ 300 gpm =
1,500 gals. Total = 1,884 gallons

EPA (40 CFR, Part 112.20 (h)(5))


• Small Scenario 98 gals.
(2,100 gallons or less)
• Medium Scenario 980 gals.
(2,100 - 36,000 gals. or 10% of largest tank)
• Large Scenario 9,800 gals.
(volume of largest single tank plus capacity of all other
tanks without secondary containment) = 9,800 gallons

The USCG Average Most Probable Discharge and EPA Small Scenario volume discharge could
result for leak or discharge from the transfer pipeline to the School intermediate tank.
The USCG Maximum Most Probable Discharge and EPA Medium Scenario volume discharge
could result from storage tank overflow during marine delivery.
The USCG Worst Case Discharge could result from equipment / pipeline failure or operator error
during marine delivery.
The EPA Worst Case Discharge could result from storage tank failure due to mechanical failure,
vandalism, or a catastrophic natural event.
• Mitigation actions and response scenarios for the above discharge planning volumes are
presented on the following pages.

2-2-1 05/13
2.2.2 Spill Response Procedures
The following section outlines initial response actions to potential discharges. The actions described
are not specifically prescribed procedures, as every spill response will be dependent upon site-
specific variables, and the judgment of the Person(s)-in-Charge (marine transfer), the Qualified
Individual(s), and/or the Incident Commander.
 Spill scenarios and mitigation actions are presented in Section 2.2.2.1.
 Evacuation plans are in Section 3.5. Figure 2-2-1 illustrates evacuation routes.
 Figure 2-2-1 illustrates drainage patterns and potential spill containment sites.
 Section 2.4 identifies sensitive areas and protection measures.
 Appendix 7 illustrates spill cleanup techniques.
INITIAL ACTIONS - ALL SPILLS
SPILL CONTAINMENT AND CLEANUP ACTIVITY WILL NEVER TAKE PRECEDENCE OVER THE SAFETY OF
PERSONNEL. DO NOT BEGIN ANY ACTIVITY UNTIL CONDITIONS ARE SAFE FOR WORKERS.
1. Close valves that allow product to flow to the segment of the system causing the spill. Remove
sources of ignition. Account for personnel and ensure their safety.
2. Restrict access. If a fire or explosion hazard exists - clear the area. If necessary, alert volunteer
fire department and position available firefighting equipment.
3. Attempt to contain a diesel fuel spill - disperse a gasoline spill due to fire, explosion hazard.
Prevent or divert spilled oil from approaching structures or draining to any water. Spill
response equipment including sorbent material, handtools, a pump and hose, storage containers
and support equipment is stored in the School mechanical room. If necessary for terrestrial
containment, earthmoving equipment can be mobilized from the City. Additional resources are
available from the other tank farm operators and AVEC. Section 2.2.3 lists response
equipment.
4. The Qualified Individual and/or on-site Incident Commander will conduct a safety assessment
and direct cleanup operations. Section 2.3.1 describes the School’s response organization.
5. The School Site Principal / Head Teacher will notify the YKSD Superintendent of Schools.
The Superintendent will ensure all spills are reported to the Alaska Department of
Environmental Conservation. If the discharge enters or threatens water, the U.S. Coast Guard
(National Response Center) will also be notified. Section 2.1 describes spill reporting
requirements.
EMERGENCY RESPONSE CHECKLIST
Safety
__ PEOPLE IN IMMEDIATE AREA ALERTED - GENERAL ALARM INITIATED
__ VALVES CLOSED - IGNITION SOURCES REMOVED / ISOLATED
__ ALL PERSONNEL SAFE AND ACCOUNTED FOR - SITE SECURITY ESTABLISHED
__ YKSD SUPERINTENDENT AND QUALIFIED INDIVIDUAL NOTIFIED
__ SITE ASSESSMENT CONDUCTED - AREA DEEMED SAFE FOR CLEANUP
Response
__ FLOW STOPPED - LEAKS PATCHED / PLUGGED
__ RESPONSE TEAM BRIEFED ON CLEANUP PLANS / PERSONNEL SAFETY
__ DRAINAGE PATHS BLOCKED - CONTAINMENT SITES ESTABLISHED
__ AGENCIES NOTIFIED
__ ON-SITE EQUIPMENT ADEQUATE, OR ADDITIONAL RESOURCES ACTIVATED
__ YKSD RESPONSE CONTRACTOR (Frontier Fuel Service/FFS) ACTIVATED, IF NECESSRY
__ SPILL TRAJECTORY PROJECTED
__ DISPOSAL / RECYCLING PLANS ESTABLISHED
__ DOCUMENTATION METHODS / LOGS IN PLACE
Post Response
__ INCIDENT INVESTIGATION INITIATED
__ WRITTEN SPILL REPORT FILED WITH AGENCIES
__ EXPENDED CLEANUP MATERIALS REPLACED
__ CORRECTIVE ACTIONS / IMPROVEMENTS IMPLEMENTED

2-2-2 08/16
2.2.2.1 Leak / Discharge from Transfer Pipe to School Intermediate Tank (EPA
Small Scenario / USCG Average Most Probable Discharge) Procedures are
applicable to piping rupture, piping leak both under pressure and not under pressure - 33
CFR Part 154.1035 (b)(2)(ii)(D)&(E).
The transfer pipe from the tank farm to the School intermediate tank is welded two inch diameter
steel about 2,500 feet in length. The pipe parallels the washeteria pipeline. It is above ground
and removed from vehicle driving areas except where it passes under roadways where is
protected within an ABS culvert. Fuel is transferred to the intermediate tank by manually
starting the transfer pump using controls mounted on the intermediate tank. Valves on tank farm
storage tanks and the transfer pipeline isolation valves at the entry/exit to the tank farm are to be
closed and locked when transfers are not being conducted. Fuel transfer rate is about 40 gpm. A
discharge would be detected by visual observation.
1. Alert the School Site Principal / Head Teacher. The School Site Principal / Head Teacher
will notify YKSD Superintendent of Schools. The Superintendent will mobilize necessary
off-site resources of YKSD response contractor and/or the District Maintenance Department.
2. Conduct a site safety assessment. Set up safety perimeter as necessary. Use caution tape to
restrict access to spill zone.
3. Ensure ADEC is notified of the incident. If the discharge enters or threatens water, also
contact the U.S. Coast Guard (National Response Center).
4. Use handtools and materials from School spill kit to contain spilled fuel. Dig trenches and
build berms to restrict spill migration. Prevent spilled fuel from migrating toward any open
water or drainage channels. Contact the City for use of heavy equipment, if necessary.
5. Remove spilled fuel using the School’s portable pump and/or sorbent material. Store
recovered fuel and contaminated materials in 55 gallon drums. Ensure drums are stored in an
area with adequate secondary containment: on containment pallets or in a diked and lined
impound.
6. Conduct damage assessment and establish plans to: 1) remove transfer pipe from service
until repaired, 2) temporary use a mobile tank to fill the intermediate tank, 3) repair transfer
pipe, and 4) assess for spill zone for contamination as a result of the spill.
7. Arrange for proper disposal or recycling of all recovered fuel/oil, oily sorbents and other
oiled debris (Section 2.5).

2.2.2.2 Storage Tank Overflow (USCG Maximum Most Probable Discharge / EPA
Medium Scenario) Procedures applicable to tank overfill and/or equipment
failure - 33 CFR Part 154.1035 (b)(2)(ii)(B)&(G)
The tank farm impound is diked and lined and has net secondary containment volume of
approximately 65,000 gallons. Storage tanks are equipped with liquid level gauges. Marine
delivery is conducted in accordance with the procedures listed in the School’s Marine Transfer
Operations Manual. Prior to delivery a Declaration of Inspection is completed and transfer
procedures are reviewed with all personnel. During the transfer watchpersons monitor the
storage tanks, exposed piping, and header. The watchpersons maintain radio contact with the
barge. Marine delivery rate is approximately 300 gpm. It is estimated that equipment failure
combined and/or operator error could result in an overflow discharge of up to 1,500 gallons.
1. Immediately alert the barge crew to terminate fuel delivery.
2. Close all valves that allow product flow to the segment of the system causing the spill.

2-2-3 08/16
3. Remove all sources of possible ignition. If a fire or explosion hazard exists, clear the area,
and position fire response equipment.
4. Confirm the spill is contained in the tank farm impoundment area. Use sorbents and
handtools to limit the area of the spill and amount of contaminated soil within the tank farm.
5. Alert the School Site Principal / Head Teacher. The School Site Principal / Head Teacher
will notify YKSD Superintendent of Schools. The Superintendent will mobilize necessary
off-site resources of YKSD response contractor and/or the District Maintenance Department.
6. Ensure ADEC is notified of the incident. If the discharge enters or threatens water, the U.S.
Coast Guard (National Response Center) will also be notified.
7. If the spill escapes the tank farm impound area, block the drainage paths to prevent product
from approaching water or buildings. Predict the direction of flow and dig trenches and build
berms to block flow. Earthmoving equipment (backhoes, loaders, dump trucks) is available
from the City. Surface drainage surrounding around the tank farm is not well defined. From
the east and south sides of the tank farm, surface drainage appears to be the east, towards
Eighth Avenue. Drainage from the west and north sides of the tank farm is to the northwest
towards undeveloped tundra. Figure 2-2-1 illustrates drainage patterns and containment
areas.
8. Recovery:
 Recover spilled fuel with sorbents and/or pumps depending on the volume.
 If pumps are used, discharge recovered fuel either to empty barrels or to the Schools
portable bladder tank.
 If fuel has been spilled on snow, shovel the contaminated snow into any container
with an impermeable lining (dump truck, drums, trash bins, plastic bags, etc.).
 Determine depth and perimeter of heavily contaminated soil and remove. Store all
recovered material in an impervious temporary storage area.
9. In conjunction with ADEC, arrange for proper disposal and/or recycling of all recovered oil,
oily sorbents, and other oiled debris. Section 2.5 lists disposal requirements and options.

2.2.2.3 Spill at Marine Header or Pipeline During Delivery (USCG Worst Case
Discharge) Procedures applicable to failure of manifold, other transfer
equipment, or hoses, as appropriate - 33 CFR Part 154.1035 (b)(2)(ii)(A)(G)
The marine pipeline is buried three-inch diameter schedule 80, cathodically protected, welded
steel about 1,000 feet in length. The receiving header is about 75 feet from the river. Fuel is
transferred to the storage tanks by pumps on the barge. During marine delivery transfer
personnel maintain constant surveillance of the header, transfer hose, and header. Drip pans are
positioned beneath the receiving header and hose connections. Delivery rate is approximately
300 gpm. The Coast Guard worst case discharge planning volume is 1,884 gallons.
1. Alert the nearest barge tankerman to terminate pumping from the barge. Remove or turn off
sources of ignition.
2. Close header, pipeline, and storage tank valves.
3. Alert the School Site Principal / Head Teacher. The School Site Principal / Head Teacher
will notify YKSD Superintendent of Schools. The Superintendent will mobilize any
necessary off-site resources of the YKSD response contractor and/or the District
Maintenance Department.
4. Use sorbents and handtools from the School and barge to contain spilled fuel in the
immediate area. Dig trenches / berms to prevent oil from entering the river.

2-2-4 08/16
5. If spilled fuel enters the river, coordinate the response with the barge crew. All fuel barges
are required to maintain spill response equipment, including containment boom, skimmers,
and storage containers.
 If the spill is near the hose or barge, attempt to place the boom around the source.
 If the spill is large or uncontrollable, identify areas of potential impact and deploy
exclusionary and/or diversionary boom.
 Attempt to recover contained product with the barge skimmer and/or sorbents.
6. Cleanup techniques and/or protection priorities must be established. To establish priorities
local considerations must be assessed quickly and accurately. What are:
 current and developing safety considerations
 extent of spill and potential environmental/economic damage
 available manpower/equipment
 time required to mobilize additional resources
 the proximity of sensitive areas, probable impact locations, time to impact
 existing/developing weather & environmental conditions
7. If the spill is on water, work with the barge crew to deploy the barge containment boom in a
diversionary or containment configuration. Sheens on water may best be removed with
sorbents.
8. The barge crew should arrange for containers or storage tanks to receive the recovered
liquids.
9. In conjunction with the vessel person-in-charge arrange for disposal of all recovered oil, oily
sorbents, and other oiled debris. Section 2.5 lists disposal requirements and options.

