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HomeMy WebLinkAboutNCG500050_Regional Office Historical File 1994 to 2014P NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory Governor April 15, 20 1_114 APR 2 3 2014 Ms. Myra Hair Brookfield Smoky Mountain Hydropower, LLC Water Quality Regional operations 314 Growden Blvd Asheville Regional 0 ce Tallassee, TN 37878 Dear Ms. Hair: E. Skvaria III Secretary Subject: Transfer of coverage / General Permit NCG500000 NCG500049 Cheoah Powerhouse NCG500050 Santeelah Powerhouse Graham County In accordance with your request of November 28, 2012, the Division hereby transfers the subject Certificates of Coverage (CoCs) to discharge under NCG500000. We apologize for the delay in processing your request. While we did receive and process the previous change of ownership to BAIS US Renewable Power Holdings, LLC, your firm's request was not received until you re- submitted it to Mr. Kevin Bowden of our staff. This action is taken pursuant to the requirements of North Carolina's General Statue 143-215.1 and the Memorandum of Agreement between North Carolina and the US Environmental Protection Agency dated July 17, 2007 (or as subsequently amended). If any parts, measurement frequencies or sampling requirements contained in this General Permit are unacceptable, you have the right to request an individual permit by submitting an individual NPDES permit application. Unless such demand is made, this CoC shall be final and binding. Please note that each CoC is not transferable except after notice to the Division. The Division may modify, or revoke and reissue this CoC. This issuance does not affect your legal obligations to obtain any other Federal, State, or Local government permit that may be required. If you have any questions concerning this permit, please contact Charles H. Weaver at telephone number (919) 807-6391 or via email (charles.weaver@ncdenr.gov). 0 cc: Asheville Regional Office Sincer y, Thomas A. Reeder, Direc For -', Division of Water Resources NPDES General Permit Files 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-6300 \ FAX: 919-807-6492 \ Customer Service: 1-877-623-6748 Internet: www.ncvvaterresources.org One NorthCarolina An Equal Opportunity \ Affirmative Action Employer STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER RESOURCES General Permit NCG500000 Certificate of Coverage NCG500049 To discharge hydroelectric dam water and similar wastewaters under the NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES In compliance with the provisions of North Carolina General'Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Brookfield Smoky Mountain Hydropower, LLC is hereby, authorized to discharge wastewater from a facility located at the Cheoah Powerhouse 15152 Tapoco Rd Tapoco Graham County to receiving waters designated as the Little Tennessee River [stream segment [2-(66)], a waterbody currently classified B waters within subbasin 04-04-02 of the Little Tennessee River Basin, in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV of the General Permit NCG500000, as attached. This permit shall become effective April 15, 2014. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day, April 15, 2014 Division of Water Resources By Authority of the Environmental Management Commission STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER RESOURCES General Permit NCG500000 Certificate of Coverage NCG500050 To discharge hydroelectric dam water and similar wastewaters under the NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Brookfield Smoky Mountain Hydropower, LLC is hereby authorized to discharge wastewater from a facility located at the Santeelah Powerhouse 1247 Farley Branch Rd Tapoco Graham County to receiving waters designated as the Little Tennessee River [stream segment [2-(66)], a waterbody currently classified B waters within subbasin 04-04-02 of the Little Tennessee River Basin, in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II,11I and IV of the General Permit NCG500000, as attached. This permit shall become effective April 15, 2014. This Certificate of Coverage shall remain in effect for the duration of the General Permit. Signed this day, April 15, 2014 C> T�hh`Pnas A. Reeder, Director ------ -. . Division of Water Resources By Authority of the Environmental Management Commission North Carolina Department of Environment and Natural. Resources Division of Water Quality w Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman Governor DirectorSecretary February 2, 2012 i FES 1 4 2012 Ms. Allison Montgomery Alcoa Power Generating, Inc. 300 N Hall Rd m Alcon, TN 37701-2516 Subject: Receipt of NCG5OOO5O renewal application Santeelah Power Facility Graham County Dear Ms. Montgomery: The Division received your request to renew Certificate of Coverage (CoC) NCG50005O on February 1, 2012. Thank you for submitting the renewal application. Please note that no additional fee is required at renewal. We are therefore returning the attached check (#134) for $100.00 that was submitted with the application. If we require any further information to renew this CoC, a staff member from the NPDES program will contact you. You may continue to operate under your existing CoC until a renewed CoC is issued, or until other action is taken by the Division. If you have any questions concerning this permit, please contact me at the telephone number or e-mail address listed at the bottom of this page. Sincerely, Charles H. Weaver, Jr. NPDES Unit cc s e} e 1ftnat ©fficel ydace Watex Proteet b' NPDffUnity a,., ... 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 512 North Salisbury Street, Raleigh, North Carolina 27604 Phone: 919 807-6300 / FAX 919 807-6495 / http://portal.ncdenr.org/web/wq An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper NorthCarohna Naturally " Division of Water Quality / Water Quality Section NCDENR National Pollutant Discharge Elimination System :4CYCiN �YR IJNk GPtAiME:R OF FjlvF(.1NMP;? 4tlrJ N4TUP,.U.. RF.50.:ar:F"i NCG500000 NOTICE OF INTENT National Pollutant Discharge Elimination System application for ci NCG500000: Non -contact cooling water, boiler blowdown, cooling similar point source discharges (Please print or type) 1) Mailing address* of owner/operator: Company Name Alcoa Power Generating, Inc. (APGI) Santeetlah Owner Name APGI Street Address 300 North Hall Rd. City Alcoa Telephone No. 865 977-3362 * Address to which all permit correspondence will be mailed 2) Location of facility producing discharge: FOR AGENCY USE ONLY Date Received Year Month Da Certificate of Coverase NCG Check # Amount Permit Assigned to State 1 LIP Corte s�rui-t5lo Fax: 865 977-3843 Facility Name Santeetlah Power Facility Facility Contact Allison Montgomery Street Address NCSR 1247 City Rymers Ferry State NC ZIP Code 28780 County Graham County Telephone No. 865 977-3362 Fax: 865 977-3843 3) Physical location information: Please provide a narrative description of how to get to the facility (use street names, state road numbers, and distance and direction from a roadway intersection). The facility is located approx.'7 miles from Robbinsville, NC. It is bordered on the southwest by mountains, on the north by the Little Tennessee river and on the east by wooded terrain. (See Attachment #1) (A copy of a county map or USGS quad sheet with facility clearly located on the map is required to be submitted with this application) 4) This NPDES permit application applies to which of the following : ❑ New or Proposed ❑ Modification Please describe the modification: 8 Renewal Please specify existing permit number and original issue date: Permit NCG500000- Cert. of Coverage NCG500050 5) Does this facility have any other NPDES permits? 8 No ❑ Yes If yes, list the permit numbers for all current NPDES permits for this facility: Permit listed above 6) What is the nature of the business applying for this permit? Hydroelectric Power Generation Page 1 of 4 04/05 NCG500000 N.O.I. 7) Description of Discharge: a) Is the discharge directly to the receiving water? ® Yes ❑ No If no, submit a site map with the pathway to the potential receiving waters clearly marked. This includes tracing the pathway of the storm sewer to the discharge point, if the storm sewer is the only viable means of discharge. b) Number of discharge points (ditches, pipes, channels, etc. that convey wastewater from the property): 3 discharge points c) What type of wastewater is discharged? Indicate which discharge points, if more than one. 8 Non -contact cooling water Discharge point(s) #: 001,002 ❑ Boiler Blowdown Discharge point(s) #: ❑ Cooling Tower Blowdown Discharge point(s) #: ❑ Condensate Discharge point(s) #: B Other Discharge point(s) #: 003 (Please describe "Other") Outfall 003 consists of stormwater and dam seepage d) Volume of discharge per each discharge point (in GPD): #1: 8,000 #2: 8,000 #3: 59,000 #4 N/A e) Please describe the type of process (i.e., compressor, A/C unit, chiller, boiler, etc.) the wastewater is being discharged from, per each separate discharge point (if applicable, use separate sheet): See Attachment #2 8) Please check the type of chemical added to the wastewater for treatment, per each separate discharge point (if applicable, use separate sheet): ❑ Biocides Name: ❑ Corrosion inhibitors Name: ❑ Chlorine Name: ❑ Algaecide Name: ❑ Other Name: 8 None Manuf.: Manuf.: Manuf.: Manuf.: Manuf.: 9) If any box in item (8) above, other than none, was checked, a completed Biocide 101 Form and manufacturers' information on the additive is required to be submitted with the application for the Division's review. 10) Is there any type of treatment being provided to the wastewater before discharge (i.e., retention ponds, settling ponds, etc.)? Iii Yes ❑ No If yes, please include design specifics (i.e., design volume, retention time, surface area, etc.) with submittal package. Existing treatment facilities should be described in detail. Design criteria and, operational data (including calculations) should be provided to ensure that the facility can comply with the requirements of the General Permit. The treatment shall be sufficient to meet the limits set by the general permits: ISee attachment #3 Note: Construction of any wastewater treatment facilities requires submission of three (3) sets of plans and specifications along with the application. Design of treatment facilities must comply with the requirements of 15A NCAC 2H .0138. If construction applies to this discharge, include the three sets of plans and specifications with this application. Page 2 of 4 04/05 NCG500000 N.O.I. 11) Discharge Frequency: a) The discharge is: ❑ Continuous B Intermittent ❑ Seasonalo i) If the discharge is intermittent, describe when the discharge will occur: During power generation, rain events and when the sump fills ii) If seasonal check the month(s) the discharge occurs: ❑ Jan. ❑ Feb. ❑ Mar. ❑ Apr. ❑ May ❑ Jun. ❑ Jul. ❑ Aug. ❑ Sept. ❑ Oct. ❑ Nov. ❑ Dec. b) How many days per week is there a discharge? 7 days per week. c) Please check the days discharge occurs: B Sat. 8 Sun. I3 Mon. B Tue. Iii Wed. B Thu. B Fri. 12) Pollutants: Please list any known pollutants that are present in the discharge, per each separate discharge point (if applicable, use separate sheet): Oil and Grease, Temperature, TSS and pH 13) Receiving waters: a) What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the facility wastewater discharges end up in? If the site wastewater discharges to a separate storm sewer system (4S), name the operator of the 4S (e.g. City of Raleigh). Little Tennessee River and Cheoah Lake b) Stream Classification: C, Tr 14) Alternatives to Direct Discharge: Address the feasibility of implementing each of the following non -discharge alternatives a) Connection to a Municipal or Regional Sewer Collection System b) Subsurface dis c) Spray irrigation osal (including nitrification field, infiltration gallery, injection wells, etc.) Due to the location and nature of hydroelectric generating facilities, it is not feasible to consider any alternative to direct discharge. The alternatives to discharge analysis should include boring logs and/or other information indicating that a subsurface system is neither feasible nor practical as well as written confirmation indicating that connection to a POTW is not an option. It should also include a present value of costs analysis as outlined in the Division's "Guidance For the Evaluation of Wastewater Disposal Alternatives". 15) Additional Application Requirements: For new or proposed discharges, the following information must be included in triplicate with this application or it will be returned as incomplete. a) 7.5 minute series USGS topographic map (or a photocopied portion thereof) with discharge location clearly indicated. b) Site map, if the discharge is not directly to a stream, the pathway to the receiving stream must be clearly indicated. This includes tracing the pathway of a storm sewer to its discharge point. c) If this application is being submitted by a consulting engineer (or engineering firm), include documentation from the applicant showing that the engineer (Or firm) submitting the application has been designated an authorized Representative of the applicant. d) Final plans for the treatment system (if applicable). The plans must be signed and sealed by a North Carolina registered Professional Engineer and stamped -"Final Design -Not released for construction". Page 3 of 4 04/05 e) Final specifications for all major treatment components (if applicable). The specifications must be signed and sealed by a North Carolina registered Professional Engineer and shall include a narrative description of the treatment system to be constructed. I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief such information is true, complete, and accurate. PrintedName of Person Sign ng: Mark Gross TWI V.Pibperatio s Manag ,r, APGI (Sgnature fA plicano (Date Signed) North Carolina General Statute 143-215.6 b (i) provides that: Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan or other document filed or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or who falsifies, tampers with or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both, for a similar offense.) Notice of Intent must be accompanied by a check or money order for $100.00 made payable to: Mail three (3) copies of the entire package to: NPDES Permits Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Final Checklist This application will be returned as incomplete unless all of the following items have been included: 8 Check for $100 made payable to NCDENR B 3 copies of county map or USGS quad sheet with location of facility clearly marked on map 11 3 copies of this completed application and all supporting documents ❑ 3 sets of plans and specifications signed and sealed by a North Carolina P.E. ii Thorough responses to items 1-7 on this application ii� Alternatives analysis including present value of costs for all alternatives Note The submission of this document does not guarantee the issuance of an NPDES permit Page 4 of 4 04/05 Attachment #1 USGS Map(s) Attachment #2 Process Data (7e) m 3 00 O N 00 O V O �c � In O IC O > o o c O+ r a; 00 G1 00 0 0 CT a�i ^ O In in O �p r, 00 00 M O N N O Rn R A. i.+ in r rl- 7 �^ � Gzl v O GT. bpA bA .a N Q) cn bA 0p _ V v o a = 0 3 3 as � R17 Y � L w � 3 Y o Z � g V, n y Q :C L i cLC c � o v C7 v U ; u a� U U vs 0 O z c R � O C O O z M Santeetlah The Santeetlah hydroelectric facility operates an air-cooled system. Stormwater and reservoir water seepage into the Powerhouse is directed to a sump located in the Powerhouse Basement. Treatment prior to discharge consists of oil and grease removal by floatation and skimming. All drains within the Santeetlah Facility (with the exception of the Oil Room) are routed to two 4,400 gallon sumps located in the basement of the Powerhouse. A transfer pump removes storm water that collects in the downstream sump to the river. An automatic level control system operates the pump. The upstream pump is a manual water jet pump. Any floating oils and grease collected in the sump are removed by skimming and placed in a drum. Transformer Banks Nos. 1 and 2 located on either side of the Powerhouse, and the OCB vessels and station service transformers located behind the Powerhouse are diked and equipped with a drainage system. This system has a manually operated gate valve that is kept closed except to drain rainwater. Process Water Non -contact cooling water from Transformer Banks 1 and 2 and from the generator bearings is discharged directly to the Little Tennessee River by-passing the basement sumps. Ea E Ea m a a 0 (3 U* Z� a iz H HIIJON IJO ccJ W'� LU 4r, U) w z Z UJ cr: LU O LL, W�—. y m < LL Ul < LL c) LLI �— z lie 00 < U) wE ill d) C; to > CL ff 0 ULM 0 — ; . dI ul > r a VI 'a U- o 060 coo E OCO 0 mM Cy ul to U) eFa KE O. C) CD a) ill d) C; to > CL ff 0 ULM 0 — ; . dI ul > r a VI 'a U- o 060 coo E OCO 0 mM Cy ul to U) eFa KE O. C) CD a) > I-- 0 0 (n cc E > < 0 0 cu E ® E E > U- LO T o 0 ci E o 0 C: tn O-C 4-- M X D E E < Q) 0 n CL 01 0 E 0 0 M -Cu:: 0 0 M :3 2, -a C: 0 0_ cn 0 cm 70 cv :3 0 0 C: E = o m o c) Zn 0 " 0) -0 CCLII U) L c (D L- E M C: (B c W c- m E C-) c Q = x m 0 (D m > >-- C: cn Ln o = (D �m 0- r- 0 o w, 0 C) Santeetlah 001 Historical Data Turbine Cooling unit #1 Maximum # # Oil & # pg # Date Flow Average Days Temp. Samples Grease Samples Samples p (MGD) (C) (mg/-) (std. units) Limits 6-9 Jun-02 0.006 0.004 2 15.1 1 4.3 1 Jul-02 16.3 1 8.3 1 6.4 7.5 1 1 Aug-02 0.006 0.005 3 16.6 1 7.8 1 Sep-02 22.8 1 4.6 1 6.7 6.8 1 1 Oct-02 23.3 1 4.0 1 6.8 1 Nov-02 18.6 1 0.0 1 6.8 1 Dec-02 16.5 1 1.2 1 6.9 1 Jan-03 12.9 1 4.4 1 8.2 1 Feb-03 15.0 1 0.0 1 7.7 1 Mar-03 0.011 0.011 3 14.6 1 0.0 1 7.2 1 Apr-03 15.2 1 0.0 1 7.5 1 May-03 18.3 1 0.0 1 7.2 1 Jun-03 22.3 1 2.7 1 6.8 1 Jul-03 23.1 1 2.5 1 6.1 1 Aug-03 23.8 1 4.9 1 6.7 1 Sep-03 23.9 1 0.0 1 6.0 1 Oct-03 22.4 1 0.0 1 6.6 1 Nov-03 0.008 0.008 3 18.2 1 0.0 1 7.5 1 Dec-03 17.6 1 5.1 1 7.1 1 Jan-04 14.3 1 1.9 1 7.3 1 Feb-04 0.011 0.011 1 14.4 1 0.0 1 7.3 1 Mar-04 18.3 1 0.0 1 7.0 1 Apr-04 18.3 1 4.1 1 7.6 1 May-04 14.4 1 2.0 1 6.9 1 Jun-04 13.5 1 0.0 1 7.5 1 Jul-04 20.0 1 0.0 1 7.0 1 Aug-04 17.2 1 0.0 1 6.4 1 Sep-04 0.011 0.007 3 Oct-04 23.0 1 0.0 1 6.2 1 Dec-04 15.3 1 0.0 1 6.5 1 Jan-05 16.6 1 7.3 1 6.4 1 Feb-05 0.011 0.011 3 15.1 1 2.7 1 6.8 1 Mar-05 14.7 1 5.4 1 6.9 1 Apr-05 12.6 1 0.0 1 6.6 1 May-05 12.2 1 2.1 1 6.5 1 Jun-05 24.3 1 0.0 1 6.1 1 Jul-05 Aug-05 Sep-05 18.6 1 2.1 1 6.7 1 Oct-05 0.002 0.001 2 16.3 1 0.0 1 6.3 1 Nov-05 0.000 0.000 0 20.8 1 0.0 1 6.5 1 Dec-05 1 1 1 Jan-06 14.7 1 0.0 1 6.8 1 Feb-06 15.1 1 1.4 1 6.7 1 Mar-06 Apr-06 18.6 1 1.0 1 6.6 1 May-06 17.2 1 3.9 1 6.6 1 Jun-06 0.005 0.002 3 21.7 1 0.0 1 6.4 1 Jul-06 22.9 1 4.8 1 6.6 1 Aug-06 15.0 1 0.0 1 7.1 1 Sep-06 Oct-06 0.009 0.005 3 20.5 1 0.0 1 6.8 1 Nov-06 20.7 1 0.0 " 1 6.6 1 Dec-06 12.5 1 0.0 1 7.1 1 Jan-07 15.5 1 1.0 1 6.9 1 Maximum 0.011 24.3 8.3 8.2 Minimum 0.000 12.2 0.0 6.0 Average 0.007 17.8 1.8 6.8 # 11 49 49.0 49 Sample Frequency - Semiannual (1/6 months) 4/4/2007 SANTEETLAH 002 Historical Data Turbine Cooling unit #2 Maximum # # Oil & # pH # Date Flow Average Days Temp. Samples Grease Samples Samples p (MGD) (C) (mg/L) (std. units) Limits 6-9 Jan-02 0.011 0.011 1 15.7 1 0.0 1 8.5 1 Feb-02 12.9 1 2.7 1 8.5 1 Mar-02 12.9 1 0.0 1 8.8 1 Apr-02 16.0 1 1.6 1 8.8 1 May-02 14.7 1 4.1 1 6.4 1 Jun-02 0.011 0.010 2 21.9 1 6.3 1 6.6 1 Jul-02 17.8 1 7.3 1 7.0 1 Aug-02 0.006 0.006 3 21.1 1 7.3 1 6.7 1 Sep-02 23.9 1 4.6 1 6.7 1 Oct-02 22.9 1 5.7 1 7.0 1 Nov-02 19.2 1 1.2 1 6.5 1 Dec-02 15.4 1 0.0 1 7.0 1 Jan-03 11.7 1 11.1 1 7.9 1 Feb-03 13.1 1 0.0 1 7.8 1 Mar-03 0.011 0.011 3 12.4 1 0.0 1 7.1 1 Apr-03 13.5 1 0.0 1 7.6 1. May-03 15.3 1 0.0 1 7.5 1 Jun-04 21.6 1 2.5 1 6.8 1 Jul-03 20.5 1 7.2 11 6.3 1 Aug-03 21.2 1 5.8 1 6.8 1 Sep-03 21.1 1 0.0 1 6.5 1 Oct-03 18.2 1 0.0 1 6.6 1 Nov-03 0.008 0.008 3 17.8 1 0.0 1 7.2 1 Dec-03 17.8 1 4.2 1 7.7 1 Jan-04 10.6 1 2.0 1 7.4 1 Feb-04 0.011 0.011 1 8.6 1 0.0 1 7.6 1 Mar-04 Shut down for maintenance Jul-04 17.8 1 0.0 1 7.4 1 Aug-04 19.2 1 0.0 1 6.8 1 Sep-04 0.011 0.006 3 Oct-04 20.5 1 0.0 1 6.1 1 Dec-04 12.4 1 2.7 1 6.6 1 Jan-05 13.5 1 0.0 1 6.8 1 Feb-05 0.011 0.011 3 12.2 1 3.1 1 6.9 1 Mar-05 9.7 1 12.3 1 7.1 1 Apr-05 18.8 1 4.2 1 6.2 1 May-05 15.6 1 2.0 1 6.5 1 Jun-05 23.8 1 0.0 1 6.2 1 Jul-05 Aug-05 Sep-05 Oct-05 0.002 0.001 2 16.3 1 0.0 1 6.3 1 Nov-05 0.000 0.000 1 14.4 1 0.0 1 6.8 1 Dec-05 Jan-06 10.0 1 0.0 1 6.9 1 Feb-06 10.9 1 1.3 1 6.7 1 Mar-06 Apr-06 13.6 1 0.0 1 6.7 1 May-06 11.2 1 1.2 1 6.8 1 Jun-06 0.005 0.002 3 15.7 1 0.0 1 6.8 1 Jul-06 18.7 1 4.4 1 6.6 1 Aug-06 15.3 1 1.3 1 7.1 1 Sep-06 Oct-06 0.008 0.004 3 17.7 1 _ 0.0 1 6.6 1 Nov-06 Dec-06 10.6 1 0.0 1 7.1 1 Jan-07 11.5 1 0.0 6.9 1 Maximum 0.011 23.9 12.3 8.8 Minimum 0.000 8.6 0.0 6.1 Average 0.008 16.0 2.2 7.0 # 12 48 48 48 Sample Frequency - Semiannual (1/6 months) 4/4/2007 SANTEETLAH 003 Historical Data Station Sump Average Maximum # Oil & # pH # Date Flow Average Flow Days Grease Samples Samples Temp. # Samples (MOD) (MGD) (mg/L) (std. units) (C) Limits 15 (avg) 20 (max.) 6-9 Feb-02 0.039 0.0 1 8.6 1 10.0 1 Apr-02 0.024 0.039 0.024 1 6.8 1 9.0 1 Jul-02 0.020 0.039 0.020 1 10.4 1 Aug-02 0.039 9.5 1 7.0 1 Oct-02 0.010 0.039 0.010 1 8.0 1 7.1 1 16.1 1 0.039 19.4 1 Feb-03 0.039 1.5 1 7.9 1 9.9 1 Apr-03 0.026 0.039 0.026 1 0.0 1 7.6 1 Aug-03 0.039 5.5 1 6.8 1 10.2 1 Sep-03 0.038 0.039 0.038 1 19.0 1 Oct-03 0.039 2.8 1 6.7 1 18.3 1 Jan-04 0.026 6.039 0.026 1 Feb-04 0.039 0.0 1 7.4 1 8.3 1 Apr-04 0.139 0.039 0.139 1 4.0 1 7.9 1 Aug-04 0.039 1.6 1 6.7 1 13.4 1 Sep,04 0.027 0.039 0.027 1 15.7 1 Oct-04 0.044 0.039 0.044 1 0.0 1 6.4 1 19.8 1 Nov-04 0.039 Dec-04 0.039 Jan-05 0.029 0.039 0.029 1 Feb-05 0.039 4.7 1 7.0 1 10.4 1 Mar-05 0.039 Apr-05 0.023 0.039 0.023 1 1.0 1 6.7 1 10.4 1 May-05 0.039 Jun-05 0.039 Jul-05 0.026 0.039 0.026 1 Aug-05 0.039 Sep-05 0.039 2.1 1 6.7 1 18.6 1 Oct-05 0.039 2.6 1 6.5 1 16.8 1 Nov-05 0.046 0.039 0.046 1 Dec-05 0.039 Jan-06 0.018 0.039 0.018 1 Feb-06 0.039 1.0 1 6.4 1 10.1 1 Mar-06 0.039 Apr-06 0.031 0.039 0.031 1 0.0 1 6.8 1 11.6 1 May-06 0.039 Jun-06 0.039 Jul-06 0.039 5.7 1 6.7 1 13.7 1 Aug-06 0.030 0.039 0.030 1 Sep-06 0.039 Oct-06 0.039 6.9 1 6.9 1 15.6 1 Nov-06 0.113 0.039 0.113 1 Dec-06 0.039 Maximum 0.139 0.139 9.5 9.0 19.8 Minimum 0.010 0.010 0.0 6.4 8.3 Average 0.039 0.039 3.2 7.1 13.9 # 17 17 20 20 20 Sample Frequency - Quarterly (113 months) 4/4/2007 ti 0 0 N V Q ti rT� r Santieetlah Powerhouse NCG500050 March 2007 Standard Operating Procedures (SOP's) North Carolina General Permit Certificate of Coverage - NCG500050 Santeetlah Powerhouse Receiving Stream The Little Tennessee River is classified as Class C - Trout waters which means that the more stringent monitoring requirements contained in the permit are in effect. Treatment System The only treatment system is the oil skimmer at the sump. The permit states that, "THERE SHALL BE NO CHROMIUM, ZINC, OR COPPER ADDED TO THE DISCHARGE EXCEPT AS PRE -APPROVED ADDITIVES TO BIOCIDAL COMPOUNDS." Additionally, the permits require authorization prior to use of biocides. A ninety (90) day notification prior to use is required. Additional paperwork, Biocide Worksheet 101, the MSDS, and a map, must be submitted, also. Effluent Monitoring and Limitations All outfalls are to be numbered serially, beginning with 001, by the permittee. Tapoco should describe and number the outfalls in order to ensure that monitoring and results are conducted and maintained properly. A(1) Requirements are either captured under A(2), flow and temperature, or not applicable, total residual chlorine (TRC) and oil & grease. A(2) Once -through Cooling Water from Hydroelectric Facilities 1 Santeetlah Powerhouse NCG500050 March 2007 1. Flow must be measured semi-annually (2/year) on the effluent. The sample type is "estimate." Tapoco retained Dennis Weeter Associates to develop SOP's for flow measurement methods at all of the outfalls at its powerhouses. These flow SOP's should be used for flow monitoring and reporting. 2. Temperature samples are to be semi-annual (2/year), effluent "grabs". A footnote at the bottom of the limits page states that both the monthly average and daily maximum limits for trout waters classification are: 0.5°C above the natural water temperature Receiving water temperature shall not exceed a maximum of 20°C for trout waters.' These statements imply that TAPOCO should determine what the natural water temperatures are and check the downstream temperatures on the same date as effluent sampling. Although streams samples are not a reporting requirement, TAPOCO should keep files for the data. Stream samples should be collected at mid -channel and mid -depth. The downstream sample should be collected at a point where the effluent is mixed with the receiving stream. The sites should be investigated and designated as sampling points. A statement at the bottom of the page gives a pH range of 6 - 9 standard units. This statement implies that TAPOCO should be periodically checking the pH of the outfalls. Although no frequency is stated, TAPOCO should check the pH at the same frequency, semi-annually, as the other permit parameters. 4. "There shall be no floating solids or visible foam (other than trace amounts) in the effluent." The "trace amounts" requirement is very subjective and can vary from inspector to inspector. A(3) Sumps and Drains 1. Flow must be measured quarterly (4/year) on the effluent. The sample type is "estimate." The flow SOP's should be used for flow monitoring and reporting. 2. Oil and grease samples must be collected quarterly (4/year) on the effluent. The sample type is "grab." Limits are established at 15 mg/L for the monthly average and 20 mg/L for the daily maximum. Footnote 1 requires visual inspection of the tailrace for oil sheens after lubrication operations. 2 Santeetlah Powerhouse NCG500050 March 2007 A statement at the bottom of the page gives a pH range of 6 - 9 standard units. This statement implies that TAPOCO should be periodically checking the pH of the outfalls. Although no frequency is stated, TAPOCO should check the pH at the same frequency, semi-annually, as the other permit parameters. 4. Chemical cleaning of the wheel pit is permitted monthly, but only with preapproved solvents. Any changes to the cleaner(s) must be approved. The tailrace must be inspected for foam or oil sheens. May not be applicable to Tapoco. 5. Mechanical cleaning which does not generate a discharge does not require permitting. 6. "There shall be no floating solids or visible foam (other than trace amounts) in the effluent." Si ng_ atojy Requirements Any documentation, such as reports, applications, or information, which are submitted to a regulatory authority must be signed and certified by a responsible corporate officer or a duly authorized representative. In TAPOCO's case, a responsible corporate official would be the current Vice-president of Alcoa Power Generation Inc. Applications must be signed by a responsible corporate officer. Reports and other information may be signed by an authorized representative if: The authorization is made in writing by a responsible corporate officer and submitted to the appropriate regulatory agency. 2. The authorization specifies either an individual or a position having responsibility for overall operation, such as the plant manager, superintendent, or overall responsibility for environmental matters for the company. Concurrence should be obtained from corporate legal staff prior to enacting the delegation. Any applications, reports, or other information (including cover letters containing data which might be used in determining compliance with water quality laws) should contain the following certification language which applies to the signee: U certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant 3 Santeetlah Powerhouse NCG500050 March 2007 penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. " Certified Operator North Carolina law, Chapter 90A-44, requires that a certified operator be in responsible charge of the wastewater treatment facilities. It is recommended that a certified operator or laboratory personnel conduct the testing required by the permit. TAPOCO should require that its operator or laboratory provide proof of existing certification and any additional training. A file which contains such documentation should be established and maintained in the TAPOCO file system. Monitoring and Records The general permits do not have requirements for submittal of monitoring data. Monitoring results should be maintained on file in the TAPOCO file system for future compliance review. 2. If flow measurement devices are installed at the discharges, the flow devices are expected to have a deviation of <10% of the true discharge rates throughout the range of expected discharge volumes. Routine calibrations according to the manufacturer's instructions should be conducted, and the calibration records should be maintained in a bound, log book. As stated previously, documented good engineering practices may be used to estimate flow values. 