2.2.2.4 Tank Failure (EPA Worst Case Scenario) Procedures applicable to tank
failure and explosion or fire - 33 CFR Part 154.1035 (b)(2)(ii)(C)(F)
1. Potential location and cause of spill, volume and product spilled
The EPA worst case discharge planning volume is 9,800 gallons - the shell capacity of the
School’s storage tank in the community tank farm.
The probability of tank failure or total release is considered to be low. All storage tanks were
installed to applicable code requirements, are inspected regularly, and maintained in good
condition. The tank farm impound is diked and lined, well designed, and provides
impervious secondary containment of approximately 65,000 gallons.
2. Procedures to Stop Discharge / Initial Actions (Notifications)
Procedures to stop the discharge would be predicated on the nature of the event. Personnel
safety would dictate all actions. Predicated upon circumstances, evacuate all potentially
threatened personnel to a designated area (Section 3.5).
Conduct no further immediate action if it will jeopardize personnel safety. All actions should
be documented in writing. Photographs should also be used to record the incident and
cleanup.
The initial Incident Commander (School Site Principal / Head Teacher) will conduct a
damage assessment and then contact notify the YKSD Superintendent of Schools. The
Superintendent will mobilize necessary off-site resources of the YKSD response contractor
and/or the District Maintenance Department.

2-2-5 08/16
The Superintendent and FSS will activate the School Response Team, and the appropriate
components of the YKSD Incident Command System (Section 2.3.3). The necessary
local/regional resources may be activated. The Coast Guard and ADEC will be notified.
When the spill site is stabilized, and conditions safe for personnel, the Incident Commander
will implement the response plan. He/she will organize and brief the Response Team on
containment and recovery actions. A site safety plan will be completed (Appendix 5).
3. Fire Prevention and Control Actions
Establish a spill zone perimeter and restrict access. In response to threat of explosion or fire:
expand the spill zone perimeter. Personnel safety will dictate all actions. Conduct no further
response action if it will jeopardize safety. Predicated upon spill location and circumstances,
evacuate threatened personnel to a designated area (Section 3.5).
Mobilize the volunteer fire department (543-2254) and School fire suppression equipment.
Fire extinguishers are positioned near the entrances to the tank farm, at the intermediate tank,
and throughout the School.
4. Direction of Flow / Potential Impact
Figure 2-2-1 identifies surface drainage patterns and potential containment points. Figure 2-
4-1 identifies sensitive areas in the vicinity. Section 2.4 describes sensitive habitats.
If spilled fuel escapes the tank farm impoundment, it will flow onto surrounding gravel pad.
Surface drainage surrounding around the tank farm is not well defined. From the east and
south sides of the tank farm, surface drainage appears to be the east, towards Eighth Avenue.
Drainage from the west and north sides of the tank farm is to the northwest towards
undeveloped tundra. A slough of Kaltag Creek is approximately 375 feet north of the tank
farm. The Yukon River is approximately 800 feet east of the tank farm. It is unlikely
navigable waters would be impacted by discharge in tank farm area. The impact would be
terrestrial contamination of the surrounding streets and tundra.
5. Containment and Control Actions
Protection of human and environmentally sensitive areas will be by prompt mechanical
response. Initial efforts will be directed at spill containment to restrict the migration of
spilled fuel and prevent oil from migrating towards developed areas or entering open water.
The following factors should be considered in making decisions about whether to proceed
with spill containment and control actions, and if so, to what extent:
 Safety of all responders.
 Accessibility for personnel and equipment.
 Biological and physical characteristics of contaminated shorelines.
 Will cleanup activities do more damage to sensitive shorelines than leaving the oil to
biodegrade naturally.
If terrestrial / shoreline containment is deemed feasible, it should be started as soon as
practicable to avoid excessive oil penetration into the soil. The primary containment strategy
is to contain spilled oil before it reaches any marine or sensitive environment. The
containment technique chosen depends upon the situation. The key to any containment effort
is to think and plan ahead. Make best use of time and available resources.
Containment dikes and trenches may be constructed with handtools and earthmoving
equipment. If spilled oil does reach open water, sorbent boom and sweeps should be

2-2-6 08/16
deployed at point of entry. The river current would likely restrict on water response actions
and rapidly disperse the refined product.
• Appendix 7 illustrates containment techniques.
School response equipment is stored in the mechanical building at the School. Additional
response equipment is stored by the other operators in the community tank farm and AVEC.
If spilled fuel does reach the water (during open water), deploy sorbent boom at point of
entry. If necessary, request additional resources from the ADEC equipment inventories in
Bethel, Mountain Village, and Aniak (Section 2.2.3).
6. Recovery Actions
Recover spilled fuel using portable pumps and sorbents from the School spill kit and local /
regional sources.
For terrestrial spills, direct suction with the pumps may be the initial method of liquid
recovery (where volume allows). Effective direct suction recovery generally requires oil to
be accumulated in quantities at least ½ inch deep. Spilled oil may be “herded” to recovery
sites with brooms and squeegees. Low pressure water flooding may be implemented when
standing product has been recovered. Heavily contaminated soils should be removed to a
lined and impervious storage area. Low pressure water flooding may be implemented when
standing product has been recovered. Heavily contaminated soils should be removed to a
lined and impervious storage area.
Sorbent material (sweeps and booms) will be the primary means of recovery of oil that enters
open water.
A Worksheet to Plan Volume of Response Resources for Worst Case Discharge is presented
in Section 2.2.3. It demonstrates that the School has access to the adequate resources to meet
federal planning requirements.
After the spill is contained and pooled product recovered, a site remediation program will
likely be required. The Incident Commander will regularly report the cleanup progress and
plans to the ADEC and EPA.
7. Recovered Product Transfer and Storage Options
Emergency contingency storage is available from four sources: 1) for small spills, the School
spill kit includes 3 ea. 85 gallon over drums and 1 ea. 55 gallon open top drum, 2) the School
spill kit also includes 1 ea. 1,000 gallon portable fuel bladder tank to meet contingency
storage planning requirements, 3) the community tank farm operators are to maintain an
empty 10,000 gallon skid-mounted storage tank located next to the tank farm, and 4) in an
emergency fuel could be consolidated within the School’s four storage tanks to make one
tank (7,000 gals.) available for emergency storage.
8. Disposal Options
State laws require that the responsible party collect and remove any oil and contaminated
debris and/or soil that result from an oil discharge.
The Incident Commander, in conjunction with ADEC, will develop an acceptable disposal
plan for contaminated material that cannot be recycled or disposed locally. Section 2.5
presents disposal options and requirements.

2-2-7 05/13
9. Actions to Protect Sensitive Areas
The terrain surrounding the tank has been previously disrupted by commercial development
(sewage lagoon), and is not considered environmentally sensitive. Kaltag Creek and the
Yukon River are the only habitats in the vicinity that are environmentally sensitive. The
actions to protect the creek and river will be mechanical containment of spilled fuel to
prevent it from reaching the water.
If it is apparent that wildlife may be threatened, alert the U.S. Fish and Wildlife Service and
the AK. Dept. of Fish & Game (Section 2.1.2).
Project spill trajectory and estimate impact times, and implement wildlife protection
strategies. Primary response strategies for wildlife protection emphasize controlling the
release and spread of spilled oil at the source to prevent or reduce contamination of
potentially affected species and/or their habitat. Primary strategies may include mechanical
cleanup and protective booming. In addition, primary response strategies include the
removal of oiled debris, particularly contaminated food sources (such as dead wildlife
carcasses and oiled vegetation) both in water and on land.
Secondary response strategies are to keep potentially affected wildlife away from oiled areas
through the use of deterrent techniques. These techniques may include visual methods
(placing scarecrows or helium-filled balloons on oiled beaches), auditory methods (firing
propane cannons), and other methods (herding wildlife with boats or aircraft).
If spilled fuel enters the creek or river, deploy sorbent and containment boom at the point of
entry to limit the area of impact. Appendix 7 illustrates boom deployment techniques.
The areas of human concern that could be impacted are identified in Section 2.4. They
include the several private homes and two City buildings east of the tank farm, and the
sewage lagoon northwest of the tank farm. Protective measures would be site evacuation and
mechanical containment of the spilled fuel. Section 3.5 is an Evacuation Plan.

2-2-8 05/13
FIGURE 2-4-1
IDENTIFIES ENVIRONMENTALLY
SENSITIVE AREAS

6 MARINE PIPELINE

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DETAIL: TANK FARM

U.S. SURVEY ;
No. 2351 AMENDED CONTAINMENT STRATEGIES
2 . • RlUie 2 1/r" lUI - - ,_ IIIIIIWDif
If'
w Terrastrial Containment- block flow-
<D fOUIID t vr JUMNU~~ tJN> ......,.. build dams, trenches.
• fQIIID &lr ... llOD @ Terrestrial Diversion- divert spill away
THE ON-SITE INCIDENT COMMANDER WILL DETERMINE THE from buildings, sensitive areas- dig/build
EVACUATION AREA AND PLAN - THE EVACUATION ROUTE WILL DEPEND -c> MIRJIIU
ON SPILL: VOLUME, LOCATION, AND WIND DIRECTION. I ~ UGMI'PIU: fj\ diversion paths and collection area.
FOR A DISCHARGE AT THE TANK FARM THE EVACUATION ROUTE AND f- #NY NCMOit ~ Marine Containment- deploy boom to
REASSEMBLY AREA WOULD BE "A" STREET TO THE WEST OR EAST, OR IOWitO contain spill at point of entry into water.
EIGHTH AVE TO THE SOUTH -AND WELL AWAY FROM THE SPill ZONE. • Si1IIIWII DIM
® Marine Diversion - deploy boom to divert
SHOULD THE NEARBY HOUSES OR CITY BUILDINGS NEED TO BE --,GHJI- .OWIIIIDD Dlt'IIIC uc IS" spilt to collection/recovery area.
EVACUATED THE SCHOOL COULD SERVE AS A REASSEMBLY AREA. I..:Y Marine Exclusion - deploy boom to
-r-AC.urc exclude/prevent spill from impacting or
_ , _ ~ MI.&N'.I.CICIIJIIN ~
entering a sensitive area.

SCHOOL PIPELINE C 1115 CU.._.., liS 1G11D

FIGURE 2-2-1.
U.S. SURVEY
t ~ No. 3172 SCHOOL SPILL RESPONSE SURFACE DRAINAGE,
t~.l EQUIPMENT STORED IN POTENTIAL CONTAINMENT POINTS &
!~ MECHANICAL I GENERATOR BLDG.
STRATEGIES, EVACUATION ROUTES
itt
!I SCHOOL

2~~
INTERMEDIATE TANK
li
~~------------------------------------------------------------------------------~------~----~~~~~~
2.2.3 Facility Response Equipment
Spill response equipment adequate to satisfy federal planning requirements is maintained by and
available to the School. The response equipment is stored in School’s mechanical / generator
building. All spill response equipment is to be maintained "operable and ready-for-deployment."
The initial deployment of response equipment can be made within 30 minutes of determination
that the safety of responders will not be jeopardized.
A visual examination and inventory of the School response equipment is to be conducted
monthly by the School Site Principal / Header Teacher, or designated alternate, as part of the
required fuel system inspection. The equipment is to be deployed and tested, in accordance with
response drill requirements described in Section 4.0 of this FRP. Equipment maintenance is to
be conducted when necessary, and after each deployment exercise to ensure the equipment is
operable and compatible.
Spill response equipment maintained by, and available to, the School includes:
CLASS TYPE / CAPACITY AMOUNT LOCATION
SORBENT MATERIAL Pads - 16"x20" 2 ea. bales Schl. mechanical bldg.
Rolls – 140’x30” 2 ea. bales “
Boom - 4 ea. 10’x4” sections p.bale 7 ea. bales = 280’ “
Sweeps 100’x19” 2 bales = 200’ “
RECOVERY – Two inch, portable, gas powered, 1 ea. “
UL listed centrifugal petroleum
PUMPS / HOSE pump – Marlow Petro-Guard Model
2AM32-P or equal w 2” gpm w two
inch camlocks, or comp. Rated at
150 gpm.
Discharge hose w 2” camlocks 100 feet “
Suction hose w 2” camlocks 50 feet “
STORAGE -CONTINGENCY 95 gal overpack poly drums 3 ea. – 285 gals. “
55 gal open-top drum 1 ea. – 55 gals. “
1,000 gal. portable bladder tank 1 ea. – 1,000 gals. “
DEPLOYMENT BOAT skiffs - readily available various Local residents
CONTAINMENT - EARTH- Grader, dozer, backhoe, loader, various City
MOVING EQUIPMENT dump truck
PERSONNEL PROTECTIVE Tyvek suits, gloves, goggles 4 ea. sets Tank farm connex
GEAR & MISCELLANEOUS boots, hardhats
Shovels, rakes, handtools Assorted “
Garbage/disposal bags 1 roll “
Fire extinguishers –portable 5+ ea. Tank farm, School
The School does not rely on response contractors to satisfy federal response equipment planning
requirements. It does rely on, by contract, Frontier Fuel Service (FFS) to provide trained
responders and ICS personnel. In the event of a major emergency, it is possible that additional
technical assistance and support equipment may be obtained from local or regional sources,
and/or response contractors.
 All barges that deliver fuel to the School are required to maintain approved Vessel Response
Plans. Equipment on board includes fabric-type containment boom equal to at least three
times the length of the vessel, skimmers, and contingency storage containers. The boom is
available when fuel is being delivered to the School.
 Alaska Village Electric Cooperative (AVEC) (561-1818) operates the Kaltag power plant. In
an emergency, response equipment stored at the AVEC plant could be made available
including sorbents, portable pumps and hose, storage containers, and support gear.
 Alaska Dept. of Environmental Conservation (269-3063 / 543-3215) has positioned 20' connex boxes
of spill response equipment at Aniak, Bethel, Mountain Village, and Toksook Bay. The equipment
may be activated by a call to ADEC. The equipment generally includes containment boom, pumps,
rope mop skimmer, hoses, generator, light stands, portable storage, and extensive support and
personnel protective gear.