3. Records are to be kept a minimum of three (3) years. This includes strip charts, all calibration and maintenance records, log books, and copies of all reports. A corporate ALCOA memo indicated that the records should be maintained indefinitely. Recording Results For each sample or measurement, the following information must be recorded and retained by TAPOCO: 4 Santeetlah Powerhouse NCG500050 March 2007 1. Location, date and time of sample collection; 2. Name of sampler; 3. Analysis(es) date(s); 4. Name of analyst; 5. Analytical method (usually a number); and 6. Analytical results TAPOCO and the contractor responsible for sampling should develop a field sheet for each sampling location that would provide the information required in items 1 and 2 above or items lthrough 6 above, if tests are performed in the field. TAPOCO and its contract laboratory, if such is used, should review and/or develop an analytical certificate that provides the information required in items 3 through 6 above for analyzed performed in the laboratory. Both the field sheet and the analytical certificate should be retained in TAPOCO's file system. Additional Monitoring It is recommended that TAPOCO record any additional monitoring and maintain the information in its file system. Quality Assurance/Quality Control (QA/QC) At a minimum, every tenth sample should be duplicated. This includes both field and laboratory testing. Duplicates should be treated as separate, individual samples and included as such in any calculations and frequency of analyses. TAPOCO should ensure that the laboratory, if appropriate, performing the analyses is conducting and documenting its own QA/QC program. A good QA/QC program ensures reproducibility of results and confidence in the accuracy of the results which are used to report compliance. If the laboratory does not have a QA/QC program, TAPOCO should change laboratories. North Carolina requires the use of certified laboratories for most analyses. pH and TRC- do not currently require certification if done in-house, although all tests will fall under certification requirements in July 1995. Documentation of certification should be maintained in the TAPOCO files. It is recommended that TAPOCO continue to use a laboratory that has certification. TAPOCO is ultimately responsible for the accuracy of the data it reports. Calibration Santeetlah Powerhouse NCG500050 March 2007 Field instruments, such as pH, temperature, and flow meters, should have individual log books which contain equipment calibration records. TAPOCO should ensure that the calibrations are performed according to the frequency suggested by the manufacturer as a minimum requirement. Laboratory instruments should have similar records. If not, TAPOCO should review its use of the laboratory. All records should be available upon request for review. If the field and laboratory records are maintained at the contractor's offices, TAPOCO should obtain all records rather than allow them to be discarded at the end of the minimum three (3) years. Log Books Log books should be bound books, not loose leaf binders or folders. Entries into field books should be written in ink. Corrections Corrections should be made with a single line through the error. The initials of the person making the correction and the date of correction should be written above the correction. DO NOT USE WHITE OUT OR DRAW MANY LINES THROUGH THE ERROR. Sampling Protocols Temperature, pH, and flow measurements are to be made in the field. A temperature reading should be taken immediately. pH readings should be obtained within fifteen (15) minutes of sample collection. Samples involved in transport should be tagged and properly labeled with all of the field data included. Chain of custody forms are required if the sampler and laboratory are different. As a management system, TAPOCO is currently analyzing oil and grease samples from various discharges. The samples should be collected in glass containers as "grabs." The samples must be preserved with sulfuric acid (H2SO4) to <2 standard units and transported to the laboratory at 4°C (397). The holding time is 28 days. Noncompliance Reporting 6 Santeetlah Powerhouse NCG500050 March 2007 The following must be reported orally within 24 hours of awareness to North Carolina, Division of Environmental Management (NCDEM): 1) a bypass, 2) an upset, and 3) a violation of a daily maximum permit limit. A written submission to NCDEM must follow within five (5) days of becoming aware of the noncompliance. NCDEM, Asheville Regional Field Office: 704-251-6208 It is recommended that TAPOCO designate an individual to report instances of noncompliance. An effort must be made to ensure that the sampler, the laboratory, and TAPOCO personnel understand the reporting requirements and act in a timely fashion. Additional Suggestions_ TAPOCO should require sampling personnel to develop and maintain a sampling log book which is specific for TAPOCO. This field book should be used to document sampling, calibration of instruments, and note unusual occurrences. When the log book is full, the book should be given to TAPOCO and maintained in its files. 2. TAPOCO should develop a computerized, historical data base for each permitted parameter. ALCOA has developed spreadsheets and "control" charts which could be used. 3. TAPOCO should require the certified operator and laboratory to develop SOP's specific for TAPOCO sampling locations and permit parameters. The SOP's should include instrument calibration techniques and analytical procedures. 7 Santeetlah Powerhouse NCG500050 Sampling Schedule Santeetlah Powerhouse General Permit - Certificate of Coverage NCG500049 March 2007 Once Through Cooling Water (OTCW) Outfalls Semiannual sampling: Two periods/year August through January; February through July Parameters: Flow and temperature (Page A2) Outfall 001 - Turbine Bearing Cooling Unit #1 Outfall 002 -Turbine Bearing Cooling Units 42 **Flow Data is pulled from Tapoco's Power Generation Logs 8 Saateetlah Powerhouse NCG500050 March 2007 Sump Outfall Quarterly sampling: Four periods/year August through October November through January February through April May through July Parameters: Flow and oil & grease (Page A3) Outfall 003 - Station sump 9 r FROM: M. A. Browning, S34 TO: B. J. Polk, Jr., S35 Environmental Affairs TAPOCO, INC. Aluminum Company of America Tennessee Operations 1997 August 18 RE: Comments and Standard Operating Procedures (SOP's) - North Carolina General Permits - COC NCG500049 (Cheoah Powerhouse) and COC NCG500050 (Santeetlah Powerhouse)- Graham County The wastewater discharge permits referenced above have been reviewed, and comments were developed for each item which I consider to be a major compliance issue or noteworthy for understanding the permit requirements. Enclosed are suggestions for SOP's which will should help ensure compliance with the permits. The suggestions are based on experience with regulatory agencies and corporate ALCOA audits. If you have any questions or need assistance, please call me at 3627. Mark Browning cc: D. E. Huddleston, S31 B. Whitehead, S35 Santeetlah Powerhouse NCG500050 August 1997 Standard Operating Procedures (SDP's) North Carolina General Permit Certificate of Coverage - NCG500050 Santeetlah Powerhouse Permit Expiration and Renewal The permit became effective 1997 August 1. The permit expires at midnight on 2002 July 31. Although not specifically stated in the permit, the permit renewal applications and any fees must be submitted to North Carolina 180 days prior to the expiration date. Receiving Stream The Little Tennessee River is classified as Class C - Trout waters which means that the more stringent monitoring requirements contained in the permit are in effect. Treatment System The only treatment system is the oil skimmer at the sump. The permit states that, "THERE SHALL BE NO CHROMIUM, ZINC, OR COPPER ADDED TO THE DISCHARGE EXCEPT AS PRE -APPROVED ADDITIVES TO BIOCIDAL COMPOUNDS." Additionally, the permits require authorization prior to use of biocides. A ninety (90) day notification prior to use is required. Additional paperwork, Biocide Worksheet 101, the MSDS, and a map, must be submitted, also. Effluent Monitoring and Limitations All outfalls are to be numbered serially, beginning with 001, by the permittee. Tapoco should describe and number the outfalls in order to ensure that monitoring and results are conducted and maintained properly. A(1) Requirements are either captured under A(2), flow and temperature, or not applicable, total residual chlorine (TRC) and oil & grease. 1 Santeetlah Powerhouse NCG500050 August 1997 A(2) Once -through Cooling Water from Hydroelectric Facilities Flow must be measured semi-annually (2/year) on the effluent. The sample type is "estimate. Tapoco retained Dennis Weeter Associates to develop SOP's for flow measurement methods at all of the outfalls at its powerhouses. These flow SOP's should be used for flow monitoring and reporting. 2. Temperature samples are to be semi-annual (2/year), effluent "grabs". A footnote at the bottomof the limits page states that both the monthly average and daily maximum limits for trout waters classification are: 0.5°C above the natural water temperature Receiving water temperature shall not exceed a maximum of 20°C for trout waters. These statements imply that TAPOCO should determine what the natural water temperatures are and check the downstream temperatures on the same date as effluent sampling. Although streams samples are not a reporting requirement, TAPOCO should keep files for the data. Stream samples should be collected at mid -channel and mid -depth. The downstream sample should be collected at a point where the effluent is mixed with the receiving stream. The sites should be investigated and designated as sampling points. A statement at the bottom of the page gives a pH range of 6 - 9 standard units. This statement implies that TAPOCO should be periodically checking the pH of the outfalls. Although no frequency is stated, TAPOCO should check the pH at the same frequency, semi-annually, as the other permit parameters. 4. "There shall be no floating solids or visible foam (other than trace amounts) in the effluent." The "trace amounts" requirement is very subjective and can vary from inspector to inspector. A(3) Sumps and Drains Flow must be measured quarterly (4/year) on the effluent. The sample type is "estimate." The flow SOP's should be used for flow monitoring and reporting. 2. Oil and grease samples must be collected quarterly (4/year) on the effluent. The sample type is "grab." Limits are established at 15 mg/L for the monthly average and 20 mg/L for the daily maximum. 2 Santeetlah Powerhouse NCG500050 August 1997 Footnote 1 requires visual inspection of the tailrace for oil sheens after lubrication operations. 3. A statement at the bottom of the page gives a pH range of 6 - 9 standard units. This statement implies that TAPOCO should be periodically checking the pH of the outfalls. Although no frequency is stated, TAPOCO should check the pH at the same frequency, semi-annually, as the other permit parameters. 4. Chemical cleaning of the wheel pit is permitted monthly, but only with preapproved solvents. Any changes to the cleaner(s) must be approved. The tailrace must be inspected for foam or oil sheens. May not be applicable to Tapoco. 5. Mechanical cleaning which does not generate a discharge does not require permitting. 6. "There shall be no floating solids or visible foam (other than trace amounts) in the effluent." Signatory Requirements Any documentation, such as reports, applications, or information, which are submitted to a regulatory authority must be signed and certified by a responsible corporate officer or a duly authorized representative. In TAPOCO's case, a responsible corporate official would be Joe Adams, President, or Julian Polk, Vice-president. Applications must be signed by a responsible corporate officer. Reports and other information may be signed by an authorized representative if: The authorization is made in writing by a responsible corporate officer and submitted to the appropriate regulatory agency. 2. The authorization specifies either an individual or a position having responsiblity for overall operation, such as the plant manager, superintendent, or overall responsibility for environmental matters for the company. Concurrence should be obtained from corporate legal staff prior to enacting the delegation. Any applications, reports, or other information (including cover letters containing data which might be used in determining compliance with water quality laws) should contain the following certification language which applies to the signee: 7 certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the 3 Santeetlah Powerhouse NCG500050 August 1997 information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. " Currently, all documents are signed by Mr. Julian Polk. Certified Operator North Carolina law, Chapter 90A-44, requires that a certified operator be in responsible charge of the wastewater treatment facilities. It is recommended that a certified operator or laboratory personnel conduct the testing required by the permit. TAPOCO should require that its operator or laboratory provide proof of existing certification and any additional training. A file which contains such documentation should be established and maintained in the TAPOCO file system. Monitoring and Records 1. The general permits do not have requirements for submittal of monitoring data. Monitoring results should be maintained on file in the TAPOCO file system for future compliance review. 2. If flow measurement devices are installed at the discharges, the flow devices are expected to have a deviation of <10% of the true discharge rates throughout the range of expected discharge volumes. Routine calibrations according to the manufacturer's instructions should be conducted, and the calibration records should be maintained in a bound, log book. As stated previously, documented good engineering practices may be used to estimate flow values. 3. Records are to be kept a minimum of three (3) years. This includes strip charts, all calibration and maintenance records, log books, and copies of all reports. A corporate ALCOA memo indicated that the records should be maintained indefinitely. RecordingResults esults For each sample or measurement, the following information must be recorded and retained by TAPOCO: 1. Location, date and time of sample collection; 4 Santeetlah Powerhouse NCG500050 August 1997 2. Name of sampler; 3. Analysis(es) date(s); 4. Name of analyst; 5. Analytical method (usually a number); and 6. Analytical results TAPOCO and the contractor responsible for sampling should develop a field sheet for each sampling location that would provide the information required in items 1 and 2 above or items lthrough 6 above, if tests are performed in the field. TAPOCO and its contract laboratory, if such is used, should review and/or develop an analytical certificate that provides the information required in items 3 through 6 above for analysed performed in the laboratory. Both the field sheet and the analytical certificate should be retained in TAPOCO's file system. Additional Monitorin ALCOA reports any additional sampling, other than those specifically named and limited,'' as an attachment to the cover letter submitted with the monthly Discharge Monitoring Reports (DMR's). More frequent analyses of permitted pollutants are reported on the DMR's. It is recommended that TAPOCO record any additional monitoring and maintain'' the information in its file system. Quality Assurance/Quality Control (QA/QC) At a minimum, every tenth sample should be duplicated. This includes both field and laboratory testing. Duplicates should be treated as separate, individual samples and included as such in any calculations and frequency of analyses. TAPOCO should ensure that the laboratory, if appropriate, performing the analyses is conducting and documenting its own QA/QC program. A good QA/QC program ensures reproducibility of results and confidence in the accuracy of the results which are used to report compliance. If the laboratory does not have a QA/QC program, TAPOCO should change laboratories. North Carolina requires the use of certified laboratories for most analyses. pH and TRC do not currently require certification if done in-house, although all tests will fall under certification requirements in July 1995. Documentation of certification should be maintained in the TAPOCO files. It is recommended that TAPOCO continue to use a laboratory that has certification. TAPOCO is ultimately responsible for the accuracy of the data it reports. Calibration 5 Santeetlah Powerhouse NCG500050 August 1997 Field instruments, such as pH, temperature, and flow meters, should have individual log books which contain equipment calibration records. TAPOCO should ensure that the calibrations are performed according to the frequency suggested by the manufacturer as a minimum requirement. Laboratory instruments should have similar records. If not, TAPOCO should review its use of the laboratory. All records should be available upon request for review. If the field and laboratory records are maintained at the contractor's offices, TAPOCO should obtain all records rather than.allow them to be discarded at the end of the minimum three (3) years. Log Books Log books should be bound books, not loose leaf binders or folders. Entries into field books should be written in ink. Corrections Corrections should be made with a single line through the error. The initials of the person making the correction and the date of correction should be written above the correction. DO NOT USE WHITE OUT OR DRAW MANY LINES THROUGH THE ERROR. Sampling Protocols Temperature, pH, and flow measurements are to be made in the field. A temperature reading should be taken immediately. pH readings should be obtained within fifteen (15) minutes of sample collection. Samples involved in transport should be tagged and properly labelled with all of the field data included. Chain of custody forms are required if the sampler and laboratory are different. As a management system, TAPOCO is currently analyzing oil and grease samples from various discharges. The samples should be collected in glass containers as "grabs." The samples must be preserved with sulfuric acid (H2SO4) to <2 standard units and transported to the laboratory at 4°C (397). The holding time is 28 days. Noncompliance Reporting The following must be reported orally within 24 hours of awareness to North Carolina, Division of Environmental Management (NCDEM): 1) a bypass, 2) an upset, and 3) a violation of a daily maximum permit limit. re Santeetlah Powerhouse NCG500050 August 1997 A written submission to NCDEM must follow within five (5) days of becoming aware of the noncompliance. NCDEM, Asheville Regional Field Office: 704-251-6208 It is recommended that TAPOCO designate an individual to report instances of noncompliance. An effort must be made to ensure that the sampler, the laboratory, and TAPOCO personnel understand the reporting requirements and act in a timely fashion. Additional Sug es� tions 1. TAPOCO should require sampling personnel to develop and maintain a sampling log book which is specific for TAPOCO. This field book should be used to document sampling, calibration of instruments, and note unusual occurrences. When the log book is full, the book should be given to TAPOCO and maintained in its files. 2. TAPOCO should develop a computerized, historical data base for each permitted parameter. ALCOA has developed spreadsheets and "control" charts which could be used. 3. TAPOCO should require the certified operator and laboratory to develop SOP's specific for TAPOCO sampling locations and permit parameters. The SOP's should include instrument calibration techniques and analytical procedures. Mark A. Browning Staff Environmental Administrator ALCOA-Tennessee Operations 1997 August 18 7 Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources SURFACE WATER PROTECTION March 19, 2007 Ms. Stephanie Sparkman Alcoa Power Generating Inc / Tapoco Inc 300 North Hall Road Alcoa, Tennessee 37701 Dear Ms. Sparkman: Alan W. Klimek, P.E. Director Division of Water Quality Asheville Regional Office E p_. �... 13 SUBJECT: Compliance Evaluation Inspection Cheoah Powerhouse Permit No: NCG500049 Santeelah Powerhouse Permit No: NCG500050 Graham County Enclosed please find a copy of the Compliance Evaluation Inspection form from the inspection conducted on March 15, 2007. Mr. Keith Haynes and I of the Asheville Regional Office conducted the Compliance Evaluation Inspections. The facilities were found to be in Compliance with permits NCG500049 and NCG500050. Please refer to the enclosed inspection report for additional observations and comments. If you or your staff have any questions, please call me at (828) 296-4500. Sincerely, Lar Frost Environmental Engineer Enclosure cc: NPDES Unit Clint Swires - Alcoa Power Generating Inc / Tapoco Inc., 300 North Hall Road, Alcoa, TN 37701 Central Files Asheville File NorthC.0lina Natumlly 2090 U.S. Highway 70, Swannanoa, NC 28778 Telephone: (828) 296-4500 Fax: (828) 299-7043 Customer Service 1 877 623-6748 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 2 3 C 00±;<t: 11 12 n'1iG3%"L, 17 18 19 1 1 �I S1 20I Remarks 21111111111111111111111111111111111111111111111116 Inspection Work Days Facility Self -Monitoring Evaluation Rating 61 QA --------------------------- Reserved ---------- ----------- 671 169 701 1 711 1 721 1:1 73 L1J 74 751 I I I 1 1 1 1 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Number) Powe:rYtou e Exit Time/Date Permit Expiration Date US Tw,-v= 129 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted _ a :'.:.-_.:,..:._:. VCa.:.: , 3010 N 'TN ,`3'i-C.l.i; 2i...., ,. ,-.,32", Yes Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Operations & Maintenance N Records/Reports Self -Monitoring Program Facility Site Review Effluent/Receiving Waters Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date _�. h r Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date 3 Ic EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 NPDES yr/mo/day Inspection Type (cont .) 1 3I 000 4" I11 12I l 17 18 3LI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mr. Keith Haynes and Mr. Larry Frost performed the inspection. The facility appeared to be well maintained and operating properly. There were no un-permitted discharges noted during the inspection. Tapoco Division's Cheoah Powerhouse consists of the dam, pinstock, generation equipment powerhouse SUMPS, cooling water discharges and tailrace. The powerhouse discharges to the Little Tennessee River/backwaters of Calderwood Lake. The facility has done and excellent job of establishing sampling points throughout the powerhouse. Clint Swires has agreed to supply the inspectors with a copy of the powerhouse's sampling plan and spreadsheet of monitoring results (last 3 years) by sampling point Page # 2 Permit: NCG500049 Owner -Facility: Cheoah Powerhouse Inspection Date: 03/15/2007 Inspection Type: Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new application? ®C1 n Cl Is the facility as described in the permit? ®❑ n n # Are there any special conditions for the permit? ❑ ■ n n Is access to the plant site restricted to the general public? n ❑ n Is the inspector granted access to all areas for inspection? n Comment: .0pe- ations Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ® n 0 n Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge n n ■ n Judge, and other that are applicable? Comment: Record ee Yes No NA NE Are records kept and maintained as required by the permit? n n n Is all required information readily available, complete and current? n n n Are all records maintained for 3 years (lab. reg. required 5 years)? ■ n n n Are analytical results consistent with data reported on DMRs? n ❑ ■ Is the chain -of -custody complete? M Q n 0 Dates, times and location of sampling n Name of individual performing the sampling ❑ Results of analysis and calibration Dates of analysis n Name of person performing analyses n Transported. COCs n Are DMRs complete: do they include all permit parameters? ❑ n ® ❑ Has the facility submitted its annual compliance report to users and DWQ? n n ® n (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? n n Is the ORC visitation log available and current? ❑ n n Is the ORC certified at grade equal to or higher than the facility classification? ❑ n Is the backup operator certified at one grade less or greater than the facility classification? ❑ ❑ ■ Cl Is a copy of the current NPDES permit available on site? ■ Cl n n Page # 3 Permit: wc�oOnn*n _ Owner -Facility: chouaxPowomnoxo ~� Inspection Date: oonoonu/ Inspection Type: Compliance Evaluation Yes No NA NE Facility has copy ofprevious year's Annual Report onfile for review? [l [] 0 [] Comment: Foci|hvieuod�tingth*emnnoUnQ�Gn2ndthennoni1Orin�reou|taepoeed sheet,Please ' ' ' e0e��n�GnOpytmiheAuhevU/eRegiona/OOioovvhe.'zz`=�----`r~~~ U Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? NN [] [] [] United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection RepOft Approval expires 8-31-98 Section A. National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 7 GiOn; (; 11 12 n'1iC1,':1.., 17 18 19 20 1 �_1 2 11 31 N'' I_' 1_' 0 1 1 Remarks 21111111111111111111111111111111111111111111111116 Inspection Work Days Facility Self -Monitoring Evaluation Rating 61 CA -------------------------Reserved--------------------- 671 169 701U 711 1 72 � h 1 73 w 74 751 1 1 1 1 1 11 80 �— Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Number) Exit Time/Date Permit Expiration Date K 2,1./ .. 07 Name(s) of Onsite Representafive(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted n`l ,... Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Operations &Maintenance E Records/Reports Self -Monitoring Program Facility Site Review Effluent/Receiving Waters Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date ARO Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date Roger C .....,,,,...ids Ai<o EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 NPDES yr/mo/day Inspection Type 3I 11 12 117 18I C (cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Tapoco Division's Santeelah Powerhouse consists of pinstock, generation equipment, powerhouse sumps, coolwater discharges and tailrace. The powerhouse discharges to Cheoah Lake/Little Tennessee River. Mr. Keith Haynes and Mr. Larry Frost performed the inspection. The facility appeared to be well maintained and operating properly. There were no un-permitted discharges noted during the inspection. The facility has done an excellent job of establishing sampling points throughout the powerhouse. Clint Swires has agreed to supply the inspectors with a copy of the powerhouse's sampling plan and spreadsheet of monitoring results (last 3 years) by sampling points. Page # 2 Permit: NCG500050 Owner - Facility: Santeelah Powerhouse ..-' Inspection Date: 03115/2007 Inspection Type: Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new application? n n n Is the facility as described in the permit? ® a n n # Are there any special conditions for the permit? n n m n Is access to the plant site restricted to the general public? n ❑ n Is the inspector granted access to all areas for inspection? ❑ ❑ ❑ Comment: ® erattons aintenanee Yes No NA NE Is the plant generally clean with acceptable housekeeping? ® n n 1-1 Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge n n ® ❑ Judge, and other that are applicable? Comment: Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ®®n Is all required information readily available, complete and current? ❑ Q Are all records maintained for 3 years (lab. reg. required 5 years)? M n n n Are analytical results consistent with data reported on DMRs? n n n Is the chain -of -custody complete? Dates, times and location of sampling n Name of individual performing the sampling n Results of analysis and calibration Dates of analysis n Name of person performing analyses In Transported COCs Are DMRs complete: do they include all permit parameters? n n n Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ n (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? n n ® n Is the ORC visitation log available and current? ❑ Q ® Cl Is the ORC certified at grade equal to or higher than the facility classification? n n ® n Is the backup operator certified at one grade less or greater than the facility classification? n n ® ❑ Is a copy of the current NPDES permit available on site? M 0 Q ❑ Page # 3 po,mm w0000noso ow"o 'nmmty: santeelahpb~emvum, Inspection Date: 0311512007 Inspection Type: Compliance Evaluation Record Keepinct Facility has copy of previous year's Annual Report on file for review? 0 0 0 COrnnoen(: Facility isupdating the sonnoUnoo�nandbhernOndohng results spreadsheet P[eareaendacopytothe' Asheville Regional 'Ofhce^when complete. �S—a.T��g Yes No mx ms Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? 0 [] 0 [] Comment: Eff| _ mt..SaTTI.1-99 'oo No wx me |oComposite sampling flow proportional? O0 0 Is sample collected below all treatment units? M M M |sproper volume collected? �El C1 0 |athe tubing clean? OOO� |aproper temperature set | �o o for nsge(kept at1Oho4.4degrees Ce|oius)? [][]N�[] , Is the facility sampling performed as required by the permit (frequency, sampling type representative)? 0 [] [] [] Comment: AR6 A :' $ r .NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross, Jr., Secretary . ,Alan 1N: Klimek, P.E., pirector NOTICE OF RENEWAL RNT �' �� I i Application for renewal of existing coverage under General P t 0 0 _ Existing Certificate of Coverage (CoC): NC060 l 9 2007 1 .� (Please print or type) �_ d WATER QUALITY SECTION ASHE VILLE R� � NAB OFFICE 1) Mailing address of facility owner/operator: - - .� Company Name C S ' r. Owner Name Street Address A) a . City A 1 r ear State -T A)— ZIP Code 577611 Telephone Number 266 5 g t7'7 - 9119 Fag: 7 7- '3 Email address �Q,& ?p S126- Con &n f �� Cac� [r�► * Address to which all permit correspondence should be mailed 2) Location of facility producing discharge: Facility Name Facility Contact Street Address tic SR I :) Cityy n�ec s ec+,y State OL-- ZIP Code 28 78a County Telephone Number R66 cl �7r1- �OO*7 Fag: Email address 3) Description of Discharge: a) Is the discharge directly to the receiving stream? M/Yes ❑ No (If no, submit a site map with the pathway to the potential receiving waters clearly marked. This includes tracing the pathway of the storm sewer to the discharge point, if the storm sewer is the only viable means of discharge.) b) Number of discharge outfalls (ditches, pipes, channels, etc. that convey wastewater from the property): c) What type of wastewater is discharged? Indicate which discharge points, if more than one. ( Non -contact cooling water Outfall(s) #: -AN i- 00: 0 Boiler Blowdown Outfall (s) #: - ❑ Cooling Tower Blowdown ❑ Condensate Other Outfall (s) #: Outfall (s) #: Outfall (s) #: CIO'3 NCG500000 renewal application (Please describe "Other") e d) Volume of discharge per each discharge point (in GPD): #001: TC)do __ #002: 8T #003: Sj 006 #004 4) Please check the type of chemical [s] added to the wastewater for treatment, per each separate discharge point (if applicable, use separate sheet): ❑ Chlorine ❑ Biocides ❑ Corrosion inhibitors ❑ Algaecide ❑ Other [#None 5) If any bog in item (4) above [other than None] was checked, a completed Biocide 101 Form and manufacturers' information on the additive must be submitted to the following address for approval: NC DENR / DWQ / Environmental Sciences Section Aquatic Toxicology Unit 1621 Mail Service Center Raleigh, NC 27699-1621 6) Is there any type of treatment being provided to the wastewater before discharge (i.e., retention ponds, settling ponds, etc.)? f�Yes ❑ No (If yes, please Include design specifics (i.e., design volume, retention time, surface area, etc.) with submittal package, Existing treatment facilities should be described in detail. ) fee S h ee_+ 7) Discharge Frequency: a) The discharge is• ❑ Continuous [Intermittent 1❑ Seasonal* i) If the discharge is intermittent, describe when the discharge will occur: See 90T ii) *Check the month(s) the discharge occurs: 21an gFeb [H'Mar. PApr [ May 8 Jun MOJul [g,'Aug. wept. EDIO' ct. [r'Nov. 16ec. b) How many days per reek is there a discharge? c- tlf c) Please check the days discharge occurs: mat. ErSun. M-Mon. B-fu-e. 1314ed. Grfhu. Cfri. 8) Receiving stream ls]: a) To what body or bodies of water (creek, stream, river, lake, etc.) does the facility discharge wastewater? If the site discharges wastewater to a separate storm sewer system (4S), name the operator of the 4S (e.g. City of Raleigh). LAlt -r ► Ri�C, -�"- �=� b) Stream Classification: T Palma 5)nfR 6.) All drains within the Santeetlah Facility (with the exception of the Oil Room) are routed to two 4400 gallon sump located in the basement of the Powerhouse. A transfer pump removes storm water that collects in the downstream sump to the river through Outfall 003. An automatic level control system operates the pump. Any floating oils collected in the sump are removed by an oil skimmer and placed in a drum for disposal. 7.) Discharge Frequency: a.) i.) Discharges from Outfall 001 and 002 only occur when Generators are running. Outfall 003 is a stormwater and seepage outfall and only discharges when the sump fills with rainwater or seepage water. NCG500000 renewal application Additional Application Requirements: The following information must be included in triplicate [original + 2 copies] with this application or it will be returned as incomplete. S Site map. If the discharge is not directly to a stream, the pathway to the receiving stream must be clearly indicated. This includes tracing the pathway of a storm sewer to its discharge point. i Authorization for representatives. If this application will be submitted by a consulting engineer (or engineering firm), include documentation from the Permittee showing that the consultant submitting the application has been designated an Authorized Representative of the applicant. Certification I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief such information is true, complete, and accurate. Printed Name of Person Signing: Jl UL'} A'"V /11-1 Title: V , 61 i2- 3-AN 0� (Signature of Applicant) (Date Signed) North Carolina General Statute 143-215.6 b (i) provides that: Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan or other document filed or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or who falsifies, tampers with or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both, for a similar offense.) This Notice of Renewal Intent does NOT require a separate fee. The permitted facility already pays an annual fee for coverage under NCG500000. Mail the original and two copies of the entire package to: Mr. Charles H. Weaver NC DENR / DWQ / NPDES 1617 Mail Service Center Raleigh, North Carolina 27699-1617 E §• ; On\ \ / § CD R \ \ § ; / f c k c ( k k 2 Q 0 C m R \ CDE m �$ \ n = n \ o k ƒ , ^ R E r / � ■ ) ) 7 - \ k \ \ \ \ \ CD� ° q < q . $ A.¢ ■ \ \ \ \ \ ( CD CD CD \ ( \ n 0 � � ■ � 3 \ \ ) OTI Ul � $ w � � \ k / / \ 0 \ k \ ~ :0 . . / 0 \ . . D a e \ \ rE, \ 0 7 \ § 9 NORTH fA m s O M i N mr i p c is H r w m - �s L O 9 3 f!7 Cn eT �3 c� om m c y m e 000°000 m 3 000 000 a N � m m a fA = p 7 m o o m a m a CL m 0 w o n O a c m m m� a u c � C! X m Pi ACD r N 00 Q1 y5. r a 3cm /I�t (p Z OD 223!y . n � 0 el A7 � rn A a o�a4 Drn m O D�p ~ _Z, C $ r> Z C'1 y mr O� o = r m r > m o X2 mZ m Dy T - m �m A G�� m i �m Nj 4 — n^o " NORTH S� a �'mWu .Ai o � � �i mN 6s � s Z. o O O O L7 -"O• �o ; a :o x o Z o ti a w�� s NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross, Jr., Secretary Alan W. Klimek, P.E., Director November 15, 2006 Bruce A. Cox Alcoa Power Generating, Inc. 300 North Hall Rd Alcoa, TN 37701 Subject: NPDES Permit NCG5OOOOO renewal Certificate of Coverage (CoC) NCG50OO5O Santeelah Powerhouse Graham County Dear Permittee: The facility listed above is covered under NPDES General Permit NCG5OOOOO. NCG5OOOOO expires on July 31, 2007. Federal (40 CFR 122.41) and North Carolina (15A NCAC 2H.O1O5(e)) regulations require that permit renewal applications must be filed at least 180 days prior to expiration of the current permit. If you have already mailed a renewal request, you may disregard this notice. To satisfy this requirement, the Division must receive a renewal request postmarked no later than February 1.2007. Failure to request renewal by this date may result in a civil penalty assessment. Larger penalties may be assessed depending upon the delinquency of the request. This renewal notice is being sent well in advance of the due date so that you have adequate time to prepare your application. If any discharge previously covered under NCG5OOOOO will occur after July 31, 2007, the CoC must be renewed. Discharge of wastewater without a valid permit would violate North Carolina General Statute 143-215.1; unpermitted discharges of wastewater may be assessed civil penalties of up to $25,000 per day. If all discharge has ceased at your facility and you wish to rescind this CoC [or if you have other questions], contact me at the telephone number or e-mail address listed below. Sincerely, Charles H. Weaver, Jr. NPDES Unit cc: Central Files NPDES File 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 512 North Salisbury Street, Raleigh, North Carolina 27604 Phone: 919 733-5083, extension 511 / FAX 919 733-0719 / charles.weaver@ ncmai1.net An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper NorthCarolina Naturally State of, North Carol ir ) A A; Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross Jr., Secretary Alan W. Klimek, P.E.; Director B J POLK TAPOCO INC/SANTEETLAH PWRHSE 300 NORTH HALL RD ALCOA, TN 37701 Dear Permittee: yW NCDENR Subject: Reissue - NPDES Wastewater Discharge Permit Tapoco Inc/Santeetlah Pwrhse COC Number NCG500050 Graham County In response to your renewal application for continued coverage under general permit NCG500000, the Division of Water Quality (DWQ) is forwarding herewith the reissued wastewater general permit Certificate of Coverage (COC). This COC is reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated May 9, 1994 (or as subsquently amended). The following information is included with your permit package: * A copy of the Certificate of Coverage for your treatment facility • A copy of General Wastewater Discharge Permit NCG500000 * A copy of a Technical Bulletin for General Wastewater Discharge Permit NCG500000 Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require modification or revocation and reissuance of the Certificate of Coverage. This permit does not affect the legal requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit package please contact Aisha Lau of the Central Office Stormwater and General Permits Unit at (919) 733-5083, ext. 578 Sincerely, for Alan W. Klimek, P.E. cc: Central Files Stormwater & General Permits Unit Files Asheville Regional Office 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone 919-733-5083 FAX 919-733-0719 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper 7: Slot Cutting Procedures - Santeetlah Dam TAPOC O Division, APGI Subject: FW: Slot Cutting Procedures - Santeetlah Dam TAPOC O Division, APGI Date: Mon, 6 Jan 2003 14:41:01 -0500 From: 'Browning, Mark A." <Mark.Browning@alcoa.com> To: "Larry Frost (E-mail)" <Larry.Frost@ncmail.net> CC: "Oxendine, Bob E." <Bob.Oxendine@alcoa.com>, "Huddleston, Dale E." <Dale.Huddleston@alcoa.com> Mr. Frost: As we discussed this afternoon, TAPOCO needs to cut a slot (expansion joint purpose) in the Santeetlah dam in Graham County. The anticipated project start date is January 15. The project duration is through February 28. This is very similar to the project you approved for the other side of the dam in January 2001. The slurry processing capacity of the slurry control system is based on the number of troughs. At Santeetlah, we will have a 3-trough system. With the 3 troughs, the system can handle about 40 gpm under normal conditions. The Contractor will introduce lake water at the rate of 5 gpm to act as a lubricant for the cutting. In addition, there will be dam leakage associated with this portion of the dam. The attached files contain a brief description of the slurry control system, a photo, a site plan sketch, and a flow chart of the system. Please review these procedures and provide us with any regulatory requirements for this project. Mark Browning Environmental Affairs Alcoa Inc. - TN Ops (865) 977-3627 246-3627 (network) mark.browningCalcoa.com Name: The Slurry Control System 2003.doc' The Slurry Control System 2003.doc Type: Winword File (application/msword) Encoding: base64 Download Status: Not downloaded with message .......... ..... . .......... _._ Name: LOCATION OF SLURRY SETUP 2003.doc =-LOCATION OF SLURRY SETUP 2003.doc` Type: Winword File (application/msword) i__ , Encoding: base64 Download Status: Not downloaded with message Name: Slurry System.jpg .&Slurry SystemJ129 Type: JPEG Image (image/jpeg) Encoding: base64 1/10/2003 2:31 PM 1 of 1 The Slurry Control System Construction services will be performed at Santeetlah Dam, which involve the cutting of a slot in the concrete of the right abutment. The cured concrete that was placed many decades ago will be cut with a wire that has diamond -impregnated beads on it. These beads will cut (grind and pulverize) the concrete. Water is used as a lubricant for this process. During the cutting process a slurry will result from the mixing of the water and the pulverized concrete. This slurry water will be collected, piped and treated with a three tank slurry collection system prior to its release into the reservoir. The three tank slurry collection system works in following manner. The collected slurry water is piped to a trough (tank) which contains seep holes to which filter bags are attached. The water will pass through the bags and the slurry will be captured inside the bags. Beneath the trough is a basin to collect the water and any slurry that may have passed through the bags. This water will be circulated back into the tank collection system. At the far end of the trough is an overflow which allows the water to flow into the next trough, in the series of the 3 troughs, where the water is again processed in the same manner. Overflow from the second trough flows to the third trough for additional processing. The effluent from the third trough, which will be clean water, will be piped to the reservoir. The discharge end of the pipe will be at least 20 feet below the water level. The Site Plan drawing shows the location of the troughs on the right abutment. The Conceptual Layout drawing shows the flow logic of the system. Below is a photo of the 3 trough system showing the white filter bags hanging from the troughs, the overflow pipes between the tops of the troughs, and the containment/settling basin for each trough. The photo was taken at the Contractor's facility. The system will be set-up at Santeetlah Dam in a similar manner. C:\WINDOWS\TEMP\The Slurry Control System 2003.doc F5 3: 0 Do i LL 9� 3 image 927x652 pixels Conceptual Layout of Slurry Systei collection Caisson (a bin 0 do's ufs face face of slot Pump Slurry troughs` Collection bin toe of block 4 w/ filter bags & Pump catch basin enclosing troughs ;1) Water shall be pumped to slum} troughs during slot cutting. Clean water from caisson leakage during periods of non -wire saw cutting will be pumped directly to reservoir after first flushing the pipe clean. 1/10/2003 2:32 PM 6tate of North CarolinG� j,, Department of Environs- gent and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross Jr., Secretary Gregory J. Thorpe, Ph.D., Acting Director 11/26/2001 B J POLK TAPOCO INC/SANTEETLAH PWRHSE 300 NORTH HALL RD ALCOA, TN 37701 1 a AIv NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES Subject: NPDES Wastewater Permit Coverage Renewal Tapoco Inc/santeetlah Pwrhse COC Number NCG500050 Graham County Dear Permittee: Your facility is currently covered for wastewater discharge under General Permit NCG500000. This permit expires on July 31, 2002. Division of Water Quality (DWQ) staff is in the process of rewriting this permit with a scheduled reissue in the summer of 2002. Once the permit is reissued, your facility would be eligible for continued coverage under the reissued permit. In order to assure your continued coverage under the general permit, you must apply to the DWQ for renewal of your permit coverage. To make this renewal process easier, we are informing you in advance that your permit coverage will be expiring. Enclosed you will find a general permit coverage renewal application form. This will serve as your application for renewal of your permit coverage. The application must be completed and - returned with the required information by February 01, 2002 in order to assure continued coverage under the general permit. There is no renewal fee associated with this process. Your facility will be invoiced for the annual permit fee at a later date. Failure to request renewal within this time period may result in a civil assessment of at least $250.00. Larger penalties may be assessed depending on the delinquency of the request. Discharge of wastewater from your facility without coverage under a valid wastewater NPDES permit would constitute a violation of NCGS 143-215.1 and could result in assessments of civil penalties of up to $10,000 per day. If the subject wastewater discharge to waters of the state has been terminated, please complete the enclosed rescission request form. Mailing instructions are listed on the bottom of the form. You will be notified when the rescission process has been completed. If you have any questions regarding the permit coverage renewal procedures please contact the Asheville Regional Office at 828-251-6208 or Delonda Alexander of the Central Office Stormwater Unit at (919) 733-5083, ext. 584 Sincerely, Bradley Bennett, Supervisor Stormwater and General Permits Unit cc: Central Files Stormwater and General Permits Unit Files Asheville Regional Office 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper Santeetlah Dam TAPOCO Subject: Slot Cutting Procedures - Santeetlah Dam TAPOCO Date: Thu, 1 I Jan 2001 09:01:26 -0500 From: "Browning, Mark A." <Mark.Browning@alcoa.com> To: "'larry.frost@ncmail.net"' <larry.frost@ncmail.net> CC: "Oxendine, Bob E." <Bob.Oxendine@alcoa.com>, "Polk, Julian <Julian.Polk@alcoa.com>, "Huddleston, Dale E." <Dale.Huddleston@alcoa.com> Mr. Frost, As we discussed this morning, TAPOCO needs to cut a slot (expansion joint purpose) in the Santeetlah dam. The anticipated project start date is the week of January 22. The project duration is estimated at 3 months. Lake water will be used as a lubricant during the cutting of the concrete, which will result in a concrete slurry. TAPOCO has designed a slurry treatment process for your review. As designed, the treated water will be returned to the lake. I have attached 3 files, which contain a schematic of the dam, a wastewater flow chart, and a written description with a digital photo of the slurry, treatment system proposed for use. Please review these procedures and provide us with any regulatory requirements for this project. <<SANT Slurry Control System>> <<SANT SLURRY SETUP rl>> Mark Browning Environmental Affairs Alcoa Inc. - TN Ops (865) 977-3627 246-3627 (network) mark.browning@alcoa.com <<Flow Chart for Slurry Discharge>> Name: SANT Slurry Control System.doc Type: Winword File (application/msword) �_=�SANT Slurr Control System.doc Encoding: base64 i _,Y g� Description: SANT Slurry Control System Download Status: Not downloaded with message Name: Flow Chart for Slurry Discharge.xls Type: Microsoft Excel Worksheet - ;Flow Chart for Slurry Discharge.xls (application/vnd.ms-excel) Encoding: base64 Description: Flow Chart for Slurry Discharge !Download Status: Not downloaded with message Name: SANT SLURRY SETUP rl.doc Type: Winword File (application/msword) SANT SLURRY SETUP rl .doc Encoding: base64 Description: SANT SLURRY SETUP rl !Download Status: Not downloaded with message 1/12/2001 9:38 AM The Slurry Control System Construction services will be performed at Santeetlah Dam, which involve the cutting of a slot in the concrete of the left abutment. The cured'concrete that was placed many decades ago will be cut with a wire that has diamond -impregnated beads on it. These beads will cut (grind and pulverize) the concrete. Water is used as a lubricant for this process. During the cutting process a slurry will result from the mixing of the water and the pulverized concrete. This slurry water will be collected, piped and treated with a three tank slurry collection system prior to its release into the reservoir. The three tank slurry collection system works in following manner. The collected slurry water is piped to a trough (tank) which contains seep holes to which filter bags are attached. The water. will pass through the bags and the slurry will be captured inside the bags. Beneath the trough is a basin to collect the water and any slurry that may have passed through the bags. This water will be circulated back into the tank collection system. At the far end of the trough is an overflow which allows the water to flow into the next trough, in the series of the 3 troughs, where the water is again processed in the same manner. Overflow from the second trough flows to the third trough for additional processing. The effluent from the third trough, which will be clean water, will be piped to the reservoir. The Site Plan drawing shows the location of the troughs on the left abutment. The Conceptual Layout drawing shows the flow logic of the system. Below is a photo of the 3 trough system showing the white filter bags hanging from the troughs, the overflow pipes between the tops of the troughs, and the containment/settling basin for each trough. The photo was taken at the Contractor's facility. The system will be set-up at Santeetlah Dam in a similar manner. C:\WINDOWS\TEMP\SANT Slurry Control System.doc � .. 0 o . w a CD . �• \ ) \ - \ \ & © Q \ \ 9 � 4 CD qq X / / R CD �( / CD . / p . ƒ D . � R � ƒ � . �ƒ 2 R \ 8 y / ƒC) al * . .- \ CD Y O / » . & CD. n 0 . 5 ? CD-1 ƒ m . /. . . . C . » . / % CD . . . 1< ; . $ O c . . � D 5 S CDcn � . . . . m . % CD CD & . m sue; O "ZIN/ TAPOCO INC. 1998 August 18 Certified Mail Return Receipt Requested Z 455 066 356 vr- Tapoco, Inc. 300 North Hall Road Alcoa, Tennessee 37701-2516 (615) 977-3321 Mr. D. Keith Haynes =r, Environmental Specialist State of North Carolina 2 f` 19Q� Department of Environment, Health and Natural Resources WATER QUALITY SECII3I� 59 Woodfin Place I�SNEVILL REGiQAt aF�c� Asheville, N.C. 28801 RE: Oil & Grease Excursions - Tapoco, Inc. - Graham County Santeetlah Powerhouse - General Permit # NC500050 Cheoah Powerhouse - Permit # NC500049 Dear Mr. Haynes: At approximately 4:35 p.m. on 1998 August 12, two (2) daily maximum excursions were discovered while inputting monitoring data into our tracking system. A 1998 January 30 oil and grease sample collected from the Cheoah station sump (outfall 004) yielded a result of 23.9 mg/L. A 1998 April 30 oil and grease sample collected from the Santeetlah station sump (outfall 003) yielded a result of 20.1 mg/L. The daily maximum limit for both locations is 20 mg/L. At Cheoah, samples collected in 1997 October, 1998 May, and 1998 July yielded results of 9.9, 13.4, and 3.6 mg/L, respectively. At Santeetlah, samples collected in 1997 October, 1998 January, and 1998 July yielded results of 8.2, 6.2, and 8.9 mg/L, respectively. The data indicates an intermittent, rather than chronic, release of oil and grease. Mr. Mark Browning, Environmental Affairs, ALCOA-Tennessee Operations, reported and discussed the excursions with Mr. Forrest Westall and yourself during the afternoon of August 13. The requirement for verbal notification within 24 hours of becoming aware of the excursions was met. You waived the 5 day written submission requirement, because the excursions were not a significant threat to health or the environment. You required instead this follow-up letter to document the events and outline corrective actions. Mr. Haynes 1998-08-18 Page 2 Tapoco, Inc. is investigating the causes of the excursions. Oil skimmer operation and maintenance procedures at both station sumps will be reviewed and modified if necessary. The existing sump pumps have oil -lubricated bearings. Replacement by sump pumps with oil -less bearings will be investigated and implemented if feasible. Tapoco, Inc. will develop and implement Standard Operating Procedures (SDP's) to ensure that all monitoring data is reviewed in a timely fashion. Environmental Affairs personnel from ALCOA-Tennessee Operations will assist with compliance issues. Thank you for you assistance with this issue. If you need further information, please call Mark Browning at (423) 977-3627. Sincerely, . Julian Polk, Jr. Vice -President Tapoco, Inc. BJP/mab cc: Burlin Gladden, Tapoco, Inc., S35 Dale Huddleston, ALCOA-TN Ops, S31 Mark Browning, ALCOA-TN Ops, S34 John Morton, ALCOA, Pgh-EHS Services, 1936D RPCC for APGI-TAPOCO/SANTEETLAH NC RELEASE PREVENTION, CONTROL and COUNTERMEASURE (RPCC) PLAN for THE SANTEETLAH POWER FACILITY NORTH CAROLINA ALCOA POWER GENERATING INC. TAPOCO DIVISION 300 NORTH HALL ROAD ALCOA, TN 37701 Prepared by: DENNIS WEETER ASSOCIATES 322 HIGH STREET MARYVILLE, TENNESSEE 37804 865/ 984-0256 e-mail: weeterl @aol.com November 2004 COPYRIGHT © 2004 Environment, Health, and Safety Services North America Alcoa Inc. This manual and all information in it is the property of Alcoa Inc. The information is confidential and is not to be copied, exhibited or given to others, nor may photographs be taken of any contents of the manual without consent of Alcoa Inc. r16 ` k This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties; guarantees] pi implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. 2004 ssed or RPCC for APGI-TAPOCO/SANTEETLAH NC RPCC OUTLINE TABLE OF CONTENTS Paqe GENERAL INTRODUCTION ................................................. INTRO - i REGULATORY CORRELATION TABLE CLEANAIR ACT.......................................................................... RCT - 1 CLEANWATER ACT................................................................... 1 COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT ............................. 8 HAZARDOUS MATERIALS TRANSPORTATION ACT ............... 8 OCCUPATIONAL SAFETY AND HEALTH ACT .......................... 9 RESEARCH & SPECIAL PROGRAMS ADMINISTRATION (RSPA) 12 PIPELINE RESPONSE PLAN................... ...... ........ RESOURCE CONSERVATION AND RECOVERY ACT .............. 13 SUPERFUND AMENDMENT AND REAUTHORIZATION ACT 19 TOXIC SUBSTANCES CONTROL ACT ...................................... 19 U.S. COAST GUARD FACILITY RESPONSE PLAN ................... 20 STATE REQUIREMENTS........................................................... 22 EMERGENCY RESPONSE ACTION PLAN A. EMERGENCY RESPONSE COORDINATOR INFORMATION.................................................................... ERAP - 1 B. DISCOVERY AND ALERT PROCEDURES ......................... 2 C. EMERGENCY NOTIFICATION PHONE LIST ...................... 3 D. RELEASE RESPONSE NOTIFICATION FORMS ................ 4 E. EMERGENCY RESPONSE EQUIPMENT ........................... 5 F. FACILITY RESPONSE TEAM .............................................. 7 G. EVACUATION PLAN............................................................ 7 H. IMMEDIATE ACTIONS........................................................ 7 1. FACILITY DIAGRAMS......................................................... 9 J. DISTRIBUTION LIST............................................................ 9 SECTION I GENERAL FACILITY INFORMATION A. GENERAL FACILITY INFORMATION ................................. 1-1 B. FACILITY DESCRIPTION.................................................... 2 C. STATEMENT OF RELEASE PLAN POLICY ....................... 8 D. PLAN CERTIFICATION....................................................... 10 E. PLAN REVIEW AND AMENDMENT .................................... 10 F. RELEASE EVENT HISTORY ............................................... 11 G. PLAN DISTRIBUTION LIST...........................I...................... 12 TOC 1 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC SECTION II MATERIALS AND FACILITY INVENTORY A. EXPLANATION OF INVENTORY CODES ........................... II - 1 B. FACILITY MAP..................................................................... 3 SECTION III MINIMUM POLLUTION PREVENTION MEASURES A. FACILITY DESIGN............................................................... III - 1 B. FACILITY MAP..................................................................... 2 C. FACILITY OPERATION....................................................... 2 D. LOADING/UNLOADING OPERATIONS .............................. 4 E. SALT STORAGE AREAS ..................................................... 5 F. ATMOSPHERIC RELEASES ............................................... 5 G. DISCHARGE DETECTION SYSTEMS ................................ 6 H. SECURITY........................................................................... 6 I. TOXIC ORGANICS OR SOLVENT MANAGEMENT PLANS 7 J. BEST MANAGEMENT PRACTICES (BMP) PROGRAM ..... 7 SECTION IV CONTINGENCY PLAN A. GENERAL OVERVIEW........................................................ IV - 1 B. EMERGENCY RESPONSE COORDINATORS ................... 1 C. STORM WATER POLLUTION PREVENTION TEAM.......... 3 D. FACILITY EMERGENCY RESPONSE PERSONNEL.......... 3 E. EMERGENCY RESPONSE CONTRACTORS ..................... 3 F. PREPAREDNESS AND PREVENTION ............................... 3 G. EMERGENCY RESPONSE EQUIPMENT ........................... 6. SECTION V EMERGENCY RESPONSE PROCEDURES A. GENERAL OVERVIEW........................................................ V - 1 B. ALERT PROCEDURES....................................................... 2 C. EMERGENCY DISPATCHER'S RESPONSIBILITIES......... 2 D. EMERGENCY NOTIFICATION PROCEDURES .................. 4 E. REQUIRED ALCOA NOTIFICATIONS ................................. 14 F. EMERGENCY RESPONSE PROCEDURES ....................... 15 G. OSHA EMERGENCY RESPONSE PLAN ............................ 18 H. DISPOSAL PLANS....................:.......................................... 18 I. INCIDENT INVESTIGATION AND CRITIQUE OF EMERGENCY RESPONSE ................................................. 21 SECTION VI INSPECTIONS AND RECORDS A. GENERAL OVERVIEW .................: - B. INSPECTION SCHEDULE ................................................... 4 C. EXAMPLE INSPECTION FORMS ........................................ 8 D. RECORDKEEPING.............................................................. 8 TOC 2 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC SECTION VII PERSONNEL TRAINING A. TRAINING OVERVIEW........................................................ VII - 1 B. TRAINING PROGRAMS...................................................... 1 C. TRAINING PROGRAM OUTLINES ...................................... 6 D. FACILITY RESPONSE TRAINING AND DRILLS ................ 6 E. TRAINING RECORDS......................................................... 6 SECTION VIII STORM WATER POLLUTION PREVENTION PLANS A. POLLUTION PREVENTION TEAM ...................................... VIII - 1 B. DESCRIPTION OF POTENTIAL POLLUTION SOURCES.. 1 C. BEST MANAGEMENT PRACTICES (BMPS)....................... 1 D. COMPREHENSIVE SITE COMPLIANCE EVALUATION .... 1 E. CONSISTENCY WITH OTHER PLANS ............................... 1 F. SPECIAL REQUIREMENTS ............................................... 1 SECTION IX OPA DISCHARGE AND RESPONSE SCENARIOS A. VULNERABILITY ANALYSIS ............................................... IX - 1 B. DISCHARGE SCENARIOS .................................................. 1 C. RESPONSE RESOURCES .................................................. 1 APPENDICES A. INSPECTION FORMS .........................................................TAB: APDX A B. REPORTS AND RECORDS ................................................TAB: APDX B C. AGREEMENTS AND CONTRACTS ....................................TAB: APDX C D. REPORTABLE QUANTITIES...............................................TAB: APDX D E. MATERIAL SAFETY DATA SHEETS ..................................TAB: APDX E F. EMERGENCY RESPONSE PROCEDURES FOR SELECTED MATERIALS ............................................TAB: APDX F G EVACUATION PLAN............................................................TAB: APDX G H. MAPS AND DRAWINGS ......................................................TAB: APDX H 1. ACRONYMS USED IN THIS DOCUMENT ..........................TAB: APDX J. OIL POLLUTION ACT (OPA) WORKSHEETS AND APPENDICES......................................................................TAB: APDX J K. SITE SPECIFIC HEALTH AND SAFETY PLAN...................TAB: APDX K L. STORM WATER PERMIT.....................................:......TAB: APDX L TOC 3 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCC/SANTEETLAH NC INTRODUCTION This Release Prevention, Control and Countermeasure (RPCC) Plan has been prepared for Alcoa Power Generating Inc., Tapoco Division (APGI-Tapoco), The Santeetlah Power Facility (Santeetlah) in accordance with federal and the state of Tennessee regulations regarding release prevention and control. This plan is designed to provide the controls and procedures necessary to minimize hazards to human health and the environment from fires, explosions, and releases of toxic and hazardous substances to the air, soil, surface waters, and groundwater. This plan incorporates, where applicable, the pollution prevention, spill control and countermeasures, and emergency planningand response provisions required by the following regulations: • Spill Prevention, Control, and Countermeasures (SPCC) requirements for oils under the Clean Water Act (CWA) and for PCBs under the Toxic Substances Control Act (TSCA) • Contingency Plan requirements for hazardous wastes under the Resource Conservation and Recovery Act (RCRA) • Emergency Response requirements for hazardous and toxic substances under the Superfund Amendments and Reauthorization Act (SARA) • Storm water Pollution Prevention (SWPP) and Best Management Practices requirements under the CWA • Release Prevention and Emergency Response requirements of the Hazardous Materials Transportation Act (HMTA) • Emergency Action Plan and Emergency Response Plan (HAZWOPER) requirements Under the Occupational Safety and Health Act (OSHA) • Environmental Protection Agency (EPA) Facility Response Plan requirements under the Oil Pollution Act (OPA) amendments to the CWA • US Coast Guard Facility Response Plan requirements for marine transportation -related facilities handling oil under the OPA amendments to the CWA • Minerals Management Service (MMS) Facility Response Plan requirements for oil handling facilities under the OPA amendments to the CWA • Research and Special Programs Administration (RSPA) Pipeline Response Plan requirements for oil pipelines under the OPA amendments to the CWA • Emergency Planning and Response requirements of the Chemical Process Safety Management Standard under OSHA • Emergency Response Program requirements for chemical accidental release prevention under the Clean Air Act (CAA) amendments § 112(r). General Duty Clause requirements for operating and maintaining a safe facility under the Clean Air Act (CAA) amendments §112(r). This plan was also prepared within the spirit of the National Response Team's Integrated Contingency Plan Guidance in a format intended to provide a highly INTRO - i November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or. implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC functional document for use in various emergency situations while providing a mechanism for complying with the multiple agency requirements listed above. The RPCC Plan begins with a Regulatory Correlation Table which provides a listing of the various Federal regulatory citations for emergency response and planning requirements. The table cross references sections in the Outline and this Plan which address each of the regulatory requirements, applicable to this facility. This table is intended to assist plant personnel in determining if specific planning requirements are applicable to their facility, and to assist Agency inspectors in assessing compliance with the various regulations. The National Response Team does not require a standardized emergency response plan format as long as a cross reference to applicable regulatory requirements is provided. The next section, Emergency Response Action Plan (ERAP) is the core of the RPCC Plan. It contains only the essential steps necessary to initiate, conduct, and conclude an emergency response action: recognition of the emergency, notification of the appropriate people/agencies, and initial response measures including assessment, mobilization, and implementation of the proper procedures to prevent or minimize risks to health or the environment. The ERAP is a separately tabbed section that locations are advised to copy and keep in a separate binder for quick access by the Emergency Response Coordinator and other appropriate spill response personnel. The rest of this document contains key supporting information for conducting preventative actions, and emergency response procedures to be followed in the event of an emergency. It also contains information necessary to document compliance with all of the location applicable regulatory requirements identified in the Regulatory Correlation Table. Designated employees of APGI-Tapoco's Santeetlah Facility are familiar with the contents of this plan, and are trained to carry out the necessary procedures either as a location team or in concert with Alcoa, Inc. -Tennessee Works, Graham County Fire Department, Graham County Emergency Management Agency, North Carolina Emergency Management Agency, North Carolina Division of Environmental Management, US EPA Region IV, National Response Center, and HEPACO, Inc. The revisions to the oil spill regulations, effective July 2002, received another extension. EPA published the extension in the Federal Register on 2004 August 11, volume 69, number 154, pages 48794-48799. The new compliance dates are: Amend SPCC Plan 2006 February 17 Implement SPCC Plan 2006 August 18 INTRO - H November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Topic CLEAN AIR ACT EPA's Risk Management Program (RMP) (40 CFR 68) Storage of highly hazardous or flammable chemicals above threshold quantities Procedures for informing the public and response agencies First aid and emergency medical treatment Emergency; response procedures Emergency response equipment Employee training Procedures for review and update Coordination with community emergency response plan • Reporting of releases The General Duty Clause (112(r)(1)) • Knowledge of hazards posed by chemicals and potential impacts • Implementation of codes, standards, and other business practices to ensure the facility is properly constructed and maintained to safely manage the chemicals • Contingency planning process CLEAN WATER ACT (CWA) Regulatory Citation specific permit conditions rules established by the 68.95(a)(1)(I) 68.95(a)(1)(ii) 68.95(a)(1)(iii) 68.95(a)(2) 68.95(a)(3) 68.95(a)(4) 68.95(c) 70.6(a)(3)(iii)(B) 112(r)(1) RPCC Outline RPCC Plan Section # Page # l NOT APPLICABLE ERAP B, C, V.A., V.C. ERAP E. IV.G. V.F. IV.G., VI.B. VII.B. I. E., I.C. V.D. 1.C. I-8 II.A., III.F., V.A.. Appendix D & H II-1 III-8 V-1 APP D&H III.A., B.& C., V.I., VI.A., VI.B., VII.A. 11I-1,2 V-20 VI-1,4 VII-1 ERAP G, W.A., B.,D.—G.,V:C.,i, D.,F., Appendix B. & G.. ERAP-7 IV-4 IV-7 V-2 APP B&G Discharge of Oil (40 CFR 110) Discharge of oil into navigable waters • Discharge of oil in such quantities as "may be harmful"W1O.W • Prohibited use of dispersants • Discharge of oil not determined as "may be harmful"• Notification of National Response Center (NRC)V-4 V-4 V-4 Oil Pollution Prevention (40 CFR 112) Spill Prevention, Control, and Countermeasures Plans November 2004 Note: if this section applies to your location you must address every requirement in your plan. H not applicable put an "N/A" in last column of this table with an accompanying explanation on a separate but enclosed and cross referenced sheet Note regulatory re Ui ,ements of 112.8 and 112.12 are the same; 112.12 RCT - 1 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied; are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Topic Regulatory Citation RPCC Outline Section # RPCC Plan Page # applies to animal, fish and vegetable oils while 112.8 applies to all other oils. • General Applicability 112.1 underground storage capacity (>42,000 gallons) 112.1(d)(2)(i) I.C. 1-8 - aboveground storage capacity (>1,320 gallons total) 112.1(d)(2)(ii) I.C. 1-8 - underground tanks subject to RCRA 280 or 281 requirements 112.1(d)(4) ERAP I ERAP 9 - compliment other safety standards, fire prevention, and pollution prevention rules 112.1(e) I.C. 1-8 • Preparation and implementation of SPCC Plans 112.3 - professional engineer certification 112.3(d) I.D. 1-10 - maintenance of SPCC Plan at facility 112.3(e) I.G. 1-7 • SPCC Plan amendment by administrator 112.4 V.D.6 V-4 - report of discharge of oil within 12 month period 112.4(a) V.D.6. V-4 - notification of state agency in charge of oil pollution control activities 112.4(c) V.D.6. V-4 • SPCC Plan amendment by owner/operator 112.5 I.E., 1-10 - Plan amendment with change in facility 112.5(a) I.E., 1-10 - Plan five-year review 112.5(b) I.E., 1-10 • SPCC General Requirements 112.7 - - full approval of management 112.7 I.C. 1-8 - cross referencing of SPCC requirements 112.7 RCT RCT - additional facilities or procedures, methods, or equipment not yet operational 112.7 IILA., IILC. III-1,2 - facility conformance with SPCC requirements 112.7(a)(1) I.C. 1-8 - explain reasons for nonconformance and describe equivalent protection 112.7(a)(2) 11LA 111-1 - type of oil and container storage capacity 112.7(a)(3)(i) Table II-1 II-4 - discharge prevention measures for loading/unloading 112.7(a)(3)(ii) HID III-4 - discharge and drainage controls 112.7(a)(3)(iii) IILC 111-4 - countermeasures for discharge discovery, response and cleanup 112.7(a)(3)(iv) ERAP B, ERAP H, ERAP-2,7 - methods of disposal of recovered material 112.7(a)(3)(v) V.H. V-19 - contact list and phone numbers 112.7(a)(3)(vi) ERAP C, V.D. ERAP-3 V-4 - reporting information 112.7(a)(4) ERAP B, ERAP D ERAP-2,4 - procedures readily usable 112.7(a)(5) ERAP B, ERAP H ERAP-2,7 prediction of direction, rate, and quantity from failure 112.7(b) I.B.6., V.F. I-2 V-16 containment and/or diversionary devices (on shore facilities) 112.7(c) IILA. III-1 demonstration of impracticability, contingency plan 112.7(d) III.A. III-1 written inspection procedures and signed records 112.7(e) VI.B.,C.,D. VI-4,8 training of personnel 112.7(f)(1) VILA. VII-1 designated person for oil spill prevention 112.7(f)(2) W.B. IV-1 - spill prevention briefings 112.7(f)(3) N.B., VILA.,6.1.i. IV-1 VII-1 fencing and locked or guarded entrance gates 112.7(g)(1) I11.H.1,2 III-6 - locked master flow and drain valves 112.7(g)(2) III.H.5,6 III-6 - locked or secured oil pump starter controls 112.7(g)(3) III.H.6. 111-6 capped or flanged loading/unloading connections 112.7(g)(4) III.H.7. 111-6 - facility lighting 112.7(g)(5) IILH.3. 111-6 RCT - 2 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Topic Regulatory Citation tank car and tank truck loading/unloading 112.7(h) containment' drainage for truck loading/unloading 112.7(h)(1) - prevention of vehicle departure before complete 112.7(h)(2) disconnection - examination of drain and outlets prior to filling and 112.7(h)(3) departure RPCC Outline' RPCC Plan Section # LPage # IILD. III-4 III.D. III-4 III.D. III-4 BUD - brittle fracture evaluation 112.7(i) v1.M � - compliance with State regulations and guidelines 112.7 (1) - inspection of retained storm water prior to discharge 112.8(b)(1), IILA.,C.2., LC. VIILG4. 112.12 b 1 - drainage from diked areas 112.8(b)(2), III.A.,C.2. 112.12 b 2 - drainage from undiked areas 112.8(b)(3), 111.A., C., D. 112.12 b 3 diversion system for final discharge 112.8(b)(4), III.A., C., D. 112.12 b 4 112.8(b)(5), III.A., C., D. - use of lift pumps 112.12 b 5 - compatibility of storage tank with oil 112.8(c)(1), 112.12(c)(1) III.A., C.10., 1 112.8(c)(2), Tables II-1, 11-2, - secondary containment 112.12(c)(2),III.A. 112 8(c)(3) 112 12(c)(3) III.C., VI.B.1 - rainwater or effluent bypass (inspection and record kee in underground tanks cathodic protection and leak testing 112.8(c)(4), 112.12(c)(4) - partially buried / bunkered tanks cathodic protection 112.8(c)(5), 112.12(c)(5) testing and inspections of aboveground tanks 112.8(c)(6), 112.12(c)(6) - control of leakage through defective internal heating 112.8(c)(7), coils 112.12 c 7 112.8(c)(8), 112.12(c)(8) tank overfill protection - observation of effluent discharges to waters 112.8(c)(9), 112.12(c)(9) - correction of visible oil leaks 112.8(c)(10), 112.12 c 10 - of mobile or portable oil storage tanks 112.8(c)(11), positioning 112.12 c 11 - transfer operations 112.8(d), 112.12(d) cathodic protection of buried piping 112.8(d)(1), 112.12(b)(1) - capping of out -of -service pipeline 112.8(d)(2), 112.12(d)(2) - design of pipe supports 112.8(d)(3), 112.12(d)(3) and testing of aboveground valves and 112.8(d)(4), - examination i elines - warnings for aboveground piping 112.12 d 4 112.8(d)(5), 112.12(d)(5) Oil Pollution Prevention (40CFR 112) OPA Phase II Regulations Promulgated July 01, 1994 - Effective August 30, 1994 -If you are subject to SPCC Planning Requirements (preceding section), complete "Certification of Applicability" (see Appendix 13) to determine if the remainder of this section is a licable. 11220(e) • Certification of Applicability • General Response Planning Requirements 11220(g) • Response Plan Elements 112.20(h) • Emergency Response Action Plan 112.20(h)(1) III.A, VI.B.2. III.A V 1. B.22- VI.B. VI.B.2. I.B.4., VI.B.1. IILC.,G., VI.B., III-4 II-1 VI-4 III-1 VI-4 VI-4 III-1,6 VI-4 1-2 VI-4 III-2,6 VI-4 able 11-1,,III.D. II-4 IILA.. III-1 III.H. 111-6 III.A. III-1 VI.B. VI-4 III.C. III 2 NOT APPLICABLE I.C. & App B I.E., I.G. RCT - 3 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGi-TAPOCO/SANTEETLAH NC Topic Regulatory Citation RPCC Outline Section # RPCC Plan Page # Primary Emergency Response Coordinator's name and phone number 112.20(h)(1)(i) ERAP A. - Emergency phone list of individuals and organization to be contacted in event of a release 112.20(h)(1)(ii) ERAP C. - Information to give to response personnel 112.20(h)(1)(iii) ERAP B, D, Appendix B - Response equipment and location 112.20(h)(1)(iv) ERAP E., IV.G. - Response personnel capabilities, duties, and response time 112.20(h)(1)(v) ERAP F., W.A.-E. - Evacuation plans 112.20(h)(1)(vi) ERAP G., IV.F.6., Appendix G - Immediate response actions 112.20(h)(1)(vii) ERAP B, H.,V.F. - Diagram of the facility 112.20(h)(1)(viii) ERAP I., Appendix H • Facility Information 112.20(h)(2) - - Name and address of facility 112.20(h)(2) I.A. - Latitude and longitude of main entrance 112.20(h)(2) LA. - SDWA Wellhead Protection Area, if applicable 112.20(h)(2) 1.B.2. - Name of facility Owner and Operator 112.20(h)(2) I.A. - Name, address, position, emergency phone number, and training experience of Emergency Response Coordinator and all alternates 112.20(h)(2) ERAP A., IV.B. - Year facility first stored oil 112.20(h)(2) I.B.3. - Describe facility operation 112.20(h)(2) I.B.3. - Facility SIC Code 112.20(h)(2) LA. - Date and type of any substantial expansion 112.20(h)(2) I.B.10. • Emergency Response Information 112.20(h)(3) - Private personnel and equipment necessary to respond to a worst case discharge 112.20(h)(3)(i) ERAP C., E., IV.D., E., G. Contracts or agreements for response personnel and equipment 112.20(h)(3)(ii) Appendix C - Emergency phone list of individuals and organizations to be contacted in event of a release 112.20(h)(3)(iii) ERAP B., C. Spill Response Notification Form 112.20(h)(3)(iv) ERAP D, Appendix B - Response personnel capabilities, duties, and response time 112.20(h)(3)(v) ERAP F., IV.A.-E. - Response equipment and location 112.20(h)(3)(vi) ERAP E., IV.G. - Evacuation plans 112.20(h)(3)(vii) ERAP G., IV.F.6., Appendix G - Diagram of evacuation routes 112.20(h)(3)(viii) ERAP G., I., Appendix G - Emergency Response Coordinator duties 112.20(h)(3)(ix) IV.B. • Hazard Evaluation 112.20(h)(4) - Tank/Impoundment inventory 112.20(h)(4) Table II-2 - Storage tanks/impoundments located on drawing 112.20(h)(4) ERAP I., II.B., Appendix H Describe operations that present risk of release (loading & unloading) 112.20(h)(4) III.C., D. Vulnerability analysis 112.20(h)(4) I IX.A. RCT November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Topic - Spill history Tiered Planning Scenarios Worst case discharge Discharge of 2,100 gallons or less Discharge of >2,100 gallons but <36,000 gallons • Discharge Detection Systems Procedures, equipment, personnel used to detect discharges • Plan Implementation Identify response personnel (facility and contracted) for small, medium, and worst case release Identify response equipment needs for small, medium, and worst case release Describe disposal plans for wastes related to spill clean- up - Describe containment volume, drainage path, valves, pumps, etc. used to contain/control release • Inspection and Training Tank and impoundment inspections - Secondary containment inspection Response equipment inspection - Drill/Exercise Pro ram Description of training plan Training and spill prevention meeting logs • Diagrams - Site plan - Drainage plan Evacuation plan • Security Emergency cut-off location Fencing and other enclosures - Guards - Lighting Securing valves, pumps, pipeline connections • Response Plan Cover Sheet • Facility response training and drills/exercise • Appendix F - Facility Specific Response Plan: Model Facility Specific Response Plan Emergency Response Action Plan Facility Information Emergency Response Information: - Notification - Response Equipment List - Response Equipment Testing/Deployment Regulatory Citation RPCC Outline RPCC Plan Section # Page # 112.20(h)(4) IF . (h)5)112.20 112.20(h)(5)(i) IX.B 112.20(h)(5)(ii) IX.B qG 112.20(h)(5)(iii) IX.B 2.2h6 110()(- 0)112.2(h)(6 112.20(h)(7) ' 112.20(h)(7)(i) IX.C. 112.20(h)(7)(ii) IX.C. 112.20(h)(7)(iii) V.H. 11220(h)(7)(iv) I.B.6., Table 11-2, III.A., H. 112.20(h)(8) ' 112.20(h)(8)(i) VI.B.1., 2., C. 112.20(h)(8)(i) VI.B.1., C. 112.20(h)(8)(f) V13.7., C. 112.20(h)(8)(ii), 112.21 VII.D. 112.20(h)(8)(iii), 112.21 VII.A.-E. 112.20(h)(8)(iv), 112.21 VI I. E, Appendix B 112.20(h)(9) - 112.20(h)(9) ERAP I., Appendix H 112.20(h)(9) ERAP I., Appendix H 112.20(h)(9) ERAP G. Appendix G 112.20(h)(10) ' 112.20(h)(10) III.H.5. 11 2.20kn)k 10) III.H.1. 112.20(h)(10) III.H.2. 112.20(h)(10) III.H.3. 112.20(h)(10) III.H.6., 7. 112.20(h)(11) Appendix B 112.21 VII.D.` Appendix F- 1.0 I.G. Appendix F - 1.1, ERAP A - J Appendix F - 1.2 I.A.,I.B.2,3,10 Appendix F - 1.3 - Appendix F - 1.3.1 ERAP B.,C.,D., Appendix B Appendix F - 1.3.2 ERAP E Appendix F - 1.3.3 ERAP E RCT - 5 November 2004 This information is the property mpl imcoa.plied, arelmadet is notas to the accuracry,to be use, dutilty orreffectiveness uof the methods, permission. copied methods,proces es products, or procedu es.r representation, expressed or RPCC for APGI-TAPOCO/SANTEETLAH NC Topic Regulatory Citation RPCC Outline Section # RPCC Plan Page # Personnel Appendix F - 1.3.4 ERAP F, IV.D.,E. - Evacuation Plans Appendix F - 1.3.5 ERAP G., I., IV.F.6, Appendix G Qualified Individual's Duties Appendix F-'1.3.6 IV.B. Hazard Evaluation: Appendix F - 1.4 - - Hazard Identification Appendix F - 1.4.1 Table 11-2 - Vulnerability analysis Appendix F - 1.4.2 IX.A. - Analysis of the Potential for an Oil Spill Appendix F - 1.4.3 IX.B. - Facility Reportable Oil Spill History Appendix F - 1.4.4 I.F. - Discharge Scenarios: Appendix F - 1.5 - Small and Medium Discharges Appendix F - 1.5.1 IX.B. Worst Case Discharges Appendix F - 1.5.2 IX.B. - Discharge Detection Systems: Appendix F - 1.6 - Discharge Detection by Personnel Appendix F - 1.6.1 III.C., G. Automated Discharge Detection Appendix F - 1.6.2 III.G. - Plan Implementation: Appendix F - 1.7 - Response Resources for Small, Medium, and Worst Case Spills Appendix F - 1.7.1 IX.C. Disposal Plans Appendix F - 1.7.2 V.H. - Containment and Drainage Planning Appendix F - 1.7.3 I.B.6.,Table 11-2, III.A.,C. - Self Inspection, Drills/Exercises, and Response Training: Appendix F - 1.8 - Facility Self -Inspection Appendix F - 1.8.1 VI. - Facility Drills/Exercises Appendix F - 1.8.2 VIII.D. - Response Training Appendix F - 1.8.3 VII.A., B.,C., E. - Diagrams Appendix F - 1.9 ERAP G., I., Appendix H Security Appendix F - 1.10 III.H. - Response Plan Cover Sheet Appendix F - 2.0 Appendix B. Determination of Reportable Quantities for Hazardous Substances (40 CFR 117) Applicable under Section 311 to discharges greater than reportable quantities into navigable waters. - determination of reportable quantity 117.3 V.D.8. V-4 - general applicability 117.11 V.D.8. V-4 - exceptions for NPDES permitted discharges 117.12 V.D.8. V-4 - where to report a release 117.21 V.D.8. V-4 National Pollutant Discharge Elimination System (40 CFR 122-129) Permitted discharge of wastewaters to surface waters • Reporting of permit noncompliance which may endanger health or the environment 122.41(1)(6) V.D.7. V-4 RCT - 6 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. _ RPCC for APGI-TAPOCO/SANTEETLAH NC Regulatory Citation RPCC Outline RPCC Plan Topic Section # Page # oral report and written submission 122.41(I)(6)(i) V.D.7. V-4 - content of report 122.41(I)(6)(ii) V.D.7. V-4 122.41(m) V.D.7. V-4 bypass 122.41(n) V.D.7. V-4 upset Storm Water Pollution Prevention Plan NOT APPLICABLE Federal Multi -sector Permit— Affects permitted See specific permit discharges of storm water associated with industrial conditions and rules activity established by the State • Pollution prevention team VIII.A. VIII.B.1. • Site map • Inventory and description of exposed materials VIII.B.2 - • List of significant spills and leaks VIII.B.3. • Test for non -storm water discharges VIII.B.4. • Summary of storm water sampling data VI11.B.5. • Pollutant sources and risks VIII.B.6. V111. B. & C. • Best management practices W.C. • Implementation 122.44(i)(4)(i) VIII.D. • Annual site inspection VIII.C.6. • Record keeping and reporting • Review and revise plan I.E., LC.,D. VIILE., • Signature requirements I.G. • Plan availability • Discharges through municipal system VIILF.3. • Salt storage piles IILE.115.1. • Section 313 facilities V1II.F.1. General Pretreatment Regulations for Existing and New NA Sources of Pollution (40 CFR 403) NA Affects wastewater discharges to publicly owned treatment works • Prohibited discharges 403.5 V.D.11 • Notice of potential problems 403.12(f) V.D.11 • Notification of changed discharge 403.120) V.D.11 Toxic Organic or Solvent Management Plan NA Applies to wastewater discharges from the following NA industries: Electroplating point Source Category (40 CFR 413), Metal Finishing Point Source Category (40 CFR 433), and Electrical and Electronics Components Point Source Category (40 CFR 469) • Monitoring requirements 413.03, 433.12, 469.13 IIL1. certification in lieu of TTO monitoring 413.03(a), 433.12(a), III.I. 469.13(a), (c) RCT - 7 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Topic Regulatory Citation RPCC Outline TRPCC Section # Plan Page # - toxic organic or solvent management Plan 413.03(b), 433.12(b), 469.13(b)(d) III.I. COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT (40 CFR 302) Release of Hazardous Substances Above Reportable Quantities NA • Designation of hazardous substances 302.4 Appendix D • Determination of reportable quantities 302.5 Appendix D • Notification requirements 302.6 V.D.2. • Continuous releases 302.8 V.D.2 initial telephone notification 302.8(d) V.D.2 - initial written notification 302.8(e) V.D.2. - follow-up notification 302.8(f) V.D.2 - notification of changes in the release 302.8(g) V.D.2 - notification of statistically significant increase in release 302.8(h) V.D.2. - annual evaluation of releases 302.8(i) V.D.2 - use of SARA Title III section 313 form 302.80) V.D.2 documentation supporting notification 302.8(k) V.D.2 - multiple concurrent releases 302.8(I) V.D.2 HAZARDOUS MATERIALS TRANSPORTATION ACT (49CFR 130,171 -177) ; 2 Transportation of Hazardous Materials • Oil spill prevention and response 130.31 III.D. 111-4 • Notice of hazardous materials incidents 171.15 V.D.12. V-4 hazardous material incidents 171.15(a) V.D.12. V-4 telephone notice 171.15(b), 175.45 V.D.12. V-4 incident report 171.15(c) V.D.12. V-4 • Hazardous material incident reports 171.16 V.D.12. V-4 written report 171.16(a) V.D.12. V-4 report submittal and retention 171.16(b) V.D.12. V-4 • Incident Investigation 171.21 V.I. V-20 • Shipping Papers 172.200 III.D. III-4 emergency response telephone number 172.201(d) III.D. III-4 hazardous substances 172.203(c) III.D. III-4 • Emergency Response Information 172.600 III.D. III-4 - scope and applicability 172.600(a) and (b) III.D. III-4 - emergency response information 172.602 III.D. III-4 - emergency response telephone number 172.604 III.D. III-4 • Hazmat Training 172.700-704 VII.B.1. VII-1 • Accidents During Transit 177.854 III.D. III-4 • Loading/unloading 173.30 III.D. III-4 RCT - 8 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETL AH NC Topic Regulatory Citation RPCC Outline Section # RPCC Plan Page # - rail - highway; 174.55 - 174,81 III.D. III-4 174,67, 177.834-844 III.D. III-4 OCCUPATIONAL SAFETY AND HEALTH ACT (29 CFR 1910) Emergency' Action Plan (29 CFR 1910.38) & Employee Alarm Systems (29 CFR 1910.165) NOT APPLICABLE Employees will not perform emergency response NA • Scope and Applicability 1910.38 (a) Intro, ERAP. F., IV.D,IV.E. 1910.38(b) • Availability of plan • Procedures for reporting fire or other emergency 1910.38(c)(1) IV.F.6. ERAP.B. • Emergency evacuation procedures and route assignments 1910.38(c)(2) ERAP.G.Gppendix • Procedures for employees remaining 1910.38(c)(3) • Procedures to account for evacuated employees 1910.38(c)(4) IV.F.6. ERAP.G., Appendix G • Rescue and medical duties. 