2-2-10 08/16
EPA regulations require an evaluation of the likelihood that portions of the worst case discharge
planning volume (9,800 gallons) would reach navigable or open water via open channel flow or
from sheet flow across land, or be prevented from reaching water when trapped in natural or
man-made depressions excluding secondary containment structures. Regulations further state
that response resources shall, as appropriate, include containment boom, or sorbent boom, or
other methods for containing oil floating on water or to protect shorelines. Evaluation of
potential impacts to this site establishes the resources available to the Facility are appropriate
based on the following criteria.
1. The tank farm is about 800 feet west of the Yukon River. If spilled fuel escapes the tank
farm impound, it would flow onto surrounding gravel pad. Surface drainage surrounding
around the tank farm is not well defined. From the east and south sides of the tank farm,
surface drainage appears to be the east, towards Eighth Avenue. Drainage from the west and
north sides of the tank farm is to the northwest towards undeveloped tundra. A slough of
Kaltag Creek is approximately 375 feet north of the tank farm. The impact would be
terrestrial contamination of the surrounding streets and tundra. It is very unlikely that any
discharge at the tank farm would impact the river or other open water.
2. If spilled fuel does migrate to open water the impact would be a very light sheen. Sorbent
boom and sorbent sweeps are effective tools for containing and recovering sheens. Sorbent
boom can be transported and deployed with local resources more quickly and easily than
fabric boom. Sorbent boom is a better tool for terrestrial containment in both summer and
winter conditions than is fabric-type containment boom.
3. Deployment of fabric-type containment boom may present life-safety hazards when the
available means of deployment and experience of local responders are realistically
considered.
4. The delivery barge is on-site at all times when oil is being transferred in the marine pipeline.
All barges that deliver fuel to the School are required to maintain an approved Vessel
Response Plan that demonstrates to the State and Coast Guard that, at minimum, it has
capability to contain and control at least 15% of its cargo capacity within 48 hours. All
barges maintain fabric-type containment boom equal in length to at least three times the
overall length of the barge. The containment boom is available for deployment when fuel is
being delivered to the community tank farm.

EPA & USCG Response Resource Requirements


The EPA and Coast Guard Guidelines for Determining and Evaluating Required Response
Resources for Facility Response Plans are presented in 40 CFR, Part 112, Appendix E, and 33
CFR, Part 154, Appendix C, respectively. The required resource calculations for the School are
presented on the following page.

2-2-11 05/13
EPA & USCG Response Resource Requirements - Response Resource Worksheet
The EPA worst case discharge planning volume is 9,800 gallons (Section 2.2.1). The Coast
Guard worst case discharge planning volume is 1,884 gallons. For planning purposes, the larger
volume must be addressed. Response resources must be available to meet the discharge planning
volume as follows:
Part I - Background Information
Step (A) Worst Case Discharge Volume 9,800 gals.
Step (B) Oil Group # 1 non-persistent
Step (C) Geographic Area Rivers and canals
Step (D) Percentages of Oil
(D1) % Lost to Natural Dissipation .80
(D2) % Recover Floating Oil .10
(D3) % Oil Onshore .10
Step (E1) On-Water Recovery
Step (D2) x Step A 980 gals.
100
Step (E2) On-Shore Recovery
Step (D3) x Step A 980 gals.
100
Step (F) Emulsification Factor 1.0
Step (G) On-Water Recovery Resource
Mobilization Factor
(G1) Tier 1 .30
(G2) Tier 2 .40
(G3) Tier 3 .60
Part II On-Water Recovery Capacity (bbls. 3/ day) (must be maintained within region or contracted for)
Step (E1) x Step (F) x Step (G1)
Tier 1 (available within 12 hours) 294 gals.
Step (E1) x Step (F) x Step (G2)
Tier 2 (available within 36 hours) 392 gals.
Step (E1) x Step (F) x Step (G3)
Tier 3 (available within 60 hours) 588 gals.
Available contingency storage capacity must be twice the daily recovery capacity = 1,176 gals.
Part III Shoreline Cleanup Volume (bbls. / day) (must be maintained within region or contracted for)
Step (E2 x Step F) 980 gals.
The School satisfies response resource requirements by having access to the following equipment:
Containment
Marine – sorbent boom 240 feet, sorbent sweeps 200 feet, containment boom on barge
Terrestrial – Handtools at School – earthmoving equipment available from City.
Transfer / Recovery Equipment
1 ea. 2 inch transfer pump rated at 150 gpm.
Derated capacity = 150 gpm x .2 efficiency factor x 10 hours per day = 18,000 gals. per day
Storage
overdrums (3 ea. @ 95 gals. ea.) 285 gals.
open top drum (1 ea. @ 55 gals.) 55 gals.
bladder tank (1 ea. 1,000 gals.) 1,000 gals.
total 1,340 gals.

2-2-12 05/13
2.3 FACILITY RESPONSE ACTIVITIES
2.3.1 Response Organization / Personnel Responsibility
YKSD has designated a Qualified Individual and Incident Commander and alternates (Section 1.1).
As described below, these individuals shall work together to direct and manage response activities
for any discharge resulting from School operations.
The Qualified Individual (Q.I.) and Incident Commander (I.C.) shall be immediately notified in the event of
any oil spill resulting from School operations - regardless of volume or time! Contact numbers are listed on
page 1-2.

IN THE EVENT OF AN OIL SPILL


THE QUALIFIED INDIVIDUAL / INCIDENT COMMANDER SHALL:
INACCORDANCE WITH 40 CFR 112.20(H)(3)(IX)(A)-(H), THE INCIDENT COMMANDER AND QUALIFIED INDIVIDUAL(S)
SHALL BE TRAINED IN, AND BE FAMILIAR WITH THESE DUTIES:

1. Activate internal alarms, assess hazards, ensure safety of personnel (Section 3 & Appendix 5).
2. Activate the School Response Team, implement the spill response plan, and coordinate local
resources (Sections 2.2.2, 2.3). Mobilize the necessary off-site resources.
3. Mobilize the necessary components of the Incident Command Management Teams (Section
2.3.3).
4. Report the spill to government agencies, as required by state and federal law (Section 2.1).
5. Monitor the effectiveness of the cleanup and interface with agencies to ensure cleanup efforts
are "adequate" (Section 2.1.5). Acts as liaison with government agencies. Acts as initial Public
Information Officer and Safety Officer until duties are delegated.
6. Record basic spill information (Section 2.1.3).
7. Ensure recovered oil / contaminated materials are recycled or disposed properly (Section 2.5).
8. Complete and submit required written reports (Section 2.1.3).
Pending arrival of the designated Qualified Individual and Incident Commander, the School Site
Principal / Head Teacher or senior YKSD person at the site of the spill shall act as the initial on-site
Incident Commander.
Members of the School Response Team (Section 1.1) will be assigned cleanup duties by the
Incident Commander. The School Response Team is comprised of local YKSD personnel, FFS
personnel from Wasilla, and YKSD personnel from Fairbanks. YKSD response personnel are to be
trained in emergency response, safety, spill response, and this FRP. Team members in conjunction
with local resources are adequate to staff a response for seven days.
 Figure 2-3-1 summarizes the School spill response organization.
 Section 1.1 lists School Response Team members and phone numbers.
2.3.2 Qualified Individuals
In compliance Coast Guard and EPA regulations, YKSD has designated a Qualified Individual
(Q.I.) and alternate. Section 1.1 of this plan identifies the current Q.I. and alternate, and provides
contact information. This plan serves as the required documentation of the Qualified Individuals,
and confirms they meet requirements of Part 154.1026, and maintain the authority to:
 activate and engage in contracting with oil spill removal organizations
 act as a liaison with the predesignated Federal On-Scene Coordinator
 obligate funds required to carry out response activities

2-3-1 08/16
INITIAL ON-SITE &
INITIAL INCIDENT COMMANDER
(SCHOOL SITE PRINCIPAL / HEAD TEACHER)

YKSD SUPERINTENDENT OF SCHOOLS

INCIDENT COMMANDER
&
QUALIFIED INDIVIDUAL
(FFS)

SCHOOL
ADEC / EPA /
INCIDENT MANAGEMENT
COAST GUARD
TEAM
MONITORS
(FFS, YKSD)

SCHOOL RESPONSE
TEAM
(YKSD & FFS)

LOCAL REGIONAL
RESOURCES RESOURCES
(YKSD) (YKSD, FFS)

FIGURE 2-3-1. SCHOOL SPILL RESPONSE ORGANIZATION

2-3-2 08/16
2.3.3 Incident Command System
The Incident Command System (ICS) is an organized approach to emergency response
management. The ICS system has been adopted by the State of Alaska and is being incorporated
into private spill response plans nationwide. It identifies functions which may have to be performed
in an emergency and establishes common terminology. The ICS concept is built on teamwork and
coordination between the public and private sector through all phases of incident management. The
basic ICS principles and organization are described below.
Principles of Incident Command System
The ICS of the responsible party (spiller) is managed by the Incident Commander who is generally
the senior official responding to the spill. The government Incident Commander is the
predesignated On-Scene Coordinator. The State of Alaska has organized an incident command
system designed to monitor spills until such time it is determined the private spill response is not
adequate. Should that occur the State may become directly involved in the cleanup.
The ICS organization is functionally oriented around five major areas: Command, Planning,
Operations, Logistics and Administration. Staffing within the ICS is flexible and based upon the
requirements of the incident. The on-site initial Incident Commander is senior operator on-site. For
small incidents one person may perform all ICS functions. As required by the situation, the School
will mobilize its Incident Management Team including appropriate Function Section Chiefs and
Unit Leaders.
In the event of a major incident, the School Incident Commander and the On-Scene Coordinators
from ADEC and the Coast Guard, and a local representative, will be designated Unified
Commanders, and form the Unified Command. In order to expedite spill response decisions and
action, the Unified Commanders will have direct access to one another at all times.
The basic principles of ICS are:
1. Common terminology for personnel, organizational positions, and operational procedures.
Terminology is to be predefined and understood by all participants.
2. Common organizational structure that includes personnel of all participating companies or
agencies operating as a unified team.
3. Defined responsibility and authority for accomplishing specific functions.
4. Written action plans to accomplish overall objectives as well as those of each operating unit.
5. Integrated emergency management facilities and communications providing a managed
interjurisdictional response.
6. Personnel qualified and trained in the ICS principles, terminology, and implementation.
7. Manageable span of control. Ideally, the span of control of any crisis manager should range
from three to seven people. Anticipating change and preparing for it are vital to emergency
management, especially during rapid build-up of an organization when good management is
complicated by too many reporting elements.
8. Evaluation of Performance following the spill response.
Incident Management Team
The Incident Management Team will consist of Incident Commander, Section Chiefs for
Planning, Operations, Logistics, and Administration, and appropriate staff support. Depending on
the magnitude of the incident, one person may fill more than one of these positions. As an incident
escalates it may be necessary for the Incident Commander to organize a Command Staff, and for
Section Chiefs to assign tasks to Unit Leaders. The following subsections lists duties of the
Incident Management Team.
Incident Commander
The Incident Commander is on-site and responsible for overall management of all spill activities.
He directs the Incident Management Team, and approves the ordering and release of resources
(contractors and equipment). He approves Incident Action Plans, and communicates with
government agencies. As the situation warrants, the Incident Commander may organize a