1910',38(c)(5)) • Names or titles of persons or departments for further 1910.38(c)(6) IV.F.6., VII.B.1. I.G.5. information 1910.38 (d) • Alarm System See 1910.165 requirements below • Employee Alarm Systems General Requirements 1910.165 (b) ERAP.G., IV.B. & F., Appendix G • Purpose of Alarm System 1910.165 (b)(1) 1910.165 b 4 • Preferred Means of Reporting Emergencies OO EMaintenance and Testing 1910.165 (d) 1910.38 (e) vacuation 1910.38 (f) IV.F. ERAP B, V.C. VI.A. & B. I NOT Chemical Process Safety Management Standard APPLICABLE (29 CFR 1910.119) Storage of highly hazardous chemicals above threshold auantities • Applicable Processes 1910.119(a)(i) - • Highly Hazardous Chemicals 1910.119 Appendix A • Employee Participation Plan of Action 1910.119(c) III.C.11. • Process Safety Information 1910.119(d) III.C.11. • Investigation of Previous Incidents 1910.119 (e)(3)(ii) I.F., III.C.11. • Process Hazard Analysis Requirements 1910.119(e)(3)(iii) III.C.11. • Written Operating Procedures 1910.119(f) III.C.11. RCT - 9 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, of the methods, processes, products, or or representation, expressed or procedures. implied, are made as to the accuracy, utility or effectiveness RPCC for APGI-TAPOCO/SANTEETLAH NC Topic Regulatory Citation RPCC Outline Section # RPCC Plan Page # • Training 1910.119(g) VII.B. • Contractors 1910.119(h) III.C.11. • Mechanical Integrity 1910.1 19(j)(1&2) III.A.& CA 1. • Inspection/testing of Process Equipment 1910.1190)(4) VI.B. • Equipment Repair 1910.1190)(5) VI.B. • Hot Work Permit 1910.119(k) IV.F.9. • Written Procedures to Manage Change 1910.119(1) III.C.11. • Incident Investigation 1910.119(m) V.I. • Emergency Planning and Response 1910.119(n) IV.F., V.G. • Compliance Audits 1910.119(o) I.E., Emergency Response Plan (29 CFR 1910.120) Employees will perform emergency response NOT APPLICABLE • Decontamination 1910.120 (k) V.G.3. • Emergency Response Program - For Uncontrolled Hazardous Waste Sites 1910.120 (1) - • Emergency Response Plan 1910.120 (1)(1) - Development of Emergency Response Plan 1910.120 (1)(1)(i) V.G. - Exemption from Preparing an Emergency Response Plan 1910.120 (1)(1)(ii) ERAP G., IVY. • Elements of an Emergency Response Plan: 1910.120 (1)(2) - - Pre -emergency Planning and Coordination with Outside Parties 1910.120 (1)(2)(i) ERAP B., C., IVY. - Personnel Roles, Lines of Authority, Communication 1910.120 (1)(2)(ii) ERAP B, C, D, F, IV.F. - Emergency Recognition and Prevention 1910.120 (1)(2)(iii) ERAP B, V.A., VII.A. - Safe Distances and Places of Refuge 1910.120 (1)(2)(iv) V.G.1. - Site Security and Control 1910.120 (1)(2)(v) V.G.3. - Evacuation Routes and Procedures 1910.120 (1)(2)(vi) IV.F.6. - Decontamination Procedures 1910.120 (1)(2)(vii) V.G.3., V.H. - Emergency Medical Treatment and Response Procedures 1910.120 (1)(2)(viii) I.G.2. - Emergency Alerting and Response Procedures 1910.120 (1)(2)(ix) IV.F.1, V.G. - Critique of Response and Follow-up 1910.120 (1)(2)(x) V.1. - PPE and Emergency Equipment 1910.120 (1)(2)(A) ERAP E, I.G.3. • Procedures for Handling Emergency Incidents: 1910.120 (1)(3) - Additional Plan Elements: Site Topography, layout, etc 1910.120 (1)(3)(i)(A) V.F. - Additional Plan Elements: Incident Reporting Procedures 1910.120 (1)(3)(i)(B) V.D. - Separate Section of Site Safety & Health Plan 1910.120 (1)(3)(ii) V.G.6. - Compatibility with Other Emergency Response Plans 1910.120 (1)(3)(iii) I.C., V.A. - Regular Plan Rehearsals as Part of Site Training Programs 1910.120 (1)(3)(iv) VII.B. - Periodic Plan Review and Amended as Necessary to Keep it Current 1910.120 (1)(3)(v) I.E., - Install Employee Alarm System in accordance with 29 CFR 1910.165 1910.120 (1)(3)(vi) ERAP G, IV.B., F., Appendix G RCT - 10 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCOISANTEETLAH NC Topic - Evaluate Incident and Implement Site Emergency Response Plan • Emergency Response Program - For Operations at TSDFs • Emergency Response Plan • Elements of an Emergency Response Plan - Pre -emergency Planning and Coordination with Outside Parties - Personnel Roles, Lines of Authority, Communication - Emergency Recognition and Prevention Safe Distances and Places of Refuge - Site Security and Control - Evacuation Routes and Procedures - Decontamination Procedures - Emergency Medical Treatment and Response Procedures - Emergency Alerting and Response Procedures - Critique of Response and Follow-up - PPE and Emergency Equipment • Training • Procedures for Handling,' Emergency Incidents Additional Elements of, Emergency Response Plans Additional Plan Elements: Site Topography, layout, etc. - Additional Plan Elements: Incident Reporting Procedures Compatibility with Other Emergency Response Plans Regular Plan Rehearsals as Part of Site Training Programs Periodic Plan Review and Amended as Necessary to Keep It Current - Install Employee Alarm System in accordance with 29 CFR 1910.165 - Evaluate Incident and Implement Site Emergency Response Plan EResponse to Hazardous Substance f Plan an Emergency Response Plan: - Pre -emergency planning and coordination with outside parties - Personnel roles, Fines of authority, training, and communication Emergency recognition and prevention Safe distances and places of refuge Site security and control - Evacuation routes and procedures - Decontamination Procedures Regulatory Citation 1910.120 (1)(3)(vii) 1910.120(p)(8) 1910.120(p)(8)(I) 1910.120(p)(8)(ii) 1910.120(p)(8)(ii)(A) 1910.120(p)(8)(ii)(B) 1910.120(p)(8)(ii)(C) 1910.120(p)(8)(ii)(D) 1910.120(p)(8)(ii)(E) 1910.120(p)(8)(ii)(F) 1910.120(p)(8)(ii)(G) 1910.120(p)(8)(ii)(H) 1910.120(p)(8)(ii)(1) 1910.120(p)(8)(ii)(J) 1910.120(p)(8)(ii)(K) 1910.120(p)(8)(iii) 1910.120(p)(8)(iv) 1910.120(p)(8)(Iv)(A) 1910.120(p)(8)(iv)(A)(1) 1910.120(p)(8)(iv)(A)(2) 1910'.120(p)(8)(iv)(B) 1910.120(p)(8)(iv)(C) 1910.120(p) (8) (iv)(D) 1910.120 (p) (8) (iv) (E) 1910.120(p) (8)(iv)(F) 1910.120(q): 1910.120(q)(1) 1910.120(q)(2) 1910.120(q)(2)(I) 1910.120(q)(2)(II) 1910.120(q)(2)(iii) 1910.120(q)(2)(fv) 1910.120(q)(2)(v) 1910.120(q)(2)(vf) 1910.120(q)(2)(vii) RPCC Outline Section # ERAP B, IV.A. V.G. ERAP B, C, G, IV.F., Appendix G ERAP B, C, D, F, IVY. ERAP B, V.A., VII.A. V.G.1. V.G.3. IV.F.6. V.G.3., V.H. V.G.2. IV.F.1.,V.G. V.I. RAP E, IV.G. VII.B. V.F. V.D. I.C., V.A. VII.B. I.E., 1AP G, IV.B., F., Appendix G ERAP B, W.A. RPCC Plan Page # V.G. ERAP B.,C.,G., IV.F.4., Appendix G ERAP B., C., D., F., IV.F. ERAP B, V.A., VII.A. V.G.1. V.G.3. IV.F.6. V.H., V.G.3. RCT - 11 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or, effectiveness of the methods, processes, products, or procedures. RPCC for APGi-TAPOCO/SANTEETLAH NC Topic Regulatory Citation RPCC Outline I Section # RPCC Plan Page # Emergency medical treatment and first aid 1910.120(q)(2)(viii) V.G.2 Emergency alerting and response procedures 1910.120(q)(2)(ix) IV.F.1.,V.G. Critique of response and follow-up 1910.120(q)(2)(x) V.I. PPE and emergency equipment 1910.120(q)(2)(xi) ERAP E., IV.G. Emergency Response Plan Coordination and Integration 1910.120(q)(2)(xii) V.G.3. • Procedures for Handling Emergency Response 1910.120(q)(3) Site -specific incident command system 1910.120(q)(3)(i) IV.B. - Identification of hazardous substances or conditions 1910.120(q)(3)(ii) IV.B. Implementation of emergency operations 1910.120(q)(3)(iii) V.G. - Use of self-contained breathing apparatus 1910.120(q)(3)(iv) V.G.3. Limit personnel at site and use buddy system 1910.120(q)(3)(v) V.G.3. - Back-up personnel and standby medical 1910.120(q)(3)(vi) V.G.2. - Designation of safety officer 1910.120(q)(3)(vii) V.G.4. - IDLH conditions or imminent danger 1910.120(q)(3)(viii) V.G.4. - Implementation of decontamination procedures 1910.120(q)(3)(ix) V.G.3. - Use of approved self-contained breathing apparatus 1910.120(q)(3)(x) V.G.3. • Skilled support personnel 1910.120(q)(4) V.G.5. • Specialist employees 1910.120(q)(5) IV.D.,VII.A., B.1. • Training 1910.120(q)(6) VII.A. - first responder awareness 1910.120(q)(6)(i) VII.B. - first responder operations 1910.120(q)(6)(ii) VII.B. - hazardous materials technician 1910.120(q)(6)(iii) VII.B.. - hazardous materials specialist 1910.120(q)(6)(iv) VII.B. - on -scene incident commander 1910.120(q)(6)(v) VII.B. • Trainers 1910.120(q)(7) VII.A.,B.2 • Refresher training 1910.120(q)(8) VII.A.,B.2. • Medical Surveillance and Consultation 1910.120(q)(9) V.G.7. • Chemical Protective Clothing 1910.120(q)(10) V.G.3. • Post -emergency Response Operations 1910.120(q)(11) V.G.3. RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION (RSPA) PIPELINE RESPONSE PLAN (49 CFR 194) Operators of onshore oil pipelines that may cause significant and/or substantial harm to environment by discharging to navigable waters NOT APPLICABLE • Operators required to submit plans 194.101 I.B.3., Section IX Introduction • Significant and substantial harm: operator's statement 194.103 i.A., G. • Worst case discharge 194.105 IX.B., Appendix J • General Response Plan Requirements 194.107 - - Resource planning requirements 194.107(a) IX.C. - Language requirements 194.107(b) I.G. - Consistency with NCP and ACP(s) 194.107(c) I.C. - Each response plan must include: 194.107(d) - - Core plan elements: 194.107(d)(1) - - Information summary as required in 194.113 194.107(d)(1)(i), 194.1131 ERAP A, B, C, D - Immediate notification procedures 194.107(d)(1)(ii) JERAP B, C, D, V.D. RCT - 12 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Topic - Spill detection and mitigation procedures Oil spill response organization - Response activities and resources - ',Agencies to have responsibilities or support - Training procedures - Equipment testing - Drill types, schedules, procedures - Plan review and update - An appendix for each response zone • Submission of state response plans • Response plan retention • Core plan information summary - Name and address of Operator - Description of each response zone • Response zone appendix information summary Core plan information summary Name and telephone number of qualified individual Description of response zone List of line sections for each pipeline Basis for determination of significant and substantial harm - Type of oil and volume of WCD • Response resources • Personnel training •Submission and approval procedures • Response plan review and update procedures • Recommended guidelines for the preparation of response tans - Information summary Notification procedures - Spill detection/mitigation procedures Response activities - List of contacts - Training procedures - Drill procedures - Response plan review/ update procedures - Response zone appendices RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) Small Quantity Generator (40 CFR 262 and 265) Generates between 100 kg and 1,000 kg of hazardous waste per calendar month Emergency Coordinator Regulatory Citation 194.107(d)(1)(iii) 194.107(d)(1)(iv) 194.107(d)(1)(v) 194.107(d)(1)(vi) 194.107(d)(1)(vii) 194.107(d)(1)(viii) 194.107(d)(1)(ix) 194.107(d)(1)(x), 194.121 194.107(d)(2) 194.109 194.111 194.113(a) 194.113 (a)(1) 194.113 (a)(2) 194.113(b) 194.113(b)(1) 194.113(b)(2) 194.113(b)(3) 194.113(b)(4) 194.113(b)(5) 194.113(b)(6) 194.115 194.117 194.119 194A 21 Appendix A Section 1 Section 2 Section 3 Section 4 Section 5 Section 6 Section 7 Section 8 Section 9 RPCC Outline Section # V.F. IV.D., E. ERAP F, H, IV.B., D., E. ERAP C., F. VILD. ERAP E, MG., VI.B. VILD. 1. E., Appendix J I.G. I.G. I.A. I.A.S. Appendix J Appendix J I.A. ERAP A, IV.B I.A.5.,Appendix J Appendix J Appendix J Appendix J IX.C. V'II. A., B. I.G. I.E:,, I.G. ERAP A., B, C, D ERAP B., C., D., V.D. V.F. ERAP B, IV.B., IV.G., V.C. ERAP B, C, IV.E. VILD. VILD. 1. E., Appendix J RPCC Plan Page # 262.34(d)(5)(i) ERAP A., IV.B. I ERAP 1 —1 IV- RCT - 13 Ivoverrwer cvv'+ This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes,products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Topic Regulatory Citation RPCC Outline Section # RPCC Plan Page # • Information Posting 262.34(d)(5)(ii) ERAP C., V.B. ERAP-3 V-2 • Employee Training 262.34(d)(5)(iii) VII.A.,B. VII-1 • Response Procedures 262.34(d)(5)(iv) V.A. V-1 - fire response 262.34(d)(5)(iv)(A) ERAP B, V.C.,F. ERAP-2 V- 2,16 - spill response 262.34(d)(5)(iv)(B) ERAP B, V.C.,F. ERAP-2 V- 2,16 - release reporting 262.34(d)(5)(iv)(C) V.D.4. V-4 • Maintenance and Operation of Facility 265.31 III.C.,D. III-2,4 • Required Equipment 265.32 IV.F.,G. IV-3,7 internal communications or alarm system 265.32(a) IV.F.1. IV-3 device for summoning assistance 265.32(b) IV.F.2. IV-3 - response equipment 265.32(c) ERAP E., W.G. ERAP-5 IV-7 - water supply 265.32(d) ERAP E., IV.G. ERAP-5 IV-7 • Testing and Maintenance of Equipment 265.33 VI.B.7. VI-4 • Access to Communications or Alarm System 265.34 IV.F.1.,2. IV-3 • Required Aisle Space 265.35 IV.F.3. IV-3 • Arrangements with Local Authorities 265.37 - - arrangements to familiarize authorities 265.37(a)(1) LE ... W.F.4. 1-10 IV-3 - designation of primary emergency authority 265.37(a)(2) IV.F.4. IV-3 - agreements with response services 265.37(a)(3) IV.F.4. IV-3 - arrangements to familiarize local hospitals 265.37(a)(4) I.E.,,IV.F. 1-10 IV-3 - documentation of refusal 265.37(b) IV.F.4. IV-3 <90-Day Generator (40 CFR 265) Generates more than 1,000 kg of hazardous waste per calendar month and accumulates for less than 90 da s • Employee Training 265.16 VILA emergency procedures, equipment, systems 265.16(a)(3) VII.B.1. emergency equipment management 265.16(a)(3)(i) VII.B.1. . automatic waste cut-off systems 265.16(a)(3)(ii) VII.B.1. communications and alarm systems 265.16(a)(3)(iii) VII.B.1. fire/explosion response 265.16(a)(3)(iv) VII.B.1. ground water contamination incidents 265.16(a)(3)(v) VII.B.1. shutdown of operations 265.16(a)(3)(vi) VILBA. training records 265.16(e) VILE., • Maintenance and Operation of Facility 265.31 III.C.,D. • Required Equipment 265.32 ERAP E., IV.G. internal communications or alarm system 265.32(a) IV.F.1. device for summoning assistance 265.32(b) IV.F.2. response equipment 265.32(c) ERAP E., N.G. - water supply 265.32(d) ERAP E., IV.G. • Testing and Maintenance of Equipment 265.33 VI.B. • Access to Communications or Alarm System 265.34 ►V.F.1.,2. • Required Aisle Space 265.35 IV.F.3. • Arrangements with Local Authorities 265.37 - - arrangements to familiarize authorities 265.37(a)(1) I.E.,,IV.F.4. RCT - 14 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC designation of primary emergency authority agreements with response services arrangements to familiarize local hospitals documentation of refusal • Purpose of Contingency Plan • Implementation of Contingency Plan • Contents of Contingency Plan - Actions to be taken to comply - SPCC Plan or other Plan - Coordination with State and local response parties - Names, addresses, phone numbers of emergency coordinator(s) - Detailed description of emergency equipment on -site - Evacuation Plan, if applicable • Copies of Contingency Plan - at facility - submitted to authorities • Amendment of Contingency Plan • Emergency Coordinator • Emergency Procedures Imminent or Actual activate alarm or communication system notify agencies with designated roles identify character, source, amount, and extent of release assess possible hazards to health or environment notify local authorities of possible need to evacuate report release to NRC or on -scene -coordinator measures to ensure that emergency does not occur, recur, or spread (containment) monitoring for hazardous conditions if operations stop treatment, storage, and disposal of wastes generated from emergency situation no incompatible waste managed until cleanup completed emergency equipment cleaned and fit for use before operations are resumed notification of authorities before resuming operations written report of incident within 15 days • Air Emission Standards' Regulatory Citation RPCC Outline Section # RPCC Plan Page # 265.37(a)(2) IV.F.4. 265.37(a)(3) IV.F.4. 265.37(a)(4) I.E.,IV.F.4. 265.37(b) IV.F.4. 265.51(a) IV.A. 265.51(b) W.A. 265.52 - 265.52(a) V.F. 265.52(b) I.C. 265.52(c) IV.F.4. 265.52(d) ERAP A., C., IV.B. 265.52(e) 265.52(f) 265.53 265.53(a) 265.53(b) 265.54 265.55 265.56 265.56(a)(1) 265.56(a)(2) 265.56(b) 265.56(c) 265.56(d)(1) 265.56(d)(2) 265.56(e) 265.56(f) 265.56(g) 265.56(h)(1) 265. 265.56(i) 265.560) 265 Subparts AA, BB, CC ERAP E., IV.G. ERAP G., IV.F.6., Appendix G LG.1. I.G.2. I.E., ERAP A., C., IV.B. W.B. IV.B. FIV.B. IV.B. IV.B. 1VV.B.,V.D.4. IV.B. IV.B. IV.B. W.B. IV.B. V.D.4. V.D.4. III.A., III.C., III.D. Treatment, Storage and Disposal Facility (40 CFR 265) NA Maintains interim status to treat, store, or dispose of NA hazardous waste. Permitted facilities are subject to similar requirements of 40 CFR 264 plus the terms and conditions of their permit. • Content of Contingency Plan 264.52 - - Emergency response actions 264.52(a) ERAP B., C, IV.B. RCT - 15 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Topic Regulatory Citation RPCC Outline Section # RPCC Plan Page # Amendments to SPCC Plan 264.52(b) Introduction Coordination with State and local response parties 264.52(c) IV.E., F.4. Names, addresses, phone numbers of emergency coordinator(s) 264.52(d) ERAP A., IV.B. Detailed description of emergency equipment on -site 264.52(e) ERAP E., IV.G. Evacuation Plan, if applicable 264.52(f) ERAP G., IV.F.6., Appendix G • Copies of Contingency Plan 264.53 - - at facility 264.53(a) LG.1. - submitted to authorities 264.53(b) I.G.2 • Amendment of Contingency Plan 264.54 - • Emergency Coordinator 264.55 ERAP A., C., IV.B. • Emergency Procedures - Imminent or Actual 264.56 - - activate facility alarm or communication system 264.56(a)(1) IV.B. - notify agencies with designated roles 264.56(a)(2) IV.B. - identify character, source, amount, and extent of release 264.56(b) IV.B. - assess possible hazards to health or environment 264.56(c) IV.B. - notify local authorities of possible need to evacuate 264.56(d)(1) IV.B. - report release to NRC or on -scene -coordinator 264.56(d)(2) IV.B., V.D.4. - measures to ensure that emergency does not occur, recur, or spread (containment) 264.56(e) IV.B. - monitoring for hazards conditions if operations stop 264.56(f) W.B. - treatment, storage, and disposal of wastes generated from emergency situation 264.56(g) IV.B. - no incompatible waste managed until cleanup completed 264.56(h)(1) IV.B. emergency equipment cleaned and fit for use before operations are resumed 264.56(h)(2) W.B. notification of authorities before resuming operations 264.56(I) V.D.4. - written report of incident within 15 days 264.560) V.D.4. • Employee Training 265.16 VII.A. emergency procedures, equipment, and systems 265.16(a)(3) VII.B.1. emergency equipment management 265.16(a)(3)(1) VII.B.1. - automatic waste cut-off systems 265.16(a)(3)(ii) VILBA. - communications and alarm systems 265.16(a)(3)(iii) VII.B.1. fire/explosion response 265.16(a)(3)(iv) VII.B.1. - ground water contamination incidents 265.16(a)(3)(v) VII.B.1. shutdown of operations 265.16(a)(3)(vi) VII.B.1. training records 265.16(e) VILE. • Maintenance and Operation of Facility 265.31 111.C., D. • Required Equipment 265.32 ERAP E., IV.G. - internal communications or alarm system 265.32(a) IV.F.1. - device for summoning assistance 265.32(b) IV.F.2 - response equipment 265.32(c) ERAP E., IV.G. - water supply 265.32(d) ERAP E., IV.G. • Testing and Maintenance of Equipment 265.33 VI.B. • Access to Communications or Alarm System 265.34 IV.F.1.,2. • Required Aisle Space 265.35 IV.F.3. • Arrangements with Local Authorities 265.37 RCT - 16 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Topic 71 arrangementsto familiarize authorities - designation of primary emergency authority - agreements with response services arrangements to familiarize local hospitals - documentation of refusal • Purpose of Contingency Plan • Implementation of Contingency Plan • Contents of Contingency Plan - actions to be taken to comply - SPCC Plan or other Plan - arrangements agreed to by authorities - names, addresses, phone numbers of emergency coordinator(s) - up to date list of all emergency equipment, including location, description, capabilities - evacuation Plan, including signals and routes Kf Contingency Plan litytted to authorities ent of Contingency Plan cy Coordinator cy Procedures - Imminent or Actual te alarm or communication system agencies with designated roles identify character, source, amount assess possible hazards evacuation of local areas release reporting measures to ensure that emergency does not occur recur or spread management of materials from emergency no incompatible waste managed emergency equipment cleaned and fit notification of authorities written report of incident • Air Emission Standards Used Oil Processors and Re -Refiners (40 CFR 279.52) Locations that chemically or physically process used oil for reuse as fuel, lubricants, or other products Regulatory Citation RPCC Outline I Section # RPCC Plan Page # 265.37(a)(1) I.E.,,IV.F.4. 265.37(a)(2) IV.F.4. 265.37(a)(3) IV.F.4. 265.37(a)(4) I.E., IV.F.4. 265.37(b) IV. F. 265.51(a) IV.A. 265.51(b) IV.A. 265.52 ' 265.52(a) V. F. 265.52(b) I.C. 265.52 (c) IV.F.4. 265.52(d) ERAP A.,C., W.B. 265.52(e) ERAP E., IV.G. 265.52(f) ERAP G.,1V.F.6., Appendix G 265.53 ' 265.53(a) I.G.1. 265.53(b) f.G.2. 265.54 I.E., 265.55 ERAP A., C., IV.B. 265.56 IV.B. 265.56(a)(1)MVB. 265.56(a)(2)265.56(b)265.56(c)265.56(d)(1)265.56(d) (2) 265.56(e) IV.B. 265.56 (g) IV.B. 265.56(h)(1) IV.B. 265.56(h)(2) IV.B. 265.56(i) V.D.4. 265.560) V.D.4. 265 Subparts AA, BB, CC III.A., III.C., III.D. NA NA • Content of Contingency Plan: 279.52(b)(2) Emergency response actions 279.52(b)(2)(i) I.E.,, IV.E.,F., III.C., V.F. Amendments to SPCC Plan 279.52(b)(2)(ii) I.E., Coordination with State and local response parties 279.52(b)(2)(iii) IV.F.4. RCT - 17 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, p procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Topic Regulatory Citation RPCC Outline Section # RPCC Plan Page # - Names, addresses, phone numbers of emergency coordinator(s) 279.52(b)(2)(iv) ERAP A., C., IV.B. Detailed description of emergency equipment on -site 279.52(b)(2)(v) ERAP E., IV.G. - Evacuation Plan, if applicable 279.52(b)(2)(vi) 'ERAP G., IV.F.6., Appendix G • Copies of Contingency Plan 279.52(b)(3) - - at facility 279.52(b)(3)(i) I.G.1. - submitted to authorities 279.52(b)(3)(ii) I.G.2. • Amendment of Contingency Plan 279.52(b)(4) I.E., • Emergency Coordinator 279.52(b)(5) ERAP A., C., IV.B. • Emergency Procedures - Imminent or Actual 279.52(b)(6) - - activate facility alarm or communication system 279.52(b)(6)(i)(A) IV.B. - notify agencies with designated roles 279.52(b)(6)(i)(B) IV.B. identify character, source, amount, and extent of release 279.52(b)(6)(ii) IV.B. - assess possible hazards to health or environment 279.52(b)(6)(iii) IV.B. - notify local authorities of possible need to evacuate 279.52(b)(6)(iv)(A) W.B. - report release to NRC or on -scene -coordinator 279.52(b)(6)(iv)(B) IV.B. - measures to ensure that emergency does not occur, recur, or spread (containment) 279.52(b)(6)(v) IV.B. - monitoring for hazards conditions if operations stop 279.52(b)(6)(vi) IV.B. - treatment, storage, and disposal of wastes generated from emergency situation 279.52(b)(6)(vii) IV.B. - no incompatible waste managed until cleanup completed 279.52(b)(6)(viii)(A) W.B. - emergency equipment cleaned and fit for use before operations are resumed 279.52(b)(6)(viii)(B) W.B. notification of authorities before resuming operations 279.52(b)(6)(viii)(C) V.D.4. written report of incident within 15 days 279.52(b)(6)(ix) V.D.4. Underground Storage Tanks (40 CFR 280) NA Storage of regulated substances in underground storage tanks > 110 gallon capacity NA • Release prevention 280.11(a)(1) III.A. • Performance standards 280.20 III.A. - spill and overfill prevention equipment 280.20(c) III.G. • Notification - release detection certification 280.22(e)(4) III.G. • Spill and overfill control 280.30 - ensure that spilling or overfilling do not occur 280.30(a) III.D. report, investigate, and cleanup 280.30(b) V.D.10. • Operation and maintenance of corrosion protection 280.31 VI.B. • Compatibility 280.32 III.A. • Repairs 280.33 III.C.10. • Reporting and record keeping 280.34 V.D.10. - release reports 280.34(a)(2) V.D.10. • Release Detection 280.40-45 III.G.,VI.B. - release detection record keeping 280.45 1 VI.B.,D. RCT - 18 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APG!-TAPOCO/SANTEETLAH NC • Suspectedrelease report • Release investigation and confirmation • Spill and overfill report • Confirmed' release response • Initial' abatement measures • Initial site characterization • Free product removal • Soil and groundwater cleanup • Corrective action plan Regulatory Citation 280.50 280.52 280.53 280.61 280.62 280.63 280.64 280.65 280.66 RPCC Outline I RPCC Plan Section # Page # V. D.10. V.D.10. V.D.10. V.D.10. V.D.10. V.D.10. V. D.10. V.D.10. V.D.10. Topic Regulatory Citation I RPCC Outline I RPCC Plan Section # Page # Emergency planning requirements apply when there is present an amount of any extremely hazardous substance equal to or greater than its threshold planning quantity,(TPO). Note that the TPQ applies to the total amount of that substance present at any one time on site, regardless of the number of containers or locations. For computing the TPQ of solids or mixtures, refer to 40 CFR 355.30(e) Emergency planning emergency planning notification facility emergency coordinator - provision of information calculation of TPQs— • Emergency release notification Section 8(e) Notification of Substantial Risk Polychlorinated Biphenyls -Management of PCB's and spills of PCB's • Registration of PCB transformer with fire department • Storage of combustible materials • Visual inspection of PCB transformer and records • PCB transformer leaks • Fire -related incident response • Disposal of spilled PCBs • Storage for disposal 355.30 355.30(b) 355.30(c) 355.30(d) 355.30(e) 355.40 None 761.30(a)(1)(vi) 761.30(a)(1)(viii) 761.30(a)(1)(ix), (xii), (xiii), (xiv) 761.30(a)(1)(x) 761.30(a)(1)(xi) 761.60(d) 761.65 I.G. ERAP A., C., IV.B. I.G. V.D.3. V.D.3. IV.F.5. III.C.9. VI.B. V.F. V.D.9. V.H. III.A. NOT APPLICABL E NA RCT - 19 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. Nowarranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. .K+T TS#H+�$Wkd�F`KY'.'�•v .rcN°d5":�'Ns. � y RPCC for APGI-TAPOCO/SANTEETLAH NC Topic Regulatory Citation RPCC Outline Section # RPCC Plan Page # storage facility 761.65(b)(1) III.A. exemption for SPCC Plan 761.65(c)(1)(iv) N/A - inspection for leaks 761.65(c)(5) VI.B. - containers 761.65(c)(6) and (7) III.A. • PCB Spill Cleanup Policy 761.125 V. H. - reporting requirements 761.125(a)(1) V.D.9. - cleanup debris disposal 761.125(a)(2) V. H. - spill boundaries 761.125(a)(3) V. H. - spill cleanup of less than one pound 761.125(b) V. H. - spill cleanup of one pound or more 761.125(c) V. H. • Post cleanup sampling 761.130 V. H. • Records and reports 761.180-193 & 202-218 V. H. US COAST.GUARQ FACILITY RESPONSE PLAN (33 CFR 154j Marine Transportation -related Facilities (MTR) that transfer oil or hazardous material in bulk to or from a vessel NA • Qualified individual and alternate 154.1026 ERAP A • Availability of response resources 154.1028 ERAP F, IV.D., IV.E. • Worst case discharge 154.1029 IX.B • General Response Plan Contents: 154.1030 - - The plan must be written in English 154.1030(a) I.G. - Organization of the plan 154.1030(b) TOC - Required contents 154.1030(c) ERAP, I, IV, V, VII, Appendix H, J - Sections submitted to Captain of the Port (COTP) 154.1 b30(d) ERAP, I, IV, V, VII, Appendix H, J - Cross references 154.1030(e) RCT - Consistency with National Contingency Plan (NCP) and Area Contingency Plan (ACP)(s) 154.1030(f) I.C. • Significant and substantial harm facilities 154.1035 - - Facility name, address, telephone 154.1035(a)(1) I.A. - Facility location 154.1035(a)(2) I.A. - Procedures to contact owner/operator 154.1035(a)(3) ERAP A - Table of contents 154.1035(a)(4) TOC - Cross index if appropriate 154.1035(a)(5) RCT - Record of changes 154.1035(a)(6) I.E., • Emergency response action plan 154.1035(b) - Notification procedures 154.1035(b)(1) ERAP B, C, D, V.D. - Contact list 154.1035(b)(1)(i) ERAP B, C - Information to be provided 154.1035(b)(1)(ii) Appendix B - Spill mitigation procedures 154.1035(b)(2) - - Volumes of oil 154.1035(b)(2)(i) IX.B., Appendix J RCT - 20 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Topic Regulatory Citation RPCC Outline RPCC Plan Section # Page # - Prioritized procedures 154.1035(b)(2)(ii) V.F. - List of equipment 154A035(b)(2)(iii) ERAP E, IV.G. - Facility personnel responsibilities b 2 154.1035 O( )(iii ) ERAP F, IV.D., ME. - Facility response activities 154.1035(b)(3) - Facility personnel responsibilities 154.1035(b)(3)(i) ERAP F, W.D., IV.E. - Qualified individual responsibilities 154.1035(b)(3)(ii) W.B. - Facility organization 154.1035(b)(3)(iii) IV.B. - Contract oil spill response organizations 154.1035(b)(3)(iv) ERAP F, W.E. - Response organization for mobile facilities 154.1035(b)(3)(v) Appendix J - Fish and wildlife sensitive environments 154.1035(b)(4) -- - Areas potentially impacted by WCD 154.1035(b)(4)(i) IX.A., Appendix J - List areas and responseactions 154.1035(b)(4)(ii) IX.A., Appendix - Maps and charts of areas potentially impacted 154.1035(b)(4)(ii) IX.A., Appendix J - Equipment and personnel to protect identified areas 154.1035(b)(4)(iii) ERAP E, F, W.E., IV.G. - Disposal plans 154.1035(b)(5) V.H. • Training and exercises 154.1035(c), 154.1050, VILD. 154.1055 • Plan review and update procedures 154.1035(d), 154.1065 I.E., • Appendices 154.1035(e) - Facility specific information 154.1035(e)(1) -- - Site plan, vessels, and piping 154.1035(e)(1)(i), (ii), (iii) ERAP I, Appendix H - Oil MSDS 154.1035(e)(1)(iv) Appendix E List of contacts 154.1035(e)(2) ERAP A, B, C Equipment lists and records 154.1035(e)(3) IV.D., W.G. Communication plan 154.1035(e)(4) V.A., B., C. - Site specific safety and health plan 154.1035(e)(5) Appendix K Acronyms and definitions 154.1035(e)(6) Appendix I Geographic specific index 154.1035(e)(7) Appendix J • Specific requirements for substantial harm facilities 154.1040 W.E., IV.G. • Mobile MTR facilities 154.1041 I.G. • Groups I -IV petroleum oils 154.1045 IX.C. • Group V petroleum oil 154.1047 IX.C. • Inspection and maintenance of response resources 154.1057 VI.B., C. D. • Submission and approval procedures 154.1060 I.G. • Plan revision and amendment procedures 154.1065 I.E.,, I.G. • Deficiencies 154.1070 LE., • Appeal process 154.1075 I•E•, • Response resource guidelines Appendix C Appendix J RCT - 21 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC RCT - 22 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. ALCOA POWER GENERATING INC. TAPOCO DIVISION THE SANTEETLAH POWER FACILITY EMERGENCY RESPONSE ACTION PLAN NOVEMBER 2004 ERAP COVER November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC EMERGENCY RESPONSE ACTION PLAN A. Emergency Response Coordinator* Information: The Emergency Response Coordinators shall be contacted in descending order. The first Emergency Response Coordinator contacted will be responsible for notifying the other Coordinators if deemed necessary. *NOTE: This location's Emergency Response Coordinators (ERC) are intended to serve in the role of "qualified individuals (EPA, USCG, and DOT), "emergency coordinators" (RCRA), and "incident commanders" (OSHA) as defined by the appropriate regulatory programs. See Section W.B. for a detailed list of Emergency Response Coordinator duties. Primary Emergency Response Coordinator Name: E. Ray Barham Title: Technical Manager, APGI-Tapoco Address: 206 Camelia Trace Maryville, TN 37801 Plant Phone: 865-977-2218 Plant Emergency Phone: 865-977-3322 Pager Number: nla Cell Phone Number: 865-617-0587 Home Phone: 865-379-8633 Time from Home to Facility 60 minutes Training Experience: M.S. Haz.Waste Mngt.;Certified Safety Prof.;40 hr HAZWOPER; 17 years OJT. Alternate Emergency Response Coordinators (listed in order in which they are to be called) Name: Timothy Poole Title: Maintenance Coordinator Address: 4753 Mint Road Marvville, TN Plant Phone: Plant Emergency Phone: Pager Number: Cell Phone Number: Home Emergency Phone: Time from Home to Facility Training Experience: 865-977-2342 865-977-2342 865-996-2262 865-599-4721 865-984-1282 60 minutes Confined Space — 4 hours, Confined Space Emergency Response — 8 hours, DOT HM 181 8 hours, OJT — 24 years (Continued on ERAP-2) ERAP-1 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Name: II Title: Address: Plant Emergency Phone: Pager Number. Cell Phone Number: Home Emergency Phone: Time from Home to Facility Training Experience: Name: Title: Address: Plant Emergency Phone: Pager Number: Cell Phone Number. Home Emergency Phone: Time from Home to Facility Training Experience: Walter Brockway Power Manager, APGI-TapocoiYadkin 865-977-3324 n/a 865-621-5677 865-671-2530 120 minutes OJT —18 years Stephanie Sparkman, P.E. Alcoa's Environmental Supervisor 12528 Early Road Knoxville, TN 37922 865-977-3671 865-564-0749 865-803-4999 865-671-1047 90 minutes 40 hours OSHA: 15 years OJT B. Discovery and Alert Procedures: If a minor leak, spill, release or fire occurs, the individual discovering the incident should attempt to locate and eliminate the source. If possible, he should try to stop or at least contain the release. This can involve closing valves, turning drums upright, activating emergency pumps, using adsorbent materials, or extinguishing the fire. Caution is advised here as these measures should only be undertaken if they can be accomplished without any risk both to the individual, as well as other employees in the vicinity. The discoverer should respond to the situation based on his/her knowledge, and the level of training as well as an assessment of the situation that the initial response will not make the situation worse. If the source is not immediately obvious or if these measures are not effective and the situation is beyond his control, then the discoverer should initiate the following emergency procedures: 1. The discoverer of a spill should first contact Alcoa, Inc. — Tennessee Operations APGI-TapocoNadkin Dispatcher at 865-977-3322 who has been designated as the "emergency dispatcher." The emergency dispatcher will make sure that an Emergency Response Coordinator is contacted. 2. Pass along the following information: a. Exact location of the emergency event b. Type and description of the emergency c. Estimate of the amount of material released, or the size of the fire d. Extent of injury or property damage incurred e. Extent of the actual and potential environmental damage f. Remedial action taken, if any ERAP-2 November 2004 pressed or This information is the property of Alcoa. It is not to be used,. reproduced, or copied without express permission. No warranties, guarantees, or representation, ex implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC 3. In the event of a release, notifications to appropriate Outside Agencies should be made in the order shown on the following Emergency Notification List. NOTIFICATION TO ANY OUTSIDE AGENCY IS TO BE MADE ONLY BY ALCOA TN OPERATIONS ENVIRONMENTAL STAFF C. Emergency Notification Phone List: Organization/Individual Phone Number EmergencyDispatcher.- APGI Tapoco/Yadkin System Dispatcher 865-977-3322 Primary Emergency Coordinator (Qualified Individual) E.Ray Barham, Technical Manager, APGI-Tapoco Work No. 865-977-2218 Pager No, n/a Cell No. 865-617-0587 Home No. 865-379-8633 Alternate Emergency Coordinator(s) Timothy Poole, Maintenance Coordinator Work No. 865-977-2342 Pager No. 865-966-2262 Cell Phone No.865-599-4721 Home No 865-984-1282 Walt Brockway, Power Manager, APGI- Work No. 865-977-3324 Tapoco/ Yadkin Pager No. n/a Cell No. 865-621-5677 Home No 865-671-2530 Stephanie Sparkman P.E., Alcoa Environmental Supervisor Work No. 865-977-3671 Pager No. 865-564-0749 Cell No. 865-803-4999 Home No 865-671-1047 Facility Response Team: APGI-Tapoco does not have an internal response team. If a spill occurs contact Dispatcher @ 865-977-3322 who shall contact Stephanie Sparkman(Work: 865/977-3671; Pager: 865/564-0749) for further instructions. Regional Response Center (RRC) Work No. 828-479-3352 Graham County Emergency Mgmt Agency Evening No. n/a Pager No. n/a Local Response Teams (list all that are ERAP-3 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Fire Department — Graham County Local Police — North Carolina Highway Patrol Ambulance —Graham County Emergency Response Contractor HEPACO, Inc. CHEMTREC (24 hr) 911 or 828-479-3333 800-662-7956 911 or 704-479-8342 National Response Center (NRC) State Emergency Response Commission (SERC)Work No. North Carolina Emergency Management Agency Evening No. Fire Marshall Work No. Evening No. State Police — North Carolina Highway Patrol Local Emergency Planning Committee (LEPC) Graham County Emergency Management Agency Local Water Supplier Day No. Evening No. National Weather Service — Morristown TN Local Television/Radio Stations for Evacuation Notification Television Stations WCVP 828-479-$080 Radio Stations WOST-13 800-332-9760 Hospital, By Ambulance District Memorial Hospital, Andrews, NC Hospital, By Air Ambulance I T_ Medical Center Knoxville, TN 1-800-424-8800 919-733-3867 1-800-662-7956 828-479-3352 423-586-3771 828-321-1200 865-544-9000 D. Release Response Notification Forms: See Appendix B for Release Response Notification Forms. ERAP-4 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or Implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. ...._.. _... RPCC for APGI-TAPOCOISANTEETLAH NC E. Emergency Response Equipment: TYPICAL RESPONSE DESCRIPTION QUANTITY LOCATION TIME RESPONSIBILIT Y Neoprene Steel - Toed Boots Steel -Toed Metatarsal Boots White Chemical Overalls Rubber Coated Work Gloves Safety Glasses Respirator Hard Hats Life Jacket 5 pairs (Required PPE for Facility) 10 pairs 10 pairs 10 pairs (Required PPE for Facility) 10 each 5 each (Required PPE for Plant) 5 each Cheoah Main Office 45 Minutes Facility Wide Immediate Cheoah Main Office 45 Minutes Cheoah Main Office 45 Minutes Facility Wide Immediate Cheoah Main Office 45 Minutes Cheoah Main Office 45 Minutes Immediate Cheoah Main Office 45 Minutes Maintenance Coordinator Maintenance Coordinator Maintenance Coordinator Maintenance Coordinator Maintenance Coordinator Maintenance Coordinator Maintenance Coordinator Maintenance Coordinator ERAP-5 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC forAPGI-TAPOCO/SANTEETLAH NC TYPICAL RESPONSE DESCRIPTION QUANTITY LOCATION TIME RESPONSIBILIT Y Fire Response Equipment Dry Chemical 3 (3) Powerhouse Immediate Maintenance Extinguishers Main Floor Coordinator CO2 32 (5) Powerhouse -Oil Immediate Maintenance Extinguishers 100 Rooms Coordinator Ibs (16) Generators (4) Powerhouse - Basement (5) Powerhouse - Main Floors (1) Storage Building -East of Powerhouse (1) Storage Building -West of Powerhouse Fire Hose - 100 ft. 1 Powerhouse Immediate Maintenance Coordinator 90 psi Water East & West Immediate Maintenance Hose Fittings Outdoor Walls of Coordinator Powerhouse Release Response Equipment 3M Oil Sorbent 2 bales-(100 Cheoah Main Office 45 Minutes Maintenance Sheets sheets/bale) Coordinator Spill Absorbent Facility Wide Immediate Maintenance Materials Coordinator Floating 1000 feet Cheoah Main Office 45 Minutes Maintenance Absorbent Booms Coordinator Trash Bags 1 box Cheoah Main Office 45 Minutes Maintenance Coordinator Shovels 3 each Cheoah Main Office 45 Minutes Maintenance Coordinator ERAP-6 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Submersible 1 each Cheoah Main Office 45 Minutes Maintenance Sump Pump Coordinator TYPICAL RESPONSE DESCRIPTION QUANTITY LOCATION TIME RESPONSIBILIT Y Release Response Equipment, con't Rope 500 feet Cheoah Main Office 45 Minutes Maintenance Coordinator Generator 1 each Cheoah Main Office 45 Minutes Maintenance Coordinator Air Comp. 5 HP 1 each Cheoah Main Office 45 Minutes Maintenance Coordinator Garden Hose 100 feet Cheoah Main Office 45 Minutes Maintenance Coordinator Sand Bags -filled 12 Cheoah Main Office 45 Minutes Maintenance Coordinator Sand Bags -empty 12 Cheoah Main Office 45 Minutes Maintenance Coordinator Boat 1 each Cheoah Dam 60 Minutes Maintenance Coordinator First,Aid Supplies: 1 Eye Wash Statns Facility Wide Immediate Maintenance Coordinator First Aid Kits 1 each Facility Wide Immediate Maintenance Coordinator F. Facility Response Team: APGI-Tapoco does not have an internal response team. If a spill occurs contact Dispatcher @ 865-977-3322 who shall contact Stephanie Sparkman (Work: 865-977-3671; Pager 865-564-0749; cell 865-803-4999) for further instructions. G. Evacuation Plan: A written plan is located in Appendix G. H. Immediate Actions: Not applicable for this plan. Various release scenarios have been evaluated and immediate action procedures are presented for each: ERAP-7 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC 1. Releases in Diked Areas a. Stop leak if possible or necessary; b. Observe dike integrity (is spill contained?); c. If spill is greater than 5 gallons, immediately notify supervisor. d. Refer to ERAP A, contact Emergency Response Coordinator(s). e. If spilled material is flammable, use NON -SPARKING TOOLS. f. Recover spilled materials if possible and cleanup residues as per RPCC Section V.H. 2. Releases inUndiked Areas NOT APPLICABLE AT THIS SITE 3. Releases to On -Site Ponds/Lagoons NOT APPLICABLE AT THIS SITE 4. Releases on Soil a. Stop leak if possible or necessary; b. If spill is greater than 5 gallons, immediately notify supervisor. c. Refer to ERAP A, contact Emergency Response Coordinator(s). d. If spilled material is flammable, use NON -SPARKING TOOLS. e. Recover spilled materials if possible and cleanup residues as per RPCC Section V.H. 5. Releases to Receiving Streams a. Stop leak if possible or necessary; b. Refer to ERAP A, contact Emergency Response Coordinator(s). c. Recover spilled materials if possible and cleanup residues as per RPCC Section V.H. 6. Release of Toxic or Hazardous Air Pollutants NOT APPLICABLE AT THIS SITE 7. Releases from UST sites NOT APPLICABLE AT THIS SITE 8. Fires and Explosions a. Dial 911; b. Evacuate personnel; c. Refer to ERAP A, contact Emergency Response Coordinator(s). 9. Release of Compressed Gases a. Dial 91.1; b. Evacuate personnel; c. Refer to ERAP A, contact Emergency Response Coordinator(s). ERAP-8 November 2UU4 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC 10. Releases from Oil -filled Electrical Equipment a. Stop leak if possible or necessary; b. If spill is greater than 5 gallons, immediately notify supervisor. c. Refer to ERAP A, contact Emergency Response Coordinator(s). d. If spilled material is flammable, use NON -SPARKING TOOLS. e. Recover spilled materials if possible and cleanup residues as per RPCC Section V.H. 11. Response to Weather -Related Emergencies (i.e., floods, tornadoes, hurricanes, heavy snow, etc.) REFER TO APPENDIX F, EMERGENCY RESPONSE PROCEDURES 12.Off-site Emergencies (e.g., a fire in a neighboring facility or an overturned fuel tanker on a nearby road). a. Dial 911; b. Evacuate personnel; c. Refer to ERAP A, contact Emergency Response Coordinator(s). The release scenarios for are affected by rainfall runoff, wind direction, rainfall, or freezing conditions. In severe weather conditions, it may take longer for emergency equipment and personnel to reach the site. Cleanup efforts will be more difficult as the plume of release may spread further. I. Facility Diagrams: "RPCC Facility Plan" Drawing is located at the end of the ERAP section. J. Distribution List: In accordance with federal, state local regulations, the plan has been distributed to the following public service organizations, clean-up contractors and key personnel within Alcoa. Hard copies of the RPCC Plan will be kept at the following locations: 1. TAPOCO Dispatching Office, Alcoa, TN 2. Cheoah Main Office 3. Santeetlah Powerhouse 4. TN OPS, ALCOA Envr. Dept (electronic only) 5. Alcoa Corp Envr Dept. Pittsburgh PA (electronic) The RPCC plan is available to all ALCOA employees, including corporate personnel, through intranet access of the Tennessee Operations web site: http`://www.tn.alcoa.com The RPCC plan is located in the EHS Manager, Chemical Release section. ERAP-9 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC The following will receive or be offered copies of the ERAP: 6. Graham County Fire Department 7. NC Division of Environmental Management -Water Quality Section 8. North Carolina Emergency Management Agency 9. Graham County Emergency Management Agency 10. HEPACO NOTE: EPA Region 4 has informed Tennessee Operations personnel that copies of the RPCC plan should not be sent to EPA Region 4 unless requested. Everyone on the distribution list will receive a copy of all amended pages as soon as they are available. Agencies will be provided with a full copy of the RPCC Plan upon request. For further information or explanation of personnel duties under this plan, contact the following: Non-ALCOA personnel should contact: Name: ........................................... Mike Infante Title: .............................................. Alcoa, Inc. - TN Operations Communication & Community Affairs Mgr. Plant Number: ............................... 865-977-3358 ALCOA and Regulatory personnel should contact: Name: ....................................................... Walter Brockway Title: .......................................................... Power Manager, APGI-TapocoNadkin Plant Number: ........................................... 865-977-3324 ERAP 10 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC SECTION I - GENERAL FACILITY INFORMATION A. GENERAL FACILITY INFORMATION Plant Name: Street Address: Mailing Address: County Plant Telephone: Fax: Business Unit Name: Business Unit Address: North American Industry Classification NAICS Code NAICS Description: Dun & Bradstreet Number: Main Facilitv'Entrance Latitude: Primary Emergency Response Coordinator Name: Title: Plant Phone Plant Emergency Phone: Pager Number Cell Phone Number Home Emergency Phone: Santeetlah Power Facility NCSR 1247, Rymers Ferry Cheoah Lake, Tapoco, NC P.O. Box 14, Tapoco, NC 28771 Graham 828-498-2354 n/a APGI-Tapoco Division 300 North Hall Road Alcoa, TN 37701 221111 Generation of Electric Power 00-133-9472 350 26' 52" 1 5L E.Ray Barham Technical Mgr — APGI-Tapoco 865-977-2218 865-977-3322 n/a 865-617-0587 865-379-8633 First Alternate Emergency Response Coordinator Name: Timothy Poole Title: Maintenance Supervisor Plant Phone 865-977-2342 Plant Emergency Phone: 865-977-2342 Pager Number 865-996-2262 Cell Phone Number 865-599-4721 Home Emergency Phone: 865-984-1282 I - 1 , November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties; guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCOISANTEETLAH NC B. FACILITY DESCRIPTION 1. LOCATION The Santeetlah Facilities are owned by Alcoa Power Generating Inc.-Tapoco Division which is headquartered in Alcoa, TN. APGI-Tapoco is a wholly owned subsidiary of Alcoa, Inc. The Santeetlah Power Facility is located on the south bank of the Little Tennessee River, near river mile 56.7, (see Figure 1, USGS Site Map in Appendix H). The facility is located approximately 7 miles from Robbinsville, NC, bordered on the southwest by mountains, on the north by the Little Tennessee River, and on the east by wooded terrain. The Santeetlah Dam forms Santeetlah Lake at mile marker 9.3 on the Cheoah River. Discharge from the dam is to the Cheoah River which discharges into the Little Tennessee River at mile marker 51.3. A hydroelectric tunnel runs approximately miles to the Powerhouse which is located at mile marker 56.7 on Cheoah Lake — Little Tennessee River. Powerhouse discharge is to Cheoah Lake which is upstream of Cheoah Dam, located on the Little Tennessee River at mile 51.6. Santeetlah Dam is the last facility of a four dam system running from Eastern Tennessee to Western North Carolina. The three other facilities include Cheoah Dam, also located in North Carolina, and Chilhowee and Calderwood Dams, both located in Tennessee. The general characteristics for the topography at the Santeetlah facility include rugged terrain with heavily forested slopes, rushing streams and waterfalls Elevation ranges from 1,200 MSL in the valley to 6,600 MSL at the peaks. From March through August, the prevailing wind direction is NE and from September through February, the prevailing wind direction is SW. A wind rose representing climatological data for Santeetlah is shown on Figure 2 in Appendix H. The western North Carolina climate is influenced primarily by storms that pass along the Gulf Coast and thence up the Atlantic Coast, and to a lesser extent by those that pass north eastward from Oklahoma to Maine. The mean annual temperature of western North Carolina is between 570 and 58°F. July is the hottest month and January is the coldest. Rainfall is well distributed throughout the year. The wettest months are January, February, and March. The average yearly rainfall for western North Carolina is 57.5" but precipitation in excess of 80" has been recorded on some mountain tops along the Tennessee - North Carolina border. 1- 2 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC 2. GEOLOGY AND GROUNDWATER The Santeetlah Powerhouse is located in the Blue Ridge region of western North Carolina. Bedrock that underlie this region is likely Precambrian in age and belongs to the Ocoee Series of sedimentary rocks, consisting of shale, siltstone, sandstone, slate, graywacke, and conglomerate. The occurrence of water in rocks of the Ocoee series is restricted to fractures formed by joints and cleavage. Most wells obtain a significant amount of groundwater at the residuum - bedrock interface. In western North Carolina, unconsolidated sediments such as gravel, sand, silt, clay, and a mixture of these materials are found. Groundwater at the Santeetlah Facility moves in a predominantly northern direction towards the Little Tennessee River. This facility is not located in, nor does it drain into a wellhead protection area, as defined in the Safe Drinking Water Act (SDWA). The major drainage tributary is the Little Tennessee River which is shown on Figure 1, Appendix H. The Little Tennessee River is classified for fish and aquatic life, recreation, livestock and wildlife watering, irrigation, and domestic/industrial water supply. The closest water intakeis the Tellico Reservoir Development Agency located approximately 37.7 river miles downstream from Santeetlah Dam. Release potentials are low for all hazardous materials, hazardous wastes and oils stored under roof or self-contained at the Santeetlah Facility. However, there is a high risk potential of water contamination with the non -secondarily contained lubricating system on the By -Pass Gates at the Dam. Also, the oil - filled equipment in the non -secondarily contained Switchyard area, located west of the Powerhouse, is considered a high risk potential for a spill/release to the soil and water. The Contingency Plan is presented in Section IV and is designed to minimize hazards to human health and the environment from any unplanned sudden or non -sudden release of oil or hazardous substances or hazardous waste constituents to surface or ground water. Section IV covers the emergency response personnel, contractors, and agencies who would respond to a release; communication and alarm systems available in the event of a release; and also lists the on -site emergency equipment available. 1 _ 3 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or - implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC 3. PRODUCTION PROCESSES The Santeetlah facility is engaged in hydroelectric generation of electricity. The dam was completed in 1928 and handles a drainage area of 176 square miles. The dam is located 5 miles from the Powerhouse and is connected by a hydroelectric tunnel. This tunnel provides mechanical energy (water pressure) which is converted to electrical energy by two generators. An average of 188,500,000 kilowatt hours of electricity annually is provided to Alcoa, Inc. - Tennessee Operations, located in Alcoa, TN. Some oils are stored on site in tanks. Oil filled equipment, transformers and circuit breakers are also located on site. See Table II-1 in Section II for the contents and location of all oil -filled vessels. The facility first started storing oil in 1928. Santeetlah is an unmanned, fully automated facility. Cheoah personnel provide necessary operation and maintenance assistance to the Santeetlah facility. Santeetlah is located southeast of the Cheoah facility and takes approximately 30 minutes to reach by automobile. 4. WASTEWATER SYSTEMS The Santeetlah Power Facility has a general NPDES permit to discharge non -contact cooling water from the generator bearings and non -process water from the Station Sump into the Little Tennessee River. The NPDES Permit number for the Santeetlah Powerhouse is NCG500049. Switching to air-cooled systems eliminated the cooling water discharges from Transformer Banks Nos. 1 and 2. Table 1-1 provides details on the existing discharges. Stormwater and reservoir water seepage into the Powerhouse is directed to a sump located in the Powerhouse Basement. Treatment prior to discharge consists of oil and grease removal by floatation and skimming. See RPCC Drawing in Appendix H for locations of outfalls. 1 - 4 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC TABLE 1-1 FACILITY OUTFALLS DRAINAGE PERMIT NO. RECEIVING AREA REFERENCE STREAM DRAWING NO. NPDES OUTFALL NCG500049 Turbine Bearing Cooling Units #1 Little Tennessee River Basin RPCC Facility Drawing - Appendix H 001 002 NCG500049 Turbine Bearing Cooling Units #2 Little Tennessee River Basin RPCC Facility Drawing - Appendix H 003 NCG500049 Station Sump Little Tennessee River Basin RPCC Facility Drawing - Appendix H Domestic Sewage Domestic sewage generated at the facility is directed to a septic system located on plant property. Storm Sewers and Drains All drains within the Santeetlah Facility (with the exception of the Oil Room) are routed to two 4.400 gallon sumps located in the basement of the Powerhouse. A transfer pump removes storm water that collects in the downstream sump to the river. An automatic level control system operates the pump. The upstream pump is a manual water jet pump. Any floating oils collected in the sump are removed by skimming and placed in a drum. Transformer Banks Nos. 1 and 2 located on either side of the Powerhouse, and the OCB vessels and station service transformers located behind the Powerhouse are diked and equipped with a drainage system. This system has a manually operated gate valve that is kept closed except to drain rainwater. The OCB vessels in the Switchyard have been converted to SF-6 gas breakers and thus do not contain oil. 1 - 5 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or. copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, p orPe RPCC for APGI-TAPOCO/SANTEETLAH NC Process Water Non -contact cooling water from Transformer Banks 1 and 2, and from the generator bearings is discharged directly to the Little Tennessee River by- passing the basement sumps. Another spill reduction improvement is that the transformers are now cooled with air and not cooled with once through lake water. Drinking Water Drinking water is supplied through bottled water. 5. HAZARDOUS MATERIALS Process chemicals are stored in the areas of use at the Santeetlah facility. The majority of the substances are liquids and gases stored in drums and tanks or oil -filled equipment. Drummed hazardous wastes are stored in a Hazardous Waste Storage Building, located southwest of the Powerhouse. Used oil and parts washer solvents are recycled. Other non -recycled, hazardous waste are stored for no longer than 90 days and are transported and disposed of by permitted EPA/State transportation and treatment storage/disposal facilities. On -site management for hazardous substances requires the attendance of personnel with appropriate equipment, prepared to stop when transfer operations are in process. Procedures for preventing and containing spills are given in Sections III and V.F. Spill absorbent materials are available facility -wide. In the event of a spill or release, emergency response equipment is stored at the Main Office. See Section IV, Table IV-1 for a listing of spill/release response equipment and supplies available. Plant wide inspections for all storage and usage areas affected by hazardous materials, hazardous wastes and oils are performed. For a detailed description of the inspection schedule see Section VI. Appropriate training is required for all employees who work with hazardous materials, wastes or oils. See Section VII for a detailed list of training offered on -site. 6. PROTECTION OF SURFACE WATERS The Powerhouse is located on the south bank of the Little Tennessee River. The majority of the facility site drains directly to the river. There is a low release potential for a spill from the facility to reach the river since the OCB units in the switchyard were converted to gas units. Also, there is a moderate release potential for the 90W oil, which is used in the lubricating system located on the By -Pass Gates at the Dam. Should a release occur it would flow north into Cheoah Lake. 1 - 6 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC The majority of the Liquid hazardous materials and oils are managed with secondary containment present. The facility manages a spill response program outlined in Section V.F. Absorbents are maintained at locations where oils and hazardous materials and wastes are managed. 