2-3-3 05/13
Command Staff which may include an Information Officer, Legal Advisor, Safety Officer, and
Government Liaison Officer. General duties of the Incident Commander include:
1. Development and implementation of preliminary strategy for the incident immediately
following activation.
2. Conducting initial briefings which summarize incident organization, current activities,
resources deployed and enroute, and special instructions.
3. Coordination of staff and function activities.
4. Constant monitoring of the spill response and the development of alternative strategies with
the Incident Management Team.
Planning Section Chief
The Planning Section Chief is responsible for collection, evaluation, and dissemination of
information regarding the spill response and status of resources. He is responsible for the
development of Incident Action Plans which are to be prepared during the course of the spill.
Incident Action Plans establish and provide specific objectives, assignments, communication plans,
medical plans, transportation plans, and other specific tasks and data. As required by the situation,
the Planning Section Chief may appoint Unit Leaders to manage functions such as documentation,
resource assessment, demobilization and technical matters. General duties of the Planning Section
Chief include:
1. Establishing a planning section at the designated command center immediately following
activation.
2. Ascertaining the critical nature of the spill and beginning surveillance and trajectory
modeling. Identifying sensitive areas and developing priorities to protect such areas.
3. Documenting and collecting spill data from the inception of the incident through
demobilization.
4. Coordinating of damage assessments and establishing monitoring and sampling activities.
5. Tracking personnel, resources, and actions of contractors, and coordinating their activities
through Incident Action Plans.
Operations Section Chief
The Operations Section Chief is responsible for management of all tactical operations directly
affecting the spill and implementing the objectives of the Incident Commander and Incident Action
Plans. He directs all cleanup activities and coordinates response contractors. Unit leaders may be
appointed to monitor field operations. General duties of the Operations Section Chief include:
1. Ascertaining the nature of the incident, evaluating the effectiveness of current actions, and
ordering additional resources as needed.
2. Establishing and maintaining staging areas, and projecting resource requirements.
3. Coordinating with the Logistics Section Chief for needed services and support.
Logistics Section Chief
The Logistics Section Chief arranges support and material needs of the response, including, but not
limited to facilities, transportation, supplies, food, fuel, and medical services. Unit Leaders may be
designated to administer functions such as communications, security, supply, food, health and social
services. General duties of the Logistics Section Chief include:
1. Establishing and maintaining the designated command and response center.
2. Coordinating with the Planning and Operations Section Chiefs and ordering, receiving,
storing and processing response equipment, personnel and supplies. Verifying
accountability and security of resources.
3. Establishing and maintaining communication networks with command center and field
operations.
4. Providing for sanitation and food service for spill work force.
5. Developing medical plans which address medical emergency procedures for the work force.

2-3-4 05/13
Administration Section Chief
The Administration Section Chief is responsible for all financial and administrative aspects of the
spill response, including procurement, clerical support, contracts, compensation, claims, data
processing and cost analysis. Management of specific tasks will likely be delegated to Unit Leaders.
Duties of the Administration Section Chief include:
1. Protecting the interest of the School in all financial matters.
2. Providing accounting functions including billings, invoice payment, and documentation of
labor, materials and services.
3. Establishing and administering vendor contracts and rental agreements.
4. Initiating investigation and documentation of claims.
Public Information Officer
The Public Information Officer (PIO) manages and distributes information regarding the incident.
Duties of the PIO include:
1. Serves as clearing point for dissemination of information. Interfaces with counterparts in
the Unified Command, media, appropriate agencies and the community.
2. Coordinates approval of the Unified Command prior to release of information to media.
3. Organizes/conducts Unified Command media briefings, town hall meeting, etc. Works to
develop supporting documents (maps, graphs, etc.).
4. Resolves conflicting information and identifies media concerns to the Unified Command.
Safety Officer
The Safety Officer develops safety plans and assesses hazards and safety conditions on an ongoing
basis. Duties of the Safety Officer include:
1. Develops and implements a site safety plan per OSHA requirements. Assesses
environments/conditions to determine the level of personal protective equipment (PPE).
Works with Unified Command counterparts to insure consistency of safety standards. Has
the authority to override decisions made by IC if deemed “unsafe”.
2. Supervises safety-related activities. Insures response personnel are adequately briefed
regarding safe working practices. Insures compliance as necessary to meet OSHA
regulations related to worker safety.
3. Establish decontamination procedures and contamination reduction zones for all on-scene
personnel and equipment.
Government Liaison Officer
The Government Liaison Officer serves as the initial point of contact for participating state and
local agencies. Duties of the Liaison Officer include:
1. Serves as a buffer to the IC. Receives/coordinates calls from agencies and private response
entities offering assistance or requesting information.
2. Identifies public and private response entities concerns regarding the status and effectiveness
of response to the incident.
3. Maintains an incident response summary distribution list for public and private response
entities information.
 Figure 2-3-2 illustrates the basic components and duties within the ICS system.

2.3.4 Response Contractor Information


YKSD does not rely on response contractors to satisfy federal response equipment planning
standards. YKSD has contracted Frontier Fuel Service (FFS) to provide spill response personnel
and expertise at all schools. FFS services include on-site maintenance, required inspections and
tests, training, and spill response including Qualified Individual responsibilities and authority. FFS
is a Wasilla based corporation organized to contract for the operation and maintenance of rural
Alaskan bulk fuel storage facilities.

2-3-5 08/16
INCIDENT
COMMANDER
COMMAND
• Set Policy, Establishes Objectives
STAFF
• Develops Response Strategies
• Approves Incident Action Plans • Information Officer - media contact
• Commits Funds • Legal advisor - legal implications
• Coordinates Function, Staff Activities • Safety Officer - worker health & safety
• Conducts Briefings, Coordinates with OSC • Government Liaison - local agency
contact/coordinator

PLANNING OPERATIONS LOGISTICS ADMINISTRATION


SECTION CHIEF SECTION CHIEF SECTION CHIEF SECTION CHIEF

• Response planning • Implements action plan Arranges: • Office management


• Provides information to • Directs field operations • Communication • Accounting functions
Command • Provides information to • Security • Contracts and rental agreements
• Spill surveillance and tracking Command • All transportation • Staff personnel
• Identifies sensitive areas • Establishes staging areas • Equipment and fuel needs • Claim documentation
• Identifies response needs • Anticipates necessary response • Facilities • Data management
• Develops incident action plan • Coordinates for needed services • Food • Response documentation
• Conducts Damage Assessment and support • Emergency medical services
• Monitors contractors • Monitors contractors • Support services
• Equipment inspection &
maintenance
• Demobilization/salvage

UNIT LEADERS UNIT LEADERS UNIT LEADERS UNIT LEADERS

FIGURE 2-3-2. INCIDENT COMMAND SYSTEM

2-3-6 05/13
2.4 SENSITIVE AREAS
2.4.1 Sensitive Areas and Protection Measures
Planning Distances
The EPA and Coast Guard "planning distance" for facilities near non-tidal water is the downriver
distance that could be impacted at maximum current in 27 and 24 hours respectively. Facilities are to
identify resources to protect potentially impacted areas within the required planning distances.
Assuming a two-knot current, the EPA planning distance is 62 miles downriver and the Coast Guard
planning distance is 55 miles downriver. The creditability of these mandatory planning distances is
suspect when applied to small fuel facilities in rural Alaska. Existing regulations do not consider the:
(1) comparatively small potential discharge volumes, (2) the distance of the tank farms from navigable
water, (3) dispersion rate of refined fuels, and (4) variable currents.
• Figure 2-4-1 illustrates the planning area in the vicinity of the School.
• Section 2.4.3 is a Vulnerability Analysis, prepared in accordance with 40 CFR, Part 112, Appendix
F, which identifies potentially threaten areas and protection measures.
• The Interior Alaska SubArea Contingency for Oil and Hazardous Substance
Discharge/Releases identifies sensitive areas, contacts, priority protection areas, and land
management maps. The plan is accessible at http://dec.alaska.gov/spar/perp/plans/scp_int.htm
• Maps in the plan are at: http://www.asgdc.state.ak.us/maps/cplans/subareas.html
Sensitive Areas
The terrain surrounding the tank has been previously disrupted by commercial development (sewage
lagoon) and is not considered environmentally sensitive. The only environmentally sensitive areas that
could realistically be impacted by a discharge from School operations are the Yukon River which is
about 800 feet west tank farm and a slough of Kaltag Creek is about 375 feet north of the tank farm.
The Rodo River drains to the Yukon River about 3½ miles south of Kaltag, but the chances are remote
that a spill from School operations could impact the river.
Actions to protect sensitive areas would be terrestrial containment at the spill site. If spilled oil enters
open water, the protection measures would be deployment of sorbent boom and sweeps, and activation
of additional response resources, as necessary.
Kaltag is across the Yukon River from the Innoko National Wildlife Reserve. The entire area is an
important breeding and resting spot for migratory waterfowl. No nesting areas or critical habitat are
within close proximity to the tank farm or pipelines. If it is apparent that wildlife may be threatened,
the U.S. Fish and Wildlife Service and the AK. Dept. of Fish & Game shall be alerted (Section 2.1.2).
The primary response strategies for wildlife protection emphasize controlling the release and spread of
spilled oil at the source to prevent or reduce contamination of habitat. In addition, initial response
strategies include the removal of oiled debris, particularly contaminated food sources (such as dead
wildlife carcasses and oiled kelp) both in water and on land. Secondary response strategies are to keep
potentially affected wildlife away from oiled areas through the use of deterrent techniques. These
techniques may include visual methods (placing scarecrows or helium-filled balloons on oiled
beaches), auditory methods (firing propane cannons), and other methods (herding wildlife with boats
or aircraft).
Kaltag is an Athabascan village with approximately 250 residents. The tank farm is about 800 west of
Yukon River, adjacent to several residential structures, city buildings and the sewage lagoon (Figure 2-
2-1). "Human populations" that could be impacted by a discharge include persons near the spill
location, which could include all people within the vicinity of the tank farm, dispensing station,
pipeline, and nearby buildings. Actions to protect human populations would be to establish safety
perimeters, and clear or evacuate the area, as described in Section 3.5. Down river human populations
that could realistically be impacted are very limited. Other than a few seasonal cabins and fish camps,

2-4-1 05/13
the closest settlement is Grayling more than 100 miles downriver. Attempts will be made to notify all
areas and residents if they are threatened by a spill from School operations.
No surface "water intakes" could be impacted by a discharge from School operations. The City water
supply is from a well / intake located more than a half mile northwest of the tank farm. There are no
other wells within at least 300 feet of the tank farm. Protection measures for any area threaten by a
discharge will be spill prevention, prompt spill response, terrestrial containment, and appropriate
remediation programs of contamination.
There are no identified archaeological sites within close proximity of the community tank farm.
Questions regarding historical or archaeological sites should be directed to the Alaska Office of
History and Archaeology (Section 2.1.2).
"Severity of Consequences" of a discharge resulting from tank farm operations would, most likely, be
limited to surface contamination. Containment and recovery operations would be initiated upon
detection. If necessary, a soil remediation program would be developed in conjunction with agency
personnel and consultants.
Threaded, Endanger Species
No threaded or endangered species inhabit the vicinity around the tank farm.
There is no state designated critical habitat or “Most Environmentally Sensitive Areas’ (MESA) in the
vicinity.

2.4.2 Area Contingency Plan


This Facility Response Plan is consistent with the State / Federal Unified Plan and the Interior Alaska
SubArea Plan for Oil and Hazardous Substance Discharge/Releases . This Plan is to be updated if the
Unified or the SubArea Plan are amended to identify additional sensitive areas within a reasonable
planning distance from the Facility.
The plans are accessible at: http://www.akrrt.org/plans.shtml

2-4-2 05/13
2.4.3 Vulnerability Analysis*
Site / Potentially Location / Distance Notification (Section 2.1)
Environment Threaten From Facility Containment / Response
Y/N (map on following page & Figs. 2-2-1, Appdx-1) Measures
NOTIFY SITE PRINCIPAL/HEAD TEACHER OF ALL SPILLS

1. water intakes N City water intake is >½ mile NW of tank farm

2. schools N School is 2,000 feet SE of tank farm

3. medical facilities N Clinic is 1,000+ feet SE of tank farm

4. residential area Y several residents on Eight Ave. and evacuate if threatened - establish safety perimeter
“C” St. - across street from tank farm build dikes/trenches to contain spill

5. businesses Y buildings and sewage lagoon evacuate if threatened - establish safety perimeter
adjacent to tank farm build dikes/trenches to contain spill

6. wetlands / sensitive areas Y Yukon River – 800 feet E of tank farm & block surface flow - deploy boom at point of entry -
tundra, Kaltag Creek N&W of tank farm notify agencies - activate additional resources

7. fish and wildlife Y same as above "

8. lakes and streams Y same as above "

9. endangered flora - fauna N

10. recreational areas Y same as above "

11. transportation routes Y nearby roadways and paths block access - evacuate if threatened - establish
safety perimeter - build dikes/trenches to contain

12. utilities Y sewage lagoon “

13. other - N

*source (40 CFR, Part 112, Appendix F)

2-4-3 02/12
2.5 DISPOSAL PLAN

2.5.1 Disposal Options / Requirements


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

2-5-1 05/13
3.0 HAZARD EVALUATION
3.1 SPILL HISTORY
No reportable oil spills (spills to navigable water) have occurred from School operations of the
current Facility.
Section 2.1.3 of this FRP lists spill documentation and report requirements.

3.2 POTENTIAL SPILLS


A discharge could result from operator error, equipment failure, vandalism, or catastrophic event.
The reasonably expected modes of major failure, rupture or accident in which oil could be spilled
are listed below. All storage tanks were installed to applicable code requirements, are inspected
regularly, and maintained in good condition. The tank farm impound is diked and lined and
provides secondary containment of approximately 65,000 gallons. The intermediate tank at the
School is a double wall UL tank with liquid level gauge, float actuated fill-limiting valves and
high level shut off switches that stop the transfer pump. All tank filling and transfers are
manually initiated and visually monitored. Pump shutdown controls are in close proximity to
transfer locations. Both the marine and intermediate tank transfer pipelines are welded steel.
Bottom-penetration valves on storage tanks and transfer pipeline isolation valves at the entry/exit
to the tank farm are to be closed and locked when transfers are not being conducted. The marine
pipeline is buried, cathodically protected, and integrity tested annually.
SOURCE POTENTIAL VOLUME RATE OF FLOW DIRECTION OF FLOW
STORAGE TANKS
TANK LEAK OR 9,800 gals. = nominal Variable Spilled oil should be contained in the diked
FAILURE
capacity of largest and lined impound. If spilled oil escapes the
storage tank. impound it would drain onto the surrounding
gravel pad. Surface drainage surrounding
around the tank farm is undefined. From the
east and south sides of the tank farm, surface
drainage is to be the east, towards Eighth
Avenue. Drainage from the west and north
sides of the tank farm is to the northwest
towards undeveloped tundra.
OVERFLOW 1,500 gals.± = assume 5 Barge transfer Same as above
minutes to detect and rate = 300
shutdown gpm±
INTERMEDIATE TANK
TANK LEAK OR 6,000 gals. = nominal Variable Oil spilled from a leak or fracture of the
FAILURE
capacity of intermediate primary tank would be contained in the
tank. double wall containment structure. If oil
escapes the containment structure it would
drain to and accumulate around the level
gravel pad beneath the tank.
OVERFLOW 200 gals.± = assume 5 Tank fill rate = Same as above
minutes to shutdown 50 gpm+/-
TRANSFER PIPE TO INTERMEDIATE TANK
PIPE RUPTURE / 1,500 gals. = assume 30 Transfer rate Spilled oil would percolate into the sandy,
FRACTURE DURING minutes to detect and 50+/- gpm. silty soils and/or migrate with the surface
terrain.
TRANSFER shutdown
MARINE PIPELINE
PIPE RUPTURE / Coast Guard worst case Barge transfer Pipeline is buried.
FRACTURE DURING discharge planning rate = 300
TRANSFER volume is 1,884 gals. gpm±

3-1 05/13
3.3 EMERGENCY SHUTDOWN SYSTEMS
Delivery of product to the storage tanks is controlled by pumps aboard the barge. Emergency
shutdown may be initiated by radio and/or verbal contact to the vessel. During product delivery,
shoreside personnel maintain radio contact with vessel personnel. Transfer of product can be
terminated within less than 30 seconds of notice. Flow in the marine pipeline is controlled by:
(1) check and ball valves the receiving header, (2) ball valves on the pipeline where it enters the
tank farm, and (3) ball valves and flex connectors at each tank. Following each barge delivery,
the marine delivery pipeline is blown with air to purge the line of fuel.
Delivery of product to the intermediate tank is controlled by a centrifugal pump in the
community tank farm. Pump shutdown controls are located on the intermediate tank and in the
tank farm pump control panel (Appendix 1, Figure A1-3).

3.4 FIRE SUPPRESSION EQUIPMENT


Portable fire extinguishers are to be maintained near the access gates to the tank farm and
intermediate tank. During marine delivery, a fire extinguisher is to be placed near the marine
header. Tanks are to be marked to identify type of fuel contained in the tank, tank capacity, and
tank number. No smoking, warning, spill notification are to be posted.
The on-site Incident Commander is designated Fire Fighting Coordinator. In the event of
potential fire, notification shall be made to the City and volunteer fire department (Section 1.2)
in order to coordinate community plans.

3.5 EVACUATION PLAN


A significant oil discharge or fire at the community tank farm could warrant area evacuation.
The tank farm is on the northwest side of the community removed from most development
except for some residential structures to the east and southeast; two City buildings (garage and
storage) to the east, and the sewage lagoon to the northwest of the tank farm (Figure 2-2-1).
The on-site Incident Commander will determine the immediate need for site evacuation and
implement an initial evacuation plan. If evacuation is warranted, it will be initiated by voice.
Persons who may be in the spill area will be instructed to evacuate in an upwind direction. If
necessary the City and VPSO will be alerted to assist with the evacuation. Personnel will be
directed to reassemble for a centralized check-in and evacuation validation (roll-call).
The evacuation route and reassembly area would likely “A” Street to the east or west, or Eighth
Avenue to the south; and then well away from the spill zone. Should the nearby houses or City
buildings need to be evacuated the School could serve as a reassembly area.
When the immediate spill area has been cleared, and based on the circumstances of the event, the
Incident Commander will determine if an expanded evacuation or further actions are warranted.
If a significant or uncontrolled discharge occurs, the following actions may be implemented:
• Access to the spill area will be blocked to all unauthorized traffic.
• Safety perimeters will be established. Only authorized personnel allowed to enter the
spill zone.
In the event of any major emergency (tank failure/fire) the Alaska Div. of Emergency Services
(428-7000) should be notified to provide coordination with existing community and regional
plans.

3-2 05/13
3.6 PERSONNEL SAFETY
Personnel safety is the highest priority in all operations. Under no circumstances will School
personnel actively respond to discharges that present an unknown, or hazardous environment, or
which may require confined space entry. In response to such events, a qualified response action
contractor will be activated.
A Material Safety Data Sheets (MSDS) for diesel fuel is in Appendix 5 of this Plan. MSDS's
provide physical data, fire, explosion, and reactivity information, spill procedures, and most
special precautions. Refer to the MSDS if there are questions regarding safe handling or
exposure to diesel fuel.
All discharges of petroleum are dangerous to a certain extent. Accumulations of hydrocarbon
vapors can have an adverse effect on personnel. The sense of smell is dulled and symptoms of
diminished responsibility and dizziness similar to drunkenness, with headaches and eye
irritation, are common. High vapor concentrations can cause suffocation, paralysis, and possibly
death.
Chemical burns may be caused by repeated or continuous contact of the skin with petroleum
products, therefore protective clothing should be worn by workers in the spill zone. Protective
gear should include rain gear (or other impermeable clothing), rubber boots, impermeable work
gloves, and possibly a face mask.
Spill responders should never work alone. A zone of safety should be established around the
spill, and only persons authorized for cleanup work allowed within this zone. The perimeter of
this zone will be predicated on location and magnitude of the incident, however, it should be well
beyond vapor, fire, or explosion danger.
In accordance with OSHA regulations, a written site safety plan is to be developed for each
response to a release of hazardous materials. A copy of an acceptable site safety plan format is
contained in Appendix 5 of this Plan.

3-3 05/13
4.0 TRAINING AND DRILLS
4.1 OPERATOR TRAINING
The YKSD Superintendent of Schools is ultimately is accountable for spill prevention and response
training at all schools. YKSD has contracted Frontier Fuel Service (FSS) to provide spill prevention,
response, and compliance assistance at all schools. FFS services include on-site maintenance, required
inspections and tests, training, and spill response including Qualified Individual responsibilities and
authority. FFS personnel are to conduct spill prevention and response training at as described below.
All School personnel are to be instructed in operations, maintenance, and spill prevention procedures
pertinent to their duties. Training is to be provided at the start of employment and at least once a year,
thereafter. At minimum, the training should address the following topics.
A. Pollution control laws, rules, and regulations
B. Fuel Storage Systems:
1. Purpose and application
2. System elements:
a. Tanks
b. Pumps
c. Accessory equipment
3. Operation and maintenance of equipment
4. Fuel transfer procedures
C. Spill Prevention and Control:
1. Potential spill sources
2. Procedures to prevent spills
3. Review of control measures:
a. Secondary containment
b. Safety valves
c. Pump shutoff switches
D. Emergency response procedures:
1. Initial spill response / notification procedures
2. Personnel safety – MSDS review
3. Location and use of emergency phone numbers
4. Location and use of fire extinguishers
5. Location and use of spill cleanup materials
6. Review of facility spill prevention and response plans
7. Local spill response resources

4.2 SPILL RESPONSE TRAINING


Members of the School Response Team are to participate in an annual spill response training program
that also addresses safety and discharge prevention training. The training program may vary from year
to year, however, at minimum, it is to address the following topics:
 Spill Prevention & Response Plans - Facility Response Plan, SPCC Plan, Operations Manual
 YKSD Response Organization – Incident Command System
 Potential Spills and Response Actions
 Discharge Prevention, Operating Procedures
 Regulatory Requirements - Spill Reporting
 Health and Safety Considerations
If volunteers or casual labors are employed during a spill response, they are to be trained to the
applicable OSHA standards listed in 29 CFR Part 1910.120.
Qualified Individual Training: In accordance with 40 CFR 112.20(h)(3)(ix)(A)-(H), the YKSD
Qualified Individual and Alternates are to be trained in implementation of this plan and their duties
including: hazard identification, assessment, and communication systems; response mobilization and
organization; notification requirements; spill containment and recovery considerations; and
coordination of rescue and response actions previously arranged with response personnel.

4-1 08/16
4.3 SPILL DRILLS, EXERCISES
The National Preparedness for Response Exercise Program (PREP) is an effort to clarify and
coordinate EPA and Coast Guard spill drill requirements. Compliance with the PREP requirements
listed below satisfies all spill drill and exercise requirements. To comply with PREP requirements,
training must be provided to individuals/positions with specific duties in this plan.
YKSD satisfies PREP requirements as follows:
PREP REQUIREMENT YKSD PROGRAM
Qualified Individual Notification YKSD has designated FFS the responsibility and authority to serve
Drill – quarterly as Qualified Individual (Q.I.) and alternate for all schools.
The purpose of Q.I. Notification Drills is to ensure Q.I.’s can be
contacted promptly by YKSD School and District personnel in the
event of a discharge. FFS will initiate and document quarterly Q.I.
Notification Drills with School and YKSD District personnel.
Equipment Deployment Drills - The School Response Team is to conduct semiannual equipment
semiannually deployment drills. The equipment necessary to respond to a small
or average most probable discharge (Section 2.2.1) is to be
deployed. In accordance with PREP requirements, actual spill
response with equipment deployment may satisfy equipment drill
requirements. FFS will assist and document required equipment
deployment drills.
Spill Management Team Tabletop Section Chiefs of the School Incident Command Organization are to
Exercise - annually participate in an annual Tabletop Exercise, which may be part of the
annual spill response training program. FFS will initiate and
document quarterly annual Tabletop Exercises with School and
YKSD District personnel.
Unannounced Drills – as School personnel will cooperate with the EPA and/or USCG in
requested by EPA or USCG conducting unannounced drills and exercises.