7. CONTINGENCY PLAN DEVELOPMENT Dennis Weeter Associates, 322 High Street, Maryville, TN, 37804, was responsible for formulating the contingency plan under the direction of APGI- Tapoco and Alcoa, Inc. Tennessee Operations Environmental Supervisor (Stephanie Sparkman). Information and guidance on the suggested contents of the contingency plan has been provided by ALCOA's Corporate Environmental Affairs Department in their Release Prevention Control and Countermeasure Plan Manual August 2004. Dr. Weeter made a site visit on 11 /04/04. 8. AIR EMISSIONS There are no air permits required for the Santeetlah facility. Acetylene, carbon dioxide, nitrogen, and oxygen are stored in compressed cylinders in areas of use. In the event of a cylinder leak, these could become an air emission source. 9. ALCOA OWNED RAILROADS Not applicable. 10. FACILITY EXPANSION There have been no substantial expansions to the Santeetlah facility completed after January 1, 1990, which would necessitate an increase in response equipment to adequately respond to a release. 1 _ 7 November 2004 This information is the property of Alcoa. It is not to be used,. reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC C. STATEMENT OF RELEASE PLAN POLICY Alcoa`s Environment, Health and Safety Policy: It is Alcoa's policy to operate worldwide in a safe, responsible manner which respects the environment and the health of our employees, our customers and the communities where we operate. We will not compromise environmental, health or safety values for profit or production. All Alcoans are expected to understand, promote and assist in the implementation of this policy. This plan contains procedures and controls designed to minimize hazards to human health and the environment by preventing: spills of oils and hazardous substances to the land and water, releases of hazardous substances to the subsurface environment, and toxic and hazardous atmospheric emissions. It was prepared to satisfy the emergency response planning requirements of the following regulations: 1) Spill Prevention, Control and Countermeasure (SPCC) requirements for Oils (40 CFR 112.1(b) & (d)(2)(ii)) and 112.7(a)(1)under the Clean Water Act (CWA) and PCBs (40 CFR 761.65(c)(1)(iv))under the Toxic Substances Control Act (TSCA); 2) Contingency Plan requirements for Hazardous Wastes (40 CFR 265.51(a)) under the Resource Conservation and Recovery Act (RCRA); 3) Emergency Response requirements for hazardous and toxic substances (40 CFR 355.30(a)) under the Superfund Amendments and Reauthorization Act Title 111 (SARA); 4) Storm water Pollution Prevention (SWPP) Plans and Best Management Practices (40 CFR 125.104) under section 304(e) of the CWA; 5) Hazardous Material Incident Reporting (49 CFR 171.6), Emergency Response Information (49 CFR 172.600), and Hazmat Training (49 CFR 172.700-.704) requirements of the Hazardous Materials Transportation Act (HMTA); 6) Emergency Action Plan (29 CFR 1910.38(a)) and Emergency Response Plan (29 CFR 1910.120) requirements under the Occupational Safety and Health Act (OSHA); 7) Facility Response Plan requirements of various regulations mandated by the Oil Pollution Prevention Act (OPA) amendments to the CWA: a. EPA regulations (40 CFR 112); b. US Coast Guard regulations (33 CFR 154) c. DOT regulations (49 CFR 194) d. Minerals Management Service (Department of Interior) regulations (30 CFR 254) 8) Process Safety Management of Highly Hazardous Chemicals (Process Safety Management Standard) requirements of OSHA (29 CFR 1910.119) and; 9) General Duty Clause and Emergency Response Planning under the Risk Management Program requirements of the Clean Air Act (CAA) amendments §112(r) regulations (40 CFR 68). 1 - 8 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC 1 D) State rules and regulations where those requirements are more stringent than those of the above referenced Federal regulations. At this location, Federal SPCC rules are more stringent than Tennessee rules. Location management will use whatever personnel, equipment, and materials are necessary to control releases at APGI-Tapoco/Santeetlah. The Primary Emergency Response Coordinator identified in the Emergency Response Action Plan shall have full authority to implement this response plan. The priorities of response team members are based upon protection of human life, mitigating environmental harm and protection of property respectively. Since this facility is subject to SPCC requirements the "Certification of thef Applicability of the Substantial Harm Criteria" form contained in Appendix B should be signed by one of the individuals signing in this section. TITLE SIGNATURE DATE Technical Manager APGI-Tapoco Division TITLE Power Manager APGI-TapocoNadkin TITLE Manager, Environmental Affairs TN Operations, Alcoa, Inc. TITLE J E.Ray Barham SIGNATURE DATE L4 16 le ; alter Broc y SIGNATURE DATE Dale Huddleston SIGNATURE DATE Maintenance Coordinator / Q` APGI-Tapoco Division �yPEle Tim TITLE O SLQI TYRE DATE Alcoa Inc. Tennessee Operations 4 Environmental Supervisor — — -rl,-• -- -'--' - 9 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without egress permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. r.,,.uw.az.,srFiqua. _ 5i� � ,. . • .� . RPCC for APGI-TAPOCO/SANTEETLAH NC D. PLAN CERTIFICATION l hereby certify that l have examined Alcoa's APGI Santeetlah facility located at Santeetlah Powerhouse, North Carolina and being familiar with the provisions for spill prevention, control and countermeasures plans of the Clean Water Act (CWA), and the Oil Pollution Act (OPA), _attest that this Release Prevention, Control and Countermeasure (RPCC) Plan has been prepared in accordance with good engineering, environmental, and safety practices, including applicable industry standards and the requirements of the regulations at 40 CFR Part 112, 1 further attest that procedures for required inspections and testing of oil containers have been established; and that this Plan is adequate for the Facility. r �3*�y�+r�lxr4i� r� V C l3uo. 1a.. 1 t ' a YY Sr r � � DATE: �'��3 Dennis W. Weeter, Ph.D., PE Jan. 28, 2005 Registration No. 10923 State of Tennessee E. PLAN REVIEW AND AMENDMENT I. This plan will be reviewed as necessary or at least annually to satisfy or determine the following conditions: a. Appropriate plant personnel received their annual training review, and any subsequent necessary revisions were made to the training program. b. The local emergency response teams, police and fire departments completed their annual visit, and reviewed both the plan as well as the location and properties of all on -site hazardous wastes and materials, and used oil management facilities. The Facility Physician has reviewed and approved emergency medical procedures and equipment. c. The plan must be updated following each occurrence of an oil or hazardous material release, and the event shall be described in the following section (l. F.). d. The plan must be amended if any of the following conditions occur. (1) to modify ineffective response procedures as revealed by results of routine drills or based on observations during actual emergency situations; 1 - 10 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC (2) if there are changes to the design, construction, operation, or maintenance of the facility which increases the potential for fires, explosions, or releases of oils, hazardous materials or wastes; (3) if the emergency equipment or coordinators change (4) if the facility permit is modified, or if the signatory authority for a storm water permit changes, or if the applicable regulations are revised; and (5) any other changes that materially affect the implementation of the response plan (e.g., the addition of used oil management provisions). These changes shall be incorporated into this plan as soon as soon as conditions requiring plan modification are known. 2. The review of this plan will not constitute meeting the requirements of the annual Comprehensive Site Compliance Evaluation (CSCE) of the Storm Water Pollution Prevention Plan. if applicable, the CSCE will be conducted independently to determine compliance with the requirements of the SWPPP and NPDES requirements. A separate CSCE report will be maintained. This Plan will be updated, following completion of the CSCE report, to identify any new sources of potential storm water pollution, to identify any new sources of non - storm water discharges, to identify any new or revised BMP's, and to incorporate any new storm water sampling data. 3. If there are no emergency releases, and amendments are not required for any of the conditions listed in 1.d. and 2. above, then the plan shall be revised every 5 years. If technical changes involving oil storage or handling conditions listed in 1. d above are made the plan must be re -certified by a professional engineer. If any technical changes are made to the conditions listed in 1.d. and 2. above that require certification by a professional engineer pursuant to State or local regulations, then re -certification is necessary. If no technical changes are made, then re -certification is not necessary. 4. Annual review of this Plan will be done by the Santeetlah RPCC Team consisting of persons listed in ERAP A. This review will be documented in the Annual Review Log which is contained in Appendix B. If you are required to submit your plan to an agency (EPA, Coast Guard, RSPA), retain a copy of your transmittal letter, a copy of any notification of deficiency received from the agency, copies of resubmittal correspondence, and all correspondence related to any appeal of findings of deficiency. F. RELEASE EVENT HISTORY According to APGI-Tapoco personnel there have been no reportable spill/releases at the Santeetlah facility in the last three years. - 11 November 2004 This information is the property of Alcoa.. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC G. PLAN DISTRIBUTION LIST In accordance with federal, state local regulations, the plan has been distributed to the following public service organizations, clean-up contractors and key personnel within Alcoa. Hard copies of the RPCC Plan will be kept at the following locations: 1. TAPOCO Dispatching Office, Alcoa, TN 2. Cheoah Main Office 3. Santeetlah Powerhouse 4. TN OPS, ALCOA Envr. Dept (electronic only) 5. Alcoa Corp Envr Dept, Pittsburgh PA (electronic) The RPCC plan is available to all ALCOA employees, including corporate personnel, through intranet access of the Tennessee Operations web site: http://www.tn.alcoa.com The RPCC plan is located in the EHS Manager, Chemical Release section. The following will receive or be offered copies of the ERAP: 6. Graham County Fire Department 7. NC Division of Environmental Management -Water Quality Section 8. North Carolina Emergency Management Agency 9. Graham County Emergency Management Agency 10. HEPACO NOTE: EPA Region 4 has informed Tennessee Operations personnel that copies of the RPCC plan should not be sent to EPA Region 4 unless requested. Everyone on the distribution list will receive a copy of all amended pages as soon as they are available. Agencies will be provided with a full copy of the RPCC Plan upon request. For further information or explanation of personnel duties under this plan, contact the following: Non-ALCOA personnel should contact: Name: ........................................... Mike Infante Title: .............................................. Alcoa, Inc. - TN Operations Communication & Community Affairs Mgr. Plant Number: ............................... 865-977-3358 ALCOA and Regulatory personnel should contact: Name: ....................................................... Walter Brockway Title: .......................................................... Power Manager, APGI-TapocoNadkin Plant Number:...........................................865-977-3324 1 - 12 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC SECTION II MATERIALS AND FACILITY INVENTORY A. EXPLANATION OF INVENTORY CODES Table 1/4 is a listing of the hazardous substances, wastes, oils and industrial gases at this location that have the potential for spills or accidental releases into the environment. For each substance the table includes: (1) a chemical description; (2) information on its storage location or area where it is used; (3) the capacity of the tank or container, (4) the number of tanks or containers for this substance at this location; (5) the maximum volume at this location; (6) the amount typically on -site; (7) the type(s) of storage containers used along with the temperature' and pressure conditions of each and the type of secondary containment provided, (8) containment type code; (9) the volume of the secondary containment; (10) the hazard class/code; (11) the release potential, (12) and a code for the release%mergency response procedures that will be followed in the event of a release. The chemical description is the same as used on the SARA Tier Two report form i.e., pure, mix, solid, liquid, gas, and EHS (Extremely Hazardous Substance). The following codes are for the ranges of the amounts typically on site over the course of the year. Quantity Range in Same Units of Measure Specified for Container Capacity (pounds or Range gallons) Value From... To... 01 0 99 02 100 999 03 1,000 9,999 04 10,000 99,999 05 100,000 999,999 06 1,000,000 9.999.999 07 10, 000, 000 49, 999, 999 08 50, 000, 000 99, 9999, 999 09 100, 000, 000 499, 999, 999 10 500, 000, 000 999, 999, 999 The type of storage container along with the actual storage conditions and the type of secondary containment provided is designated for each source using the following codes. For each above ground tank the additional codes listed under A below are used to describe the type of tank construction. November 2004 press permission. No warranties, guarantees, or representation, expressed or This information is the property of Alcoa. It is not to be used, reproduced, or copied without ex implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC A Above Ground Tank R Process Impoundment (e.g., mudlake) Ao Open Top S Oil Filled Transformer or Switch ear Ac Closed To T Other Af Floating Top B Completely Buried Tank 77� wk B-280 Buried Tank Regulated under RCRA 280 or 281 1 Ambient Pressure Bu Unprotected bare steel 2 Greater than Ambient Bc Coated and Cathodic Protection 3 Less than Ambient Bid Bn Double Wall Tank 4 Ambient Temperature I Non -corroding Material (e.g., fiberglass) C Tank Inside Building 5 Greater than Ambient D Steel Drum 6 Less than Ambient E Plastic or Non-metallic drum 7 Cryogenic Conditions F G Can Carboy a *004dti Dike or Berm H Silo b Curbing I Fiber drum c Culvert, Gutter, Sump i Bag d Weir, Boom, Dam K Box e Spill Diversion Pond L Cylinder f I Retention Pond M Glass Bottle or Jug q Drip Pan N Plastic Bottle or Jug h Sorbent Materials 0 Tote Bin i Other P Tank Wagon (mobile oil storage) j None Q Rail Car 11-2 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCUSANTEETLAH NC The hazard class/codes listed in Table II-1 are a combination of EPA and RCRA Categories and are defined below. Ct'H/t'ilrl'SH l,.lcts��riVa�w�r .� �sv�� Materials Included Code FH -Fire Hazard Flammable, combustible liquids, pyrophoric materials, and oxidizes SRP - Sudden Release of Pressure Explosives, compressed gas, aerosol cans R - Reactive Unstable reactive materials, organic peroxides water reactive materials A - Immediate (Acute) Health Hazard Toxic materials, irritants, sensitizers, and corrosive materials. Includes other hazardous chemicals that have an adverse effect with short term exposure. C - Delayed (Chronic) Health Hazard Carcinogens and other hazardous chemicals that have an adverse effect with long term exposure. EPA Waste I.D. Number RCRA regulated wastes (e.g.,, FOO2 - spent halo enated solvents r _ _ AL. r�,..l:�,. ,,.1 +hn+ mntorial Will Helease porenval ranrc]nys d1V I✓aOcu uN�". .� - - - •..__ _- _______ leave the confines of its containment vessel, pipe, or dike and enter the environment. A "low" ranking indicates secure containers, few or no valves and piping that could leak, secondary containment and/or little chance for a released material to enter the environment. A "moderate" ranking may indicate less secure containers, piping and valves which may leak, moderate possibility of container damage by vehicles, no secondary containment and/or a possibility that released material may enter the environment. A "high" ranking may indicate that containers are not suitable for the chemical stored, poor conditions or age of containers, high possibility of container damage by vehicles, frequent spill history, little or no secondary containment and/or high possibility that released material may enter the environment through drains, soil percolation, or vapor releases. Spill and Emergency Response Procedures are identified by a code number in the last column of Table H-1. These code numbers identify the subsection in Section V.F. which provides detailed response procedures for the specific spill sources. Appendix E indicates the location of MSDS sheets for each material listed in Table 11-1 and contains applicable Emergency Response Guidelines. MSDS sheets can be located on the Alcoa Intranet web site. B. FACILITY MAP See the RPCC Facility Drawing located in Appendix H for the locations of the storage areas listed in Tables II-1. 11 3 November 2004 This information is the property of Alcoa. 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FACILITY DESIGN Minimum release preventive measures in into the design of the following storage containers and facilities on the Santeetlah site include: 1. Drums, carboys, and other containers are, if located outdoors, typically secondarily contained and protected from runon and runoff. This applies to single units or multiple units. Units located indoors shall be secondarily contained unless any of the following conditions are met: i) The units are used in a process; The units are located such that a leak or spill drains to an in - plant sump which is self contained. Greater than 10' from an outside door or opening. 2. Aboveground tanks containing liquids shall, if located outdoors, be secondarily contained, and protected from runon and runoff. This applies to single units or multiple units. Units located indoors shall be secondarily contained unless any of the following conditions are met: i.) The units are used in a process; The units are located such that a leak or spill drains to an in - plant sump which is self contained Greater than 35' from an outside door or opening. Aboveground tanks of compressed gas or liquified gas do not require secondary containment unless the contained gas is condensed upon release. Secondary containment facilities shall be capable of retaining 110% of the volume of the largest tank plus have freeboard equal to the depth of a 24 hour 25 year frequency storm event. Freeboard would not be required for facilities not exposed to precipitation. Freeboard requirements would not apply to double walled tanks that are enclosed and protected from precipitation. Secondary containment facilities shall have drains that are closed and secured. Santeetlah has an aboveground diesel tank that is secondarily contained and is part of the emergency generator. 3. Santeetlah does not have underground storage tanks. 4. Santeetlah does not have surface impoundments. I11 - 1 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC 5. There are no waste piles at Santeetlah exposed to wind or precipitation. 6. All raw materials and wastes are either stored in buildings, under cover, or in diked areas. 7. There are no landfill closure projects on this site. 8. There are no aboveground pipelines carrying hazardous materials on this site. 9. The transformers at the switchyard have been converted to SF-6 gas and are oil free. 10. Santeetlah does not have items that contain PCB's greater than 50 ppm. 11. There is no drainage trough near the transformers at the Santeetlah facility. Documentation to these minimum facility design conditions is available via engineering drawings, engineering reports, and bills of materials that are maintained by the Plant Engineering Department. Further the RPCC Certifying Engineer inspected the facilities and operations on November 04, 2004. A Stormwater Management Plan is not required at Santeetlah according to APGI- Tapoco Division. The RPCC is the Stormwater Management Plan. B. FACILITY MAP See the RPCC Facility Drawing in Appendix H for the location of the facilities discussed in this Plan, and Table IV-1 for a listing of spill control and emergency response equipment. C. FACILITY OPERATION See Section V-B and the Santeetlah Emergency Procedures Plan (Appendix F) which contain procedures to be followed when reporting or responding to a spill or release. Table II-1 indicates areas and processes where Moderate to High risk exists for release. The following are operating practices that could be used to reduce the risk of pollution entering surface waters, air, land or groundwater. By-pass gates are not secondarily contained. III - 2 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, orrepresentation, expressed or implied, are made as to the accuracy, utility or effectivenessofthe methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Minimum release preventative measures incorporated into the operation of the following areas and facilities include: 1. Storage Areas for drums, carboys, and other containers a. Areas are routinely inspected. b. Aboveground tanks are routinely inspected. C. Santeetlah does not have underground storage tanks. d. Santeetlah does not have surface impoundments. e. Santeetlah does not have waste piles. f. Santeetlah does not store raw materials outdoors. g. There are no closed landfills on this site. h. Aboveground pipelines are not used on this site to transfer hazardous materials. i. Santeetlah actively inspects transformer pits. j. Santeetlah does not store PCB items. Santeetlah does not have items that contain greater than 50 ppm PCBs. k. There is no drainage trough on this site. 2. Should Santeetlah install secondary containment at the facility, manually operated drain valves outside dikes will be used. Appendix B contains a model"containment drainage form." 3. Santeetlah is not required to have ad Non-Hazardous are to be moved to thegement on-s to Plan. Hazardous and non hazardous hazardous waste "storage building". All plant areas are routinely inspected. Hazardous and non -hazardous waste drums are managed via Alcoa, Inc., Tennessee Operations at the South Plant, Alcoa, TN. 4. Santeetlah does have routine operations that present a risk of releasing oil or hazardous substances. Systems, identified as follows, should in the near future be modified as so: (i) Temporary dikes shall be used when performing maintenance on By - Pass gates. III - 3 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC 5. There are no fuel loading stations at Santeetlah. There is a diesel tank, secondarily contained, at the emergency generator. 6. There are no on -site waste disposal practices exposed to precipitation. NOTE: Items III-C.7, III-C.8, and III-C.9 from the Corporate guidelines answer questions that relate to the Stormwater Plan. Each question is answered in a duplicate manner and repeated because that is recommended in the Corporate guidelines. 7. Santeetlah does not have a separate Storm Water Management Plan. The RPCC serves as the Storm Water Management Plan. 8. Santeetlah does not have a separate Storm Water Management Plan. The RPCC serves as the Storm Water Management Plan. 9. Santeetlah does not have a separate Storm Water Management Plan. The RPCC serves as the Storm Water Management Plan. 10. There are no fuel stations at this site. There is a diesel tank, secondarily contained, at the emergency generator. 11, CHLORINE is not managed on this site. D. LOADING/UNLOADING OPERATIONS See RPCC Facility Drawing in Appendix H for locations where fuels, oils, chemicals, and raw materials are loaded and unloaded. Santeetlah will determine if on -site loading and unloading operations adhere to applicable DOT regulations. At the By-pass gates operations are intended to be managed to contain spills and leaks, and in accordance with the applicable requirements of 40 CFR 112. Maximum volume of oil at risk ranges up to 60 gallons. Shipping and receiving personnel have received HM 181 and Hazard Communication training. In addition, these personnel are familiar with notification procedures to initiate emergency response actions There are no loading racks at this facility. Loading and unloading of oils and fuels shall be conducted under manned conditions at both the truck and the receiving tank. Standard loading/unloading procedures include the following: • Verify that shipment received is the product ordered • Verify that quantity of material to be unloaded (loaded) will not exceed storage tank (tank truck) capacity • Ensure that truck brake is set and wheels are blocked III - 4 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC • Make sure packages are secured to prevent relative motion between containers • If flammable materials are being handled, make sure truck is grounded, remove all ignition sources, and prohibit smoking • Use proper tools for loading/unloading to prevent damaging containers • Take precautions to prevent undue temperature changes of cargo, prevent tampering, prevent removal or leakage during transport • Require that a qualified person observes loading/unloading operation and remains with truck until operation completed • Review MSDS for use of personal protective equipment and review spill response procedures • Connect hoses and set tank valves and truck valves • Check truck drain valves for proper closure before beginning, loading • Monitor hose connections and valve positions • Collect leaks in proper container or implement spill response procedures • Make sure valves are secured before hoses are disconnected and be sure hoses are disconnected before truck leaves • Ensure that hazardous materials are not loaded together if prohibited by 49 CFR 177.848 • Make sure vehicle is properly placarded • Make sure shipping papers properly identify hazardous materials and contain emergency response information (such as MSDS) and emergency telephone number (must be monitored at all times material is in transit and must be answered by person or agency knowledgeable of hazards, characteristics and emergency response procedures for materials of concern) • Ensure that carriers transporting oil have oil spill prevention and response plans conforming to DOT regulations 49`CFR Part130 • Ensure that transportation of hazardous materials off -site by Alcoa vehicles and employees conforms to DOT regulations pertaining to disabled vehicles, accidents, broken or leaking containers, and repairs as outlined in DOT 177 Subpart D The revisions to the oil spill regulations, effective July 2002, received another extension. EPA published the extension in the Federal Register on 2004 August 11, volume 69, number 154, pages 48794-48799.` The new compliance dates are: Amend SPCC Plan 2006 February 17 Implement SPCC Plan 2006 August 18 E. SALT STORAGE AREAS Santeetlah does not store road salt. F. ATMOSPHERIC RELEASES AND RISK MANAGEMENT PROGRAM There are no permitted air sources at this site. November 2004 III - 5 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Gaseous and liquified gas tanks (acetylene, argon, carbon dioxide, nitrogen, and oxygen) are inspected as required by appropriate North Carolina agencies. These tanks are filled, inspected, and maintained by the vendors who supply the products. A "Chlorine Management Plan" is not required at this site. G. DISCHARGE DETECTION SYSTEMS Include a description of all spill or discharge detection devices such as tank overfill alarms, secondary containment sensors, leak detectors, etc., provided at this facility. Describe how the reliability of automatic leak detection devices is checked and the frequency of inspection. Describe procedures used to verify an alarm signal and actions to be initiated when a release is verified. For example, oil storage containers subject to SPCC requirements must provide at least one of the following devices: • high liquid level alarms with audible or visual signal at a constantly attended operation or surveillance station • high liquid level pump cutoff devices to stop flow at a preset container level • direct audible or code signal communication between container gauge and the pumping station • a fast response system for determining the liquid level of each bulk storage container such as digital computers, telepulse, or direct vision gauges. Storage containers include diesel storage tank and transformers. Permanent storage tanks are no longer used. Transformers could only experience a high oil level condition during initial filling operations. All of these devices have oil level gauges or sight glasses which are monitored by a qualified person during filling operations. There are no pumps or oil supplies to increase the level when this equipment is in operation. The fuel tank is filled by an outside vendor. They do have sight gauges and are monitored during filling operation. H. SECURITY Security measures are an integral part of the facility pollution prevention program. This facility's security system is designed to prevent accidental or intentional entry into the plant so that a release incident related to vandalism, theft, or sabotage is avoided. Site security details are located on Page 30, Appendix F, Emergency Response Plan. As of Nov. 2004, this facility does not have a security system or patrol. The SHIFT mechanic inspects all dikes and removes rainwater if necessary. The inspectors log is permanently kept at Cheoah Main Office. 111 - 6 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Secured fencing surrounds the powerhouse. Areas where hazardous chemicals or wastes are handled and stored are either under inspection by persons in individual production areas or plant security. The facility is adequately lighted both internally as well as externally. All drain valves or other valves which would permit release of tank contents are in the closed position when the system is not in either operating or standby modes. Pump starter controls are locked in the off position and accessible only to authorized personnel when the system is not in either operating or standby modes. The loading/unloading piping connections are securely capped or blank -flanged when not in service or when in standby mode for a period of 6 months or more. This will be verified during the inspection procedures. I. TOXIC ORGANICS OR SOLVENT MANAGEMENT PLANS Santeetlah is not required to maintain a toxic organic or solvent management plan. J. BEST MANAGEMENT PRACTICES (BMP) PROGRAM Santeetlah is not required to maintain a BMP plan or program. 111 _ 7 November 2004 .This information is the property mpl implied, It is to to the accuracy, acy,dutiltyy orreffectiv n'essuofthermethods,Iproces es products, or procedures. r representation, expressed or RPCC for APGI-TAPOCO/SANTEETLAH NC • If his assessment indicates that evacuation of local areas may be advisable he must: 1) notify and confer with appropriate local authorities regarding whether or not local areas should be evacuated, and 2) notify either the government official designated as the on -scene coordinator for their geographical area or the National Response Center and include all of the pertinent information • During the emergency, take all reasonable measures to ensure that fires, explosions, or releases do not occur, recur, or spread to other hazardous areas in the facility • Evaluate the need to stop other processes or operations that may interfere with response procedures • Direct the monitoring for leaks, pressure buildup, gas generation, or pipe/valve ruptures following the stoppage of production operations during the emergency • Assess the interaction of the spilled substance with water and/or other substances stored at the facility and notify response personnel at the scene of that assessment (e.g., necessity to remove and isolate containers of incompatible materials) • Immediately after the emergency, provide for treating, storing, or disposing of any recovered wastes, contaminated soil or water associated with the emergency event • Obtain authority to immediately access company funding to initiate cleanup activities • Direct cleanup activities until properly relieved of this responsibility • In the affected area(s) of this facility ensure that: 1) no waste that may be incompatible with the released material is treated, stored, or disposed of until cleanup procedures are completed; 2) all emergency equipment identified in the Emergency Response Action Plan (ERAP) or in Section W.G. of this plan has been cleaned and is fit for its intended use before operations are resumed. NOTE: This location's Emergency Response Coordinators are intended to serve in the role of "qualified individuals (EPA, USCG, and DOT), "emergency coordinators" (RCRA), and "incident commanders" (OSHA) as defined by the appropriate regulatory programs. E.Ray Barham, Technical Manager, APGI-Tapoco, is responsible for oil pollution prevention activities on this site. (See next page.) IV-2 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation; expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for AP(3I-TAPOCO/SANTEETLAH NC E.Ray Barham, Technical Manager, APGI-Tapoco, is responsible for the following activities: • Command and control • Public information • Safety • Liaison with government agencies • Spill containment and countermeasures contracted services) • Planning • Logistics support • Finance activities (both internal and C. STORM WATER POLLUTION PREVENTION TEAM Not applicable at this facility. D. FACILITY EMERGENCY RESPONSE PERSONNEL See ERAP A &'B E. EMERGENCY RESPONSE CONTRACTORS The following company is under contract to Alcoa, Inc. - TN Operations, for emergency response activities. APGI-Tapoco Division is also covered under this contract. Contractor: .................................. HEPACO, Inc. Telephone Number: 865-219-0840 800-888-7689 Response Time: ......................... 2.0 Hours, 40 Minutes Responsibility: Emergency Response Service Assistance Appendix C contains the contract which describes HEPACO's responsibilities. F. PREPAREDNESS AND PREVENTION 1. The following in -plant communication and alarm systems are available for providing immediate emergency instructions to facility personnel, APGI- Tapoco Headquarters, and Alcoa, Inc. — TN Operations: Automatic Fire Alarm System in the Powerhouse (audible alarm locally and signals Cheoah Facility) Automatic Alarm Unauthorized Entry to Powerhouse (signals Cheoah facility) IV-3 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guar representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, p procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Telephone Alerting System in Powerhouse Santeetlah Powerhouse Control Room 828-498-2354 - Cheoah Powerhouse Control Room 828-498-2217 or .................................................. 865-977-3393 Two Way Radio System Powerhouse Control Room Powerhouse Main Office All APGI-Tapoco Vehicles PA System ..........................................Facility Wide Pager...................................................Key Personnel Cellular Phones...................................Not applicable 2. The following are communication systems that are available for summoning emergency assistance from local police and fire departments, or State or Local emergency response teams. Telephone Alerting System ......................Powerhouse Control Room Main Office Two Way Radio System ...........................Powerhouse Control Room Main Office, All APGI-Tapoco vehicles Cellular Phones ........................................Not applicable 3. The following buildings should actively maintain adequate aisle space and access to allow unobstructed movement of personnel, fire protection, release control and decontamination equipment during an emergency response event; Powerhouse (all floors), Hazardous Waste Storage Building, Oil House 4. Arrangements with the following outside agencies have been made for providing help during an emergency that exceeds the plant's emergency response capabilities. Agency Area of Expertise Alcoa, Inc., TN Operations Environmental emergency Environmental Supervisor response assistance Stephanie Sparkman- 865-977-3671 Typical Response Time: Approx.1 hour, 40 min. s� IV - 4 November 2004 This information is the property of Alcoa. It is not to he used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Agency Graham County Fire Department 911_or 828-479-3333 Typical Response Time: Approx. 20 min. North Carolina Emergency Management Agency 919.733-3867 Typical Response Time: 2 hours North Carolina Highway Patrol 800`-662-7956 Area of Expertise Fire fighting assistance Major oil release assistance Evacuation assistance Hazardous waste or hazardous material release assistance State Warning Point Graham County Hazardous waste or hazardous Management Agency material release assistance 828-479-3352 Evacuation assistance Typical Response Time: 60 minutes HEPACO, Inc. Emergency response assistance 800-888-7689 (See Appendix C for Equipment Typical Response Times: 2hours, List) 40 minutes CHEMTREC (Chemical Transportation Emergency Center) 1-800-424-9300 Typical Response Time: Immediate Emergency information and assistance for hazardous materials Graham County Ambulance Emergency transport assistance Service 911 or 828-479-8342 Typical Response Time: 1 hour, 20 min. Hospital, By Ambulance District Memorial Hospital, Andrews NC Medical assistance 828-321-1200 Hospital, By Air Ambulance U.T. Medical Center Knoxville, TN 865-544-9000 Television Stations WCVP ............... 828-479-8080 Radio Stations W O ST-13 .......... 800-332-9760 Medical assistance Community notification Community notification IV - 5 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC 5. The facility does not contain any PCB transformers (transformers that contain 50 ppm or greater PCB). 6. In the event of a major disaster such as an earthquake, war, tornado, flood, bomb threat, etc, it may be necessary to evacuate all personnel from the facility. Santeetlah's Evacuation Procedures are part of the Emergency Procedures Plan located in Appendix F. The plan details the shutdown procedures, evacuation routes and assembly points. 7. In the event of a flood the community evacuation procedures are covered in APGI-Tapoco's Emergency Action Plan for Dam Failure, Tallassee Project FERC No.2169, maior revision December 1993. A copy of this plan is located in Santeetlah's Powerhouse Control Room. In the event of a community evacuation, procedures from the "Graham County Emergency Operations Plan" will be followed. A copy of the Plan can be reviewed at the Emergency Management Office, Graham County Communications, 828-479-3352. 8. In the event of a community evacuation, procedures from the "Graham County Emergency Operations Plan" will be followed. A copy of the Plan can be reviewed at the Emergency Management Office, Graham County Communications, 828-479-3352. During flood conditions, it may be difficult to properly respond to a release. Assistance from the spill response contractors previously mentioned may be required. Also, during a labor strike, management personnel would be responsible for emergency response to a spill incident and they may require outside assistance; thus increasing the time period for controlling the incident. 9. Hot work permits are not applicable at this facility Plant safety procedures require written authorization in the form of a excavation permit prior to any excavation work. G. EMERGENCY RESPONSE EQUIPMENT See ERAP Section E. for a detailed tabular listing including the description, quantity, capability (e.g., liquid holding capacity), and storage location(s), of all equipment and materials that have been designated for use in responding to fires, spills and emergency releases. IV-6 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC SECTION V - EMERGENCY RESPONSE PROCEDURES A. GENERAL OVERVIEW 1. The Emergency Response Procedures describe response activities to fires or explosions, and those emergencies resulting in releases of oil, hazardous materials, or hazardous wastes to the environment, including air, soil, surface waters and groundwaters. 2. The facility's "Emergency Procedures Plan", prepared by EMPE, Inc., and dated 1/94, includes management of major injuries, fires, earthquakes, floods, tornados or severe storms, and blizzards. The plan also addresses communication and reporting procedures in the event of an emergency. A copy of the Emergency Procedures Plan is included in Appendix F. The "Evacuation Plan", which is activated in the event of a bomb threat, severe earthquake or fire is also included in the "Emergency Procedures Plan". This "Evacuation Plan" includes shut down procedures, evacuation routes and assembly points. In the event of a flood/darn failure where downstream evacuation is necessary, procedures for evacuation are covered in APGI-Tapoco's Emergency Action Plan for Dam Failure, Tallassee Project FERC No. 2169, maior revision December- 1993. A copy of this plan is located in the Santeetlah Dam Office. Dennis Weeter and Associates assumes NO liability for the content or regulatory accuracy of the above mentioned plans. These Emergency Response Procedures will be used in conjunction with the County's emergency response plan if the situation mandates this action. The Graham County Emergency Management Service's plan entitled "Graham County Emergency Operations Plan" addresses procedures for county wide evacuation. The plan also discusses handling the following events during an emergency situation: fire and rescue, health and medical, shelter and mass care, evacuation, transportation, resource management, tornadoes, floods, transportation accidents, chemical spills, radiological accidents, energy crisis, nuclear attack, winter storms, and earthquakes. A copy of the Plan can be reviewed at the Graham County Emergency Management Office, Graham County Communications, 828-479-3352. 3. These Procedures will be reviewed annually, and amended as needed to address changes or additions to facilities processes, operations, hazardous substances, and personnel which would adversely impact their effectiveness. V - 1 November 2004 This information is the propertympl implied, are madetto be used, as to the accuracryautilty, orreffectivven'essuof thermethods,lproces es products, or procedures.r representation, expressed or RPCC for APGI-TAPOCO/SANTEETLAH NC 10 4. Following the occurrence of a spill, release, fire, or explosion that requires implementation of this plan, the Primary Emergency Coordinator must notify the proper regulatory agencies within the timeframe specified by the applicable regulation(s) (See Section V.D.), and follow-up, if required, with a written Release Report (examples in Appendix B) which will be submitted within the time frame requirements (5-15 days) of the specific regulation(s). ALERT PROCEDURES See ERAP B for the procedure the individual discovering the incident will initiate. APGI-Tapoco's Santeetlah Powerhouse is a small quantity hazardous waste generator. The following information shall be posted next to the telephone: • Name and phone number of Emergency Response Coordinator • Location of Fire Extinguishers and spill control materials * Phone number of the fire department C. EMERGENCY DISPATCHER'S RESPONSIBILITIES Below is a list of emergency events with the First Plant Contacts and their notification responsibilities. 1. Releases of Oils. Hazardous Materials or Waste Oils First Plant Contacts - Technical Manager, APGI-Tapoco E.Ray Barham.....................................................865-977-3322 or 865-977-2418 (Work) 865-379-8633 (Home) n/a (Pager) 865-617-0587(cell) Maintenance Coordinator Timothy Poole......................................................865-977-2342(Work) 865-984-1282 (Home) a. Notify - Alcoa's Environmental Supervisor Stephanie Sparkman................................865-977-3671 (Work) 865-671-1047 (Home) 865-564-0749 (Pager) 865-803-4999(cell) b. Notify - Power Manager, APGI-TapocoNadkin Walter Brockway.......................................865-977-3324 (Work) 865-671-2530 (Home) 865-621-5677 (cell) V - 2 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC C. Depending upon the severity of the situation, First -Plant -Contacts will either_ implement the appropriate emergency response and cleanup procedures presented in Section V.F with plant personnel or contact HEPACO for outside assistance. HEPACO 800-888-7689 or 865-219-0840 Emergency Response Contractor 2. Fire First Plant Contacts - Technical Manager, APGI-Tapoco or E.Ray Barham ...................................................865-977-3322 865-977-2418 (Work) 865-379-8633° (Home) n/a (Pager) 865-617-0587(cell) Maintenance Coordinator Timothy Poole......................................................865-977-2342(Work) 865-984-1282 (Home) a. Notify Graham County Fire Department ............911 or 704-479-3333 b. Notify - Alcoa's Environmental Supervisor (Work) Stephanie Sparkman..:............................865-977-3671 865-671-1047 (Home) 865-564-0749 (Pager) 865-803-4999(cell) C. Notify Power Manager, APGI-Tapoco/Yadkin Walter Brockway.......................................865-977-3324 (Work) 865-671-2530 (Home) 865-621-5677 (cell) For a detailed list of responsibilities for the First -Plant Contacts, evacuation procedures, fire safety and preparedness information, see the Emergency Procedures Plan located in Appendix F. V - 3 November 2004 Thisinformation is the property of Alcoa. It is not tobe used, reproduced, or copied without express permission.es eswaor guarantees, procedureor representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, p products, RPCC for APGI-TAPOCO/SANTEETLAH NC D. EMERGENCY NOTIFICATION PROCEDURES NOTE: This section provides a summary of emergency notification requirements. For additional details and more defined procedures on when to report a release, please refer to the ALCOA RELEASE REPORTING MANUAL. 1. Regulatory Basis Environmental release reporting procedures are addressed by the following regulations: a. Comprehensive Environmental Response, Compensation and Liability Act (CERCLA/Superfund), b. Superfund Amendments Reauthorization Act of 1986 (SARA), c. Resource Conservation and Recovery Act (RCRA), d. Toxic Substances Control Act (TSCA), e. Clean Water Act (CWA), f. Oil Pollution Prevention Act (OPA) g. Clean Air Act (CAA), h. Underground Storage Tank (UST) regulations i. Hazardous Materials Transportation Act (HMTA) j. Occupational Safety and Health Act (OSHA). Subsections 2-13 include information on the proper reporting requirements for chemical releases covered by the above Federal regulations. The Federal reporting requirement must be used in coniunction with the State requirements. One does not substitute for the other. Definitions are also included where appropriate to help to better explain the regulatory language. 2. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) - Hazardous Substances Report any "release" into the environment equal to or exceeding the "reportable quantity" in any 24-hour period to United States Coast Guard, Washington, D.C. National Response Center (800) 424-8802 or (202) 267-2675 (Answered 24 hours/day) The oral notification of this release should include: a. Name and location of the facility b. Chemical name or identity of released substances c. An estimate of the quantity of substances released d. Name and telephone number of the person reporting. No follow-up written report is required. V - 4 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC A reportable quantity is defined as one pound for hazardous substances other than substances for which specific quantities are listed in 40 CFR Part 302 Table 302A, and 40 CFR Part 300 Appendix D and E. Appendix D contains a table listing applicable hazardous substances and their reportable quantities. Hazardous Substances are defined by Superfund legislation as: a. Hazardous Substances (Section 311, Clean Water Act) b. Hazardous Waste (Section 3002, Resource Conservation and Recovery Act) c. Toxic Water Pollutants (Section 307, Clean Water Act) d. Hazardous Air Pollutants (Section 112, Clean Air Act) e. Substances designated to present substantial danger under Section 102, Superfund Act (CERCLA) f, Substances controlled under Section 7, Toxic Substances Control Act g. Any other substance that because of its physical and/or chemical properties might pose a danger to human health or the environment. "Release" is defined as any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping or disposing into the "environment". "Environment" is defined as all surface and groundwater, land surface, or subsurface strata and ambient air within the United States or under the jurisdiction of the United States. Releases that are contained within a building are not considered to have entered the environment. 3. Emergency Planning and Community Right -to -Know Act (EPCRA) or SARA Title III - Extremely Toxic and Hazardous Substances NOT APPLICABLE AT THIS SITE. V - 5 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No processes, products, or arantees. procedues.r representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, p RPCC forAPGI-TAPOCO/SANTEETLAH NC 4. Resource Conservation and Recovery Act (RCRA) - Hazardous Wastes Report any releases into the environment equal to or exceeding the reportable quantity to: United States Coast Guard, Washington, D.C. National Response Center (800) 424-8802 or (202) 267-2675 North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management Hazardous Waste Section P.O. Box 29535 Raleigh, NC 27626 (919) 733-2178 North Carolina Division of Environmental Management Emergency Response Commission 116 West Jones St. Raleigh, NC 27603-1335 (919) 733-3867 North Carolina Highway Patrol State Warning Point (800) 662-6956 If the release, fire, or explosion from this facility could threaten human health or the environment outside the facility then local authorities should also be notified if evacuation of local areas is considered advisable. Graham County Emergency Management Service P.O. Box 575 Robbinsville, NC 28771 (828) 479-3352 The oral notification of this release should include: a. Name and telephone number of reporter. b. Name, address, and EPA identification number of the facility. c. Time and type of incident (e.g., release, fire). d. Name and quantity of material(s) involved, to the extent known. e. The extent of injuries, if any. f. The possible hazards to human health or the environment outside the facility. V - 6 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC A written report should be submitted to the EPA Regional Administrator within 15 days of the incident and should include: a. Name, address, and telephone number of the owner or operator. b. Name, address, and telephone number of the facility. c. Date, time, and type of incident (e.g., fire, explosion). d. Name and quantity of material(s) involved. e. The extent of injuries, if any. f. An assessment of actual or potential hazards to human health or the environment, where this is applicable. g. Estimated quantity and disposition of recovered material that resulted from the incident. Following a release, the Regional Administrator as well as appropriate State and local authorities will be notified that the following conditions are met before operations resume in the area affected by the release: • no materials that may be incompatible with the material released will be treated, stored, or disposed until clean-up has been completed • all emergency equipment identified in the Emergency Response Action Plan or in Section W.G. of this plan has been cleaned and is fit for its intended use. EPA Region 4 Atlanta Federal Center 61 Forsyth Street, SW Atlanta, GA 30303-3104 (800) 241-1754 or (404) 562-9900 5. Clean Air Act (CAA) - Excess Air Emissions NOT APPLICABLE TO APGI-TAPOCO'S SANTEETLAH FACILITY. 6. Clean Water Act (CWA) and Oil Pollution Act (OPA) - Oil Immediately report spills into or upon the "navigable water of the United States to: United States Coast Guard National Response Center (800) 424-8802 or (202) 267-2675 EPA Region 4 Atlanta Federal Center 61 Forsyth Street, SW Atlanta, GA 30303-3104 (800) 241-1754 or (404) 562-9900 V 7 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCOISANTEETLAH NC North Carolina Division of Environmental Management - Water Quality Section 512 North Salisbury Street Raleigh, NC 27604 (919) 733-5083 North Carolina Division of Environmental Management Emergency Response Commission 116 West Jones St. Raleigh, NC 27603-1335 (919) 733-3867 North Carolina Highway Patrol State Warning Point (800) 662-6956 "Spills" include discharges which violate applicable water quality standards or cause a film or sheen upon or discoloration of the surface of the water or adjoining shorelines or cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines. "Oil" means oil of any kind and in any form, including but not limited to: petroleum, fuel oil, sludge, oil refuse, and oil mixed with water other than dredged spoil. "Discharge" includes but is not limited to spilling, leaking, pumping, pouring, emitting, emptying, or dumping. It excludes discharges in compliance with a NPDES permit. However, most permits prohibit any discharge causing a sheen. "Navigable Water of the United States" is broadly defined as all surface waters. Addition of dispersants or emulsifiers to oil that would circumvent the provisions of CWA Section 311 b 3 is prohibited. NOTE: A reportable quantity for oil may be interpreted as any amount that produces a visible sheen on water or 25 gallons or more if released to the soil. The oral spill report should include; a. Time of the Spill b. Identity of the material spilled c. Approximate quantity spilled d. Location and source of the spill including type of tank and tank capacity e. Cause and circumstances of the spill f, Existing or potential hazards (fire, explosion, etc.) if any g. Personal injuries or casualties, if any and description of property damage, if any h. Corrective action being taken and an approximate timetable to control, contain, and clean-up spill V - 8 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC i. Name(s) and telephone number(s) of individual(s) who discovered and/or reported the spill j, Facility location including latitude and longitude of main entrance, distance and direction to nearest city k. Other unique or unusual circumstances. Facilities required to have a Spill Prevention Control and Countermeasure (SPCC) Plan that have a spill in excess of "1,000 U. S. gallons" in a single event or have two spill events within any 12-month period into or upon "navigable water of the United States" shall submit to the appropriate EPA Regional Administrator within 60 days from the time the facility becomes aware of the spill a written report containing the following information: a. Name of the facility b. Name(s) of the owner or operator of the facility c. Location of the facility d. Date and year of initial facility operation e. Maximum storage or handling capacity of the facility and normal daily throughput f. Description of the facility, including maps, flow diagrams, and topographical maps g. A complete copy of the SPCC plan with any amendments h. The cause(s) of the spill, including a failure analysis of the system or subsystem in which the failure occurred i, The corrective actions and/or countermeasures taken, including an adequate description of equipment repairs and/or replacement j. Additional preventive measures taken or contemplated to minimize the possibility of recurrence k, Such other information as the Regional Administrator may reasonably require pertinent to the Plan or spill event. 7. Clean Water Act (CWA) -Water Discharge Excursions Report any excursion or noncompliance which may endanger health or the environment within 24 hours of becoming aware of the circumstances to the appropriate EPA Regional Administrator or State contact. A written submission must also be provided within 5 days of becoming aware of the circumstance. North Carolina Division of Environmental Management Water Quality Section 512 North Salisbury Street Raleigh, NC 27604 (919) 733-5083 North Carolina Highway Patrol State Warning Point (800) 662-6956 The following information must be orally reported within 24 hours: v 9 November 2004 This information is the property n plieAlcoa. d, areimadenot as to the accurracy,dutiltyy, or effectivvenlessuofthermethods,permission. processes products, or procedures.r representation, expressed or RPCC for APGI-TAPOCO/SANTEETLAH NC a. Any unanticipated "bypass" which exceeds any effluent limitation in the NPDES permit b. Any "upset" which exceeds any effluent limitation in the NPDES permit c. Violation of a maximum daily discharge limitation for any pollutants listed in the NPDES permit to be reported within 24 hours. "Bypass is defined as the intentional diversion of waste streams from any portion of a treatment facility. "Upset" is defined as an exceptional incident in which there is unintentional and temporary noncompliance with technology based permit effluent limitations, because of factors beyond the reasonable control of the permittee. A written report must be submitted to the Regional U.S. EPA office within 5 days and should include: a. Description of the noncompliance and its cause b. Period of noncompliance, including exact dates and times c. If the noncompliance has not been corrected, the anticipated time that it is expected to continue d