Triennial Exercise Once every three years the School is to conduct an exercise that
tests the entire response plan, including Organizational Design,
Operational Response, and Response Support. FFS will initiate and
document Triennial Exercises with YKSD personnel.
 "Fact sheets" that detail the requirements for the above PREP requirements are on the following pages.
 Appendix 6 contains sample training documentation forms that may be used to satisfy record keeping
requirements. Records sufficient to document the required training must be maintained for a period of 5
years, and must be available for inspection upon agency request.
4.4 COAST GUARD PERSON-IN-CHARGE TRAINING
To comply with Coast Guard regulations (33 CFR, Part 154.710), the YKSD and vessel persons-in-
charge of marine transfers must have had a minimum of 48 hours of experience in oil transfer
operations, and, at minimum, they must know:
(1) The hazards of each product transferred;
(2) The rules in 33 CFR, Parts 154 and 156;
(3) The facility operating and fuel transfer procedures;
(4) The oil barge transfer systems (in general);
(5) The oil barge transfer control systems (in general);
(6) The facility oil transfer control systems;
(7) Oil spill reporting procedures;
(8) The facility oil spill contingency plan procedures.
In accordance with 33 CFR Part 154.740, written certification shall be maintained that each designated
person-in-charge has completed the training requirements of Part 154.710. A sample copy of an
acceptable certification form is in Appendix 6.
4.5 PREP TRAINING FACT SHEETS
Refer to the following pages.
 Q.I. Notification Drill - quarterly
 Spill Management Team Tabletop Exercise - annually
 Equipment Deployment Drills - semiannually
 Unannounced Drills - as requested by the EPA or USCG

4-2 08/16
QI NOTIFICATION DRILLS

COAST GUARD & EPA REGULATED FACILITIES

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

4-3 05/13
SPILL MANAGEMENT TEAM TABLETOP EXERCISE
COAST GUARD & EPA REGULATED FACILITIES

Applicability: - Facility Spill Management Team


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

4-4 05/13
EQUIPMENT DEPLOYMENT DRILLS
COAST GUARD & EPA REGULATED FACILITIES

Applicability: - Facilities with facility-owned response equipment


Frequency: - Semiannually
Initiating - Company Policy
Authority:
Participating - Facility Personnel
Elements:
Scope: - Deploy and operate facility-owned response equipment identified
in the response plan. Only a representative sample of each type
of equipment or that which is necessary to respond to an EPA defined
small discharge, whichever is less, need be deployed.
- The remainder of the equipment which is not deployed must be
included in a comprehensive training and maintenance program.
Credit will be given for deployment conducted during training.
The maintenance program must ensure that the equipment is
periodically inspected and maintained in good operating condition
in accordance with manufacturer’s recommendations and best
commercial practices. All inspection and maintenance must be
documented by the owner.

Objectives: - Demonstrate ability of facility personnel to deploy and operate


equipment.
Certification: - Self Certification
Verification: - Verification to be conducted by appropriate oversight agency
during periodic site visits.
Records:
Retention: - 3 Years (USCG)
5 Years (EPA)
Location: - At facility.
Evaluation: - Self Evaluation.
Credit: - Plan holder may take credit for this exercise when conducted in
conjunction with other drills as long as all objectives are met and
a proper record generated. Likewise, credit may be taken for an
actual spill response when these objectives are met and a proper
record generated.

Note: If a facility with facility-owned equipment also identifies OSRO equipment in


their response plan, the OSRO equipment must also be deployed and operated in
accordance with the equipment deployment requirements for OSRO owned
equipment.

4-5 05/13
UNANNOUNCED DRILLS
COAST GUARD & EPA REGULATED FACILITIES

Applicability: - Response Plan holders within the Area


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

4-6 05/13
APPENDIX

1. FACILITY SPECIFIC INFORMATION


1.1 Facility Description ..................................................................... A1-1
1.2 Facility Plot Plan ......................................................................... A1-3
1.3 Valve Identification ..................................................................... A1-3
1.4 Product Information .................................................................... A1-3

2. LIST OF CONTACTS
2.1 Key Personnel - Qualified Individuals ......................................... A2-1
2.2 Federal, State, Local Officials ..................................................... A2-1
2.3 Response Contractors ................................................................ A2-1

3. EQUIPMENT LIST AND RECORDS


3.1 Facility Response Equipment ..................................................... A3-1

4. COMMUNICATIONS PLAN
4.1 Communications Plan / Equipment............................................. A4-1

5. SITE-SPECIFIC SAFETY AND HEALTH PLAN


5.1 Site Safety Plan .......................................................................... A5-1
5.2 Material Data Safety Sheet ......................................................... A5-1

6. DOCUMENTATION FORMS
6.1 Spill Report / Notification Form ................................................... A6-1
6.2 Facility Inspections ..................................................................... A6-1
6.3 Training ...................................................................................... A6-1

7. SIMPLIFIED CLEANUP TECHNIQUES ..................................................... A7-1

APPENDIX 05/13
APPENDIX 1
FACILITY SPECIFIC INFORMATION
1.1 Facility Description
• Figure 1 is a location map.
• Figure 2 is an area plan with tank farm detail.
• Figure 3 is a piping plan.
The Yukon Koyukuk School District (“YKSD”) operates the Kaltag School (“School”) and its
related oil storage tanks and piping which supply fuel for school heat and backup power
generation. Diesel fuel is the only oil stored in bulk. Total annual fuel throughput is about
18,000 gallons.
The School fuel system (“Facility”) consists of four vertical tanks in the community tank farm
which provide total nominal storage capacity of 34,100 gallons, and a 2,500 foot pipeline which
supplies a 6,000 gallon intermediate tank at the School. The community tank farm also contains
fuel storage tanks that are separately owned, operated, and maintained by the City of Kaltag and
Kaltag Cooperative. Fuel is delivered to the community tank farm by barge via a 1,000 foot
marine pipeline which is individually operated by the three tank farm operators when fuel is
being delivered to their respective tanks.
The community tank farm, marine pipeline, and the School pipeline and intermediate tank were
installed in 1998/9 as part of a State of Alaska bulk fuel upgrade project. The upgrade project
included preparation and submittal of a Facility Response Plan (“FRP”) for the community tank
farm as a single, co-located, cooperatively operated entity. The 1999 FRP was in place until
2013, at which time YKSD elected to prepare this FRP which specifically covers the School fuel
system components and regulatory requirements for which YKSD is responsible.
The School receives fuel by marine delivery normally once. There is no dock, therefore the
barge beaches or anchors near shore and extends its hose to the marine pipeline fill point
connection (header). All School fuel is transferred by pipeline to the intermediate tank at the
School. Pipeline transfers to the intermediate tank at the School generally occur once a month.
No marine fueling is conducted from the Facility.
Bulk Storage Tanks / Secondary Containment
The School bulk fuel storage consists of the following tanks:
TANK DIAMETER VERTICAL / REHAB OR CAPACITY
LOCATION X PRODUCT INITIAL
NO. HORIZONTAL (GALS)
HGHT-LENGTH SERVICE DATE
ST-11 TANK FARM 9.5’ x 13’ 10” V DIESEL 1998/9 7,300
ST-12 “ 10’ x 13’ 10” “ “ “ 8,100
ST-13 “ 11’ x 13’ 10” “ “ “ 9,800
ST-14 “ 10.5’ x 13’10” “ “ “ 8,900
Tank Farm Total: 34,100
IT-1 SCHOOL 7’ x 17’ H DIESEL 1998/9 6,000
School Total 40,100

The original date of purchase and/or service of the vertical tanks are unknown. In 1998 they
were relocated from existing local service and entirely refurbished. Each vertical tank was
drained, cleaned, and visually inspected, internally and externally, for evidence of corrosion and
for weld integrity. Necessary repairs were made and new appurtenances installed. The tanks

A1 - 1 05/13
were sandblasted and painted. The intermediate tank package was purchased and installed in
1998.
The four vertical tanks are “BIA” type tanks that are equipped with normal and emergency vents,
water draw valves, three-inch fill connections, and gauges. They are positioned on treated
timbers on grade.
The 6,000-gallon intermediate tank at the School is a horizontal, double wall, skid mounted UL
tank. It is equipped with liquid level gauge, float actuated fill-limiting valves and high level shut
off switches that stop the transfer pump.
The vertical tanks are within the community tank farm which is a diked and lined impound
approximately 85’x 65’. It is surrounded by an earthen dike approximately two-feet high. The
impound floor and dike walls are covered with a fuel resistant liner that is covered with gravel.
The net capacity of the impound is approximately 65,000-gallons, which provides containment
for the contents of the largest tank plus more than 12-inches of freeboard for precipitation.
Drainage within the impound is to a collection sump at the southeast corner of the tank farm.
Accumulated storm water is removed from the sump with a hand or portable pump.
Secondary containment for the intermediate tank at the School is provided by its double wall
structure and redundant overfill protection devices. All transfers to the intermediate tank are
manually initiated and visually monitored by an operator who has direct access to pump
shutdown controls.
Marine Pipeline, Fill / Distribution Piping, Transfer Pipe to Intermediate Tank
Fuel is delivered to the School storage tanks via a three-inch marine pipeline that extends about
1,000 feet from the tank farm to a marine fill point header located about 75 feet from the river.
The pipe is buried, schedule 80, welded steel that is coated and cathodically protected with
magnesium anodes. The marine header is a capped camlock fitting with three-inch check and
ball valves. A steel, two-barrel drip pan (spill box) is positioned beneath the header. The header
is protected by steel bollards.
Within the tank farm the fill and distribution pipelines pass through ball valves located where the
piping enters/exists the impound. The valves are used to isolate each pipeline that is not in
service. Tank farm piping is two and three-inch schedule 40, black steel. Joints are welded,
except for flanged and threaded joints that connect to valves and pumps. The tank farm piping is
equipped with steel flex connectors, pressure relief valves, check valves, and strainers. The
storage tank fill/withdrawal connections are three-inch ball valves. Piping is secured with pipe
straps to steel and timber supports.
The transfer pipe from the tank farm to the School intermediate tank is welded two inch diameter
steel about 2,500 feet in length. The pipe parallels the washeteria pipeline. It is above ground,
except where it passes under roadways, where it is protected within an ABS culvert. Fuel is
transferred to the intermediate tank by manually starting the transfer pump using controls
mounted on the intermediate tank. The pipe is located away from vehicle driving areas except
for the road crossings where it is buried in a carrier pipe.
Security
The School may receive, or transfer seven days a week. Normally transfers from the tank farm
to the intermediate tank occur once a month. School personnel normally observe the
intermediate tank during daily routine duties. The tank farm is normally observed daily by the
other tank farm operators who conduct dispensing operations from tank farm. At least once a
A1 - 2 05/13
month, the School Site Principal / Head Teacher, or designated alternate, is to conduct and
document a thorough visual inspection of the entire School fuel system. Any fuel system
discrepancies, leaks or potential discharge, or items which are in need of maintenance are to be
reported to the YKSD Director of Facilities and Maintenance or the Maintenance Mechanic in
Fairbanks.
Leak detection is by visual monitoring or inventory discrepancy. There are no automated leak
detection systems in the School fuel system. .
An eight-foot high chain-link fence, topped with barbed wire surrounds the community tank
farm. The intermediate tank and its transfer pump control panel are also enclosed by chain link
fence. All entrance gates to fuel storage areas are to be closed and locked when the area is
unattended.
Bottom-penetration valves on storage tanks and transfer pipeline isolation valves at the entry/exit
to the tank farm are to be closed and locked when transfers are not being conducted.
Two pole mounted area lights illuminate the tank farm. Area lighting at the School provide
some illuminate of the intermediate tank.
Portable fire extinguishers are positioned at the entrance gates to the tank farm and intermediate
tanks. Tanks are to be marked to identify type of fuel contained in the tank, tank capacity, and
tank number. No smoking, warning, spill notification are to be posted.
School spill response equipment is maintained in mechanical/generator room. Additional spill
response equipment is to be maintained at the tank farm by the City and Kaltag Cooperative.
AVEC also maintains spill response equipment at its power plant.
In addition to this Facility Response Plan, the School also maintains a marine transfer Operations
Manual, as required by the Coast Guard, and a Spill Prevention Control and Countermeasure
Plan (SPCC) as required by the EPA.

Tank inspection and testing procedures are addressed in the SPCC Plan.

1.2 Facility Plot Plan - Figure 2, page A1-5.

1.3 Valve Identification - Figure 3, page A1-6.

1.4 Product Information


Diesel fuel is the product stored in bulk. A Material Safety Data Sheet (MSDS) for diesel fuel is
in Appendix 5 of this FRP.
Fuel is delivered to the tank farm normally once a year in tank barges that normally range in
capacity to about 5,000 barrels and 150 feet in length. Only one barge at a time can deliver fuel
to the tank farm. No marine transfers are conducted from the tank farm.

A1 - 3 05/13
-- / KALTAG
TANK FARM

-.- ,,- ...~-----·


___

..... =-f·~
-
-....
-
- -
-
..
~

+- I
-:_.,_

-.....

Lears
Point

·i FIGURE
FIGURE 1. 1. LOCATION
LOCATION MAP
MAP

A1-4
Lh
tt.-------------------------...l.--i..-J,_________________________;;-·---------L-..1--.--l--~---i.iiiiN~~·
rr: _... ..······· ··········· .... ···... I i'-·--------------------·-·r-·--------·---::
g "A STREET ~ II FUEL BARGE
MOORING AREA alfOOER Ill
THE AREA SUBJECT TO COAST GUARD JURISDICTION IS THE MARINE TRANSFER AREA (PIPELINE AND HOSE) BETWEEN
~---------------------1--------------
THE VESSEL, OR WHERE THE VESSEL MOORS, AND THE FIRST MANIFOLD OR SHUTOFF VALVE ON THE PIPELINE
. . .--------------------------------------·-··---------------
COMMNITY
SAFETY AND r~ ·-. . g \---· '"\· ¥ i
1
1.....- I I o ~ ~ MOORNIG AREA ENCOUNTERED AFTER THE PIPELINE ENTERS THE SECONDARY CONTAINMENT AREA AROUND THE BULK STORAGE
TANKRESPONSE
SPILL FARM f-f "rr-- f-.. ~-1-,.11'1 -~ ' ~r. • ~ ' "'"I •--<..a_.._,\'1.._,\.. ..·· 30 i
TANKS. EPA JURISDICTION EXTENDS “INLAND” FROM THE FIRST VALVE IN THE TANK FARM TO ALL TANKS AND TRANSFER
EQUIPMENT ,: -=-r~.~~~. \ :30"30': : : 30 i j \ \ \ \\.. LOCATIONS. SEE FIGURE A1-3 j
I · =-" ·. 13
! I 14
I I : : \ \ \ ~·. j
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8
i \ i i i i ! I
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WASHElERIA/
WillER PLIHT :
WASHETERIA 1
, • :::;,/ : : • : . 1 21 • 1\ r :((

i---,----·T·---~I I •
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.// '·., '.·,,'·J}:·, jj '...J;r:~ Ii I Q


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i: u.s. SURVEY
No. 2351 AMENDED
iI
/:! LEGEND NOTES
,/
/ . ....... ., ... ·.,
,._'-. '., •. j
• 1 ~~ 1--------------,!
jc;; I lj
2 'fl
/; + FOUND 2 1/2" I!IIJI BRASS CAP IIONLINENT 1. The purpose of this survey is to locate the Consolidated
Tonk Farm, the Dispenser Station, lrlorine Header,

~-· '-f~'-<, <D FOUND 1 1/2" ALIMNUW CN' I:IONUWENT Washeteria/Power Plant Pipeline and the School Pipeline.
// :; ! I; 1./
/ '·.... -~~,, Ii I
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2 /1
j' I ~I
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-(>
FOUND ~/II· IRON ROO
POWER POLE
2. The underground pipeline from the Worine Header to
Con.olidated Tonk Form, os shown, is for grophlccll
the
/ • ,;.<\.. • ' •'::/' ' • I I'··
1.. : FIGURE 2.
d' I

r.r--·-~-----1---------r:v--·ir
purpoaee only, exact location unknown.
-· '··' '•.kat: '-......... .! <>* IJQfT POL£

SCHOOL PIPELINE
r-- ~. '- '- • " '-
" ;.) '.i\
. '-....
. '~·
1

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OH/E -
OUY ANCHOR
IIOU.NID
SliiUUTE DISH
lMRHCAD EL£C'IlUC IJNE
--*"-- CIWN LINK FENCE
AREA PLAN I
TANK FARM DETAIL
STATE OF ALASKA, DIVISION OF ENERGY
4 ' \ , --F'--~lK j
""-'··&"<..._
.... "=. 't:/__.,j
2----------....,,l---.L
________ __SJRE.EI_ _____ J 2fL-----·~"1\·,.I
_______ ~ ,!.~.---- - - - F - - - UNDERGROUND FUEL 1..1£ LOCATION APPROXII:IIlTE
AS-BUILT

·", ,JI.----------·-··T·------------------J---------· .. J [ ASS CIJ..VEIIT, ~ NOTED I OF

10' iS Ill"-
f7\
~ I
:
SCHOOL,' ...
H KALTAG BULK
-:: ...: _. I U.S. SURVEY ·1· FUEL UPGRADES
.;. ;m jscttooL No. 2021 AMENDED '1 '1

~ ~ :~
U.S. SURVEY : TRACT A ..• SCHOOL SPILL RESPONSE
w !-
~~~
No. 3772 I
EQUIPMENT STORED IN FIGURE A1-2
~~~ '1:'1: MECHANICAL / GENERATOR BLDG.
AREA PLAN
~~I
~8
SCHOOL
INTERMEDIATE TANK
~~__:_ l il, SAFETY AND
SPILL RESPONSE ·
__

E~§l------------------------------------------------------------~===E:Q:U::IP:M:E:N:T==~~--~--------~~------------·--------~I:i _j~----------------~~D~AA~W~N~~~=~~a2~----~w~.o~.~N~o:~~99•--t-ot ~
A1-5
9~!5
11.1<:< ______________________________________________ ____
~
OR

6 MECHANICAL
TO SCHOOL -----/1-- TO WASHET£RIA ATO MARINE HEADER SYMBOLS
T
I PIPE aru£C110N

---o ElBOW TURHED DO~

TOE OF DIKE ~TO DISPENSER


--o ELBOW TURHED UP
1~1 f1DJa.E C(lji£C1Ql

r;f;! PRESSURE Rn.EF VN..VE


DISPENSING STATION
N
rn==s--~\
i. alECI( VN..VE
L-

/FENCE ON TOP OF DIKE


101 IIAU. YN..VE

~~~ SOlB«XD VN..VE


• • ~ SlRIHR

[]] FLOW WEIER

~
/
i
I
I
I :==6
I TANK /75 J-1
TANK /2 THE AREA SUBJECT TO COAST
~
3900 GALLON
CITY
I DIESEL
15,000 GALLON
I (!,1 GUARD JURISDICTION IS THE
/1 OIL I MARINE TRANSFER AREA
I
I
f'MIIt§!@d (PIPELINE AND HOSE) BEl\'VEEN

~
I THE VESSEL, OR WHERE THE
I
VESSEL MOORS, AND THE
CAJfALK 4e LAODER FIRST MANIFOLD OR SHUTOFF
,VII'-'Ir-
!'-
i .....
~ VALVE ON THE PIPELINE
16¢
ENCOUNTERED AFTER THE (6) VERTICAL . /
+-J TANK /9
~
PIPELINE ENTERS ~E
BALL VALVE'S ..../"' TOE OF DIKE
TANK /4 \ SECONDARY CONTAINME T
KALTAG COOP KALTAG COOP

__
17,500 GALLON ~101 AREA AROUND THE 8 .LK

~t!
7900 GALLON
DIESEL D/ES£L STORAGE TANKS. EPA
JURISDICTION EXTENes
(
__l____b HINLAND" FROM THE FIRST

~~
VALVE IN THE TANK FARM. .
-
SCHOOL
~ L.....<:-11-l~J· TYP
TANKS #'S 11-14
11. TANK /10
J-l ~1--tt ®E~
TANK /13 \ ~ I 00
SCHOOL
TANK /5
KALTAG COOP
trt
KALTAG COOP
12,500 GALLON HIOI iii
~~T
1101
9800 GALLON
It OIL
8900 GALLON
GASOLINE
DIESEL
-o
~=r=
r h
f
I
.- YIOI!-11-:>----
TANK /8
J•...,
(
J"-. CITY \

~0101:
8000 GALLON L. p . I I
1 I I
!J!.

~
/1 OIL !J!.

~~ TANK /1
lk
1-1/2" MAlE ~
110:1
TANK /14
SCHOOL
8900 GALLON
/1 OIL
-c...J i!i
KALTAG COOP
25,000 GALLON
GASOLINE
~101
'c.-------i l/1101
1.
1ts: 0

~ -~aK<SUMP
CAI.ILOCK "---
r h
~ 1
1-
I

HAND
PUMP

~------ .....
0 E_NLJ~R~ED PIPING PLAN

STATE OF ALASKA
DIVISION OF ENERGY, KALTAG
TANK FARM UPGRADE
(!)

~
c-.i
TANK FARM PIPING
8-
~
I PLAN
-
....... 0w
"'
~
It:
w
I
FIGURE-REA1-3
~ ~
.• ,:.:.~
C) TA~~ -~·ARM PIPING PLAN FIGU
PIPING
PIN~
3.
PLAN
c_i PLAN
SCALE. 1 -
~e~ PI
olil::c

~g~ A1-6
-7
A1- I

§~ 5 DRAWN BY: KK W.O. No: 96-109


n.G:< I
APPENDIX 2

LIST OF CONTACTS

2.1 Key Personnel - Qualified Individuals

Refer to Section 1.1 - page 1-2.

2.2 Federal, State, Local Officials

Refer to Section 2.1.2 - page 2-1-2.

2.3 Response Contractors

Refer to Section 2.3.4

A2-1 05/13
APPENDIX 3
EQUIPMENT LIST AND RECORDS

Section 2.2.3 lists response equipment maintained at, and available to, the School.
The operational status of all identified equipment is "ready for deployment." The equipment
is to be inspected and inventoried monthly. It can be deployed with 30 minutes of notice to
proceed.
The equipment is adequate to respond to the average most probable discharge and to meet
tier 1, 2 and 3 planning requirements.
A Worksheet to Plan Volume of Response Resources for Worst Case Discharge is presented
in Section 2.2.3.

A3-1 05/13
APPENDIX 4
COMMUNICATIONS PLAN

4.1 Communications Plan / Equipment


The Incident Commander is responsible for setting up communications during a spill event.
Verbal communication among cleanup personnel will be adequate in most cases.
Communications with the Coast Guard, EPA, ADEC and others will be initiated and
maintained by telephone. A log of all communications with agencies should be maintained.
The log should include, at minimum the date and time, the person and agency contacted, and
topics discussed.
During marine delivery, a minimum of two radio handsets will be used for communication
between vessel and facility personnel. Radio communication will be maintained
continuously throughout all phases of the transfer operation. By agreement with the fuel
supplier, the vessel, not the School, provides the required radios during marine transfers.
Radios used during marine transfers are to be intrinsically safe and meet Class I, Division I,
Group D standards.

Coordination with Federal On-scene Coordinator (FOSC)


Following initial agency notification, the Incident Commander will initiate necessary
procedures to ensure communications and coordination of the actions with the predesignated
Federal On-Scene Coordination (FOSC). These procedures may include but are not limited
to the following: establishing open, continuous communications; identifying types of
information that will be relayed to the FOSC (i.e. projected plans, accomplishments,
complications); soliciting comments and recommendations from the FOSC, as well as
resolving differences; and, having the FOSC attend and participate in spill management team
meetings.

A4-1 05/13
APPENDIX 5
SITE SAFETY PLAN

5.1 Site Safety Plan


Section 3.0 presents information on spill history, potential spills, emergency shutdown
systems, fire suppression equipment, evacuation plans, and personnel safety.
In the event of a discharge, the Incident Commander on-site will serve as the initial safety
officer. If determined necessary, an experienced safety specialist may be activated from the
Public Health Service or contractors.
In accordance with OSHA requirements (29 CFR, Part 1910.120), an incident specific safety
plan will be developed for each hazardous substance release. An acceptable format for the
safety plan is presented on the following page.

5.2 Material Safety Data Sheets


A Material Data Safety Sheets (MSDS) for diesel fuel is included in this Appendix,
following the Site Safety Plan.

A5-1 05/13
INITIAL
SITE SAFETY PLAN
MINI SITE SAFETY PLAN FOR: _____________________________ DATE: __________________

PROJECT MANAGER: ______________________ SITE SAFETY OFFICER: ______________________

FOREMAN: _______________________________ CREW: ________________________________


_________________________________________________________________________________________
_________________________________________________________________________________________

SITE CHARACTERIZATION: SAFETY HAZARD(S): _________________________________

PRODUCT(S): ________________________ CONCENTRATION: ________ PEL: _____________

CHEMICAL(S): ______________________ CONCENTRATION: _________ PEL: _____________

WORK PLAN/SITE ACTIVITIES PLANNED: ________________________________________________


_________________________________________________________________________________________

HEALTH EFFECTS & SYMPTOMS: ________________________________________________________


_________________________________________________________________________________________
_________________________________________________________________________________________

PERSONAL PROTECTION REQUIRED?: _________________ LEVEL: ________________________


_________________________________________________________________________________________

SITE ZONES ESTABLISHED (ATTACH SITE MAP)? WHY? ___________________________________


_________________________________________________________________________________________

DECONTAMINATION REQUIRED? WHY? _________________________________________________


_________________________________________________________________________________________

TRAINING REQUIRED:
_________________________________________________________________________________________
_________________________________________________________________________________________
_________________________________________________________________________________________

PHYSICAL EXAMS REQUIRED: ___________________________________________________________

CONTINGENCY PLAN: ___________________________________________________________________


_________________________________________________________________________________________

EMERGENCY NUMBERS: AMBULANCE: ________________ HOSPITAL: _____________________

AIR MONITORING TO BE DONE: __________________ INTERVAL: _____________________

SAFETY RULES AND SAFETY PLAN READY: _______________________________________________

DATE PREPARED: _____________________ PLAN EXPIRES: ________________________


APPENDIX 6

DOCUMENTATION FORMS

In compliance with Coast Guard and EPA requirements, the following (or similar) records
are to be completed and maintained.
The School Responsible Person (Site Principal / Head Teacher) is to ensure required records
are completed, maintained, and available for agency inspection. Frontier Fuel Service (FFS)
and YKSD are to confirm that required fuel system recordkeeping is current.
Documentation is to be maintained for five years, except for records of significant tank
repairs, modifications, integrity tests, and spill reports that are to be maintained permanently.
Sample forms for the following documentation are included on the following pages.

6.1 Spill Report / Notification Form

6.2 Facility Inspections


Facility Inspection - Monthly Checklist
(includes all tanks, piping, transfer areas, response equipment)

Tank Farm Stormwater Drain Log

Static Liquid Pressure Test of Pipelines

Liquid Level Sensing Devices Test Log

6.3 Training
Annual Training & Drills Documentation / Certification
(includes equipment deployment drill, table top exercise, unannounced drill, and
safety and discharge prevention training)

Designation of Persons in Charge of Marine Transfers and Certification


of Training and Qualifications

A6-1 08/16
KALTAG SCHOOL
OIL SPILL REPORT AND NOTIFICATION FORM
USE ADDITIONAL PAGES AS NEEDED
1) REPORTING PARTY: NAME __________________________________________
ADDRESS __________________________________________
TELEPHONE __________________________________________

2) RESPONSIBLE PARTY: NAME __________________________________________


ADDRESS __________________________________________
TELEPHONE __________________________________________

3) SOURCE OF SPILL: ___________________________________________________________________

4) CAUSE SPILL: ________________________________________________________________________

_____________________________________________________________________________________

5) TIME & DATE OF INCIDENT: ________________________________________________________

6) LOCATION OF INCIDENT: ________________________________________________________


7) FACILITY: MAXIMUM STORAGE CAPACITY _______________________________
DAMAGED TANK CAPACITY _______________________________
NORMAL DAILY THROUGHPUT _______________________________

8) MATERIAL RELEASED: PRODUCT _________________________________________


TOTAL QUANTITY _________________________________________
QUANTITY IN WATER _________________________________________

9) ACTIONS BEING TAKEN TO MITIGATE / RE-MEDIATE INCIDENT: _____________________________


_____________________________________________________________________________________

10) IMPACT: AFFECTED AREA ________________________________________________________


INJURIES ________________________________________________________
FATALITIES ________________________________________________________
EVACUATIONS ________________________________________________________
DAMAGES ________________________________________________________

11) ESTIMATED QUANTITY RECOVERED: ___________________________________________________

12) METHOD OF RECYCLING / DISPOSAL: ___________________________________________________


_____________________________________________________________________________________

13) ACTIONS TAKEN TO PREVENT REOCCURRENCE: _________________________________________


_____________________________________________________________________________________

14) NOTIFICATIONS MADE TO: ADEC ____________________________________________


(DATE / TIME / PERSON) NRC / USCG ____________________________________________
OTHER ____________________________________________

15) WRITTEN SPILL REPORT SENT TO:


ADEC ___YES ___NO DATE _____
USCG ___YES ___NO DATE _____
EPA ___YES ___NO DATE _____

INITIAL NOTIFICATION MUST NOT BE DELAYED PENDING COLLECTION OF ALL INFORMATION


NATIONAL RESPONSE CENTER - (800) 424-8802
KALTAG SCHOOL – OIL STORAGE
VISUAL INSPECTION - MONTHLY CHECKLIST*

DATE: __________
INSPECTED BY: __________________ INSPECTED / OK REQUIRES
() ATTENTION
(attach comments)

STORAGE AND INTERMEDIATE TANKS


EACH TANK INSPECTED FOR:
• Visible signs of leakage, damage _________ _________
• Signs of distortions, denting, bulging _________ _________
• No severe corrosion - paint in good condition _________ _________
• Foundations sound, no evidence of cracking, settlement _________ _________
• Tank valves – locked / good condition _________ _________
• Tank level gauges – readable / good condition _________ _________
• Tank vents – free of obstructions / operate properly _________ _________
• Tank ladders – secure with no sign of severe corrosion, damage _________ _________
• All tank openings, manways properly sealed – bolts tight _________ _________
• Intermediate Tank – Interstitial space inspected – clean / dry _________ _________
TANK FARM IMPOUND - SECONDARY CONTAINMENT
• Diked area impervious– in good condition _________ _________
• Retained water level acceptable (low) – no oil sheens _________ _________
• Containment areas free of debris, fire hazards _________ _________
• Access gates – clear, operable _________ _________
TANK FARM PIPING, PUMPS
• Free of leakage – good condition _________ _________
• Pipe valves, supports, connections, flex connectors – good condition _________ _________
EXPOSED PIPE – outside of tank farm
• Free of leakage, damage – good condition _________ _________
• Valves, supports - good condition _________ _________
• Marine header - good condition _________ _________
SURROUNDING AREA
• Fences – tank farm and intermediate tank – good condition _________ _________
• Locks storage area entrance gates _________ _________
• Security lights - operate properly _________ _________
• Warning & No Smoking Signs posted _________ _________
• Electrical wiring, control panels – good condition _________ _________
• Spill response equipment – inventory complete / equip. operable _________ _________
• Response Plan, Operations Manual, SPCC Plan in place _________ _________
ADDITIONAL COMMENTS
OTHER CONDITIONS THAT SHOULD BE ADDRESSED FOR CONTINUED SAFE OPERATIONS

* In the event of severe weather (snow, ice, wind storms) or maintenance (such as painting) that could affect the operation
of critical components (normal and emergency vents, valves), an inspection of these components is required
immediately following the event.
This checklist (or similar documentation) to be retained for 36 months to comply with Steel Tank Institute tank
inspection standard, STI SP001.
KALTAG SCHOOL – OIL STORAGE
COMMUNITY TANK FARM IMPOUND - SCHOOL STORAGE TANK
STORMWATER DRAIN LOG

Date & Time Time Any


Location of Draining Draining Sheen Operator's
Draining Started Finished Y/N Signature

* Operator's signature confirms that no oil or sheen was discharged during draining.

This form (or similar documentation) is required by 40 CFR, Part 112.8(c)(3).


KALTAG SCHOOL – OIL STORAGE

STATIC LIQUID PRESSURE TEST OF PIPELINES

DATE: _______________________

LOCATION: ___________________

TEST BY: ____________________

MAX. HELD
WORKING TEST TIME / PRESSURE
PIPELINE PSI PSI DURATION (Y / N)

________________ __________ __________ __________ __________

________________ __________ __________ __________ __________

________________ __________ __________ __________ __________

________________ __________ __________ __________ __________

MARINE TRANSFER PIPELINES SHALL BE STATIC LIQUID PRESSURE TESTED AT LEAST ONCE
EACH YEAR TO 1½ TIMES WORKING PRESSURE. (33 CFR, Part 156.170).

This form (or similar documentation) must be available for Coast Guard Inspection. (33
CFR, Part 154.740).
KALTAG SCHOOL – OIL STORAGE
LIQUID LEVEL SENSING DEVICES - TEST LOG
All tank level gauges and intermediate tank high level pump shutoff controls to be tested.

TANK # DEVICE(S) DEVICE(S)


TESTED BY DATE TESTED OK () REQUIRE REPAIR ()
COMMENTS / ACTION TAKEN

Testing of level sensing devices required by 40 CFR Part 112.8(c)(8)(v).


This form (or similar documentation) required by 40 CFR Part112.7(e).
Test procedures and frequency for level sensing devices described in Section II.E of SPCC Plan.
KALTAG SCHOOL – OIL STORAGE

201__ TRAINING & DRILLS SELF CERTIFICATION FORM

THIS FORM IS TO BE RETAINED FOR FIVE YEARS

1. SPILL RESPONSE / PREVENTION TRAINING (Annual): Date:


Review - Update Response Plan / Discuss Spill Prevention, Operating, Transfer Procedures / Location:
Discuss Potential Spills, Scenarios, Response Actions / Review Reporting & Regulatory
Requirements / Review First Aid, Fire, Health and Safety Considerations - MSDS Forms /
Inspect - Deploy Facility Response Equipment.
Signatures of Participants:*
Observations / Evaluation:*
Recommendations:*

2. PREP - QUALIFIED INDIVIDUAL NOTIFICATION DRILL Date:


Contact made with Q.I. Contact made with Alternate Q.I. Date:
Names of Participants:* Date:
Observations / Evaluation:* Date:
Recommendations:*

3. PREP - MANAGEMENT TEAM TABLETOP EXERCISE (Annual): Date:


Review: Response Plan / Notification / Communications / Mobilization of Equipment & Location:
Personnel / Response Organization / Logistics / Protection of Sensitive Areas.
Signatures of Participants:*
Observations / Evaluation:*
Recommendations:*

4. PREP - EQUIPMENT DEPLOYMENT EXERCISE (Semiannual): Date:


Deploy and Inspect Facility Response Equipment. One exercise must include Location:
boom, anchor systems, recovery and transfer systems. Second exercise must include
“representative" equipment adequate to cleanup "average most probable" discharge.
Signatures of Participants:*
Observations / Evaluation:*
Recommendations:*

5. PREP - UNANNOUNCED EXERCISE (as requested by EPA or USCG): Date:


Conduct Proper Notifications / Demonstrate equipment deployment can be: Location:
timely, conducted with adequate equipment, properly deployed.
Signatures of Participants:*
Observations / Evaluation:*
Recommendations:*

*This information must be recorded for each drill, exercise, program - use additional pages, as necessary.
These exercises may be conducted concurrently.

This form (or similar documentation) required by 40 CFR, Part 120.20(h)(8), and 33 CFR, Part 154.1050(b)
KALTAG SCHOOL – OIL STORAGE

DESIGNATION OF PERSONS IN CHARGE OF MARINE TRANSFERS


AND
CERTIFICATION OF TRAINING AND QUALIFICATIONS

THIS FORM IS TO BE MAINTAINED AT THE FACILITY AND IS TO BE AVAILABLE FOR


EXAMINATION BY THE COAST GUARD. IT IS TO BE UPDATED WHEN NECESSARY TO
ACCURATELY LIST ALL DESIGNATED PERSONS IN CHARGE.

I hereby certify the persons listed below meet the training and qualification requirements for
designated persons in charge as listed in 33 CFR Part 154.710.

Yukon Koyukuk School District


Facility Responsible Person:
Designated Persons In Charge:
Name Date
_____ ________________

___________ ________________

_____ ________________

This form (or similar documentation) required by 33 CFR, Part 154.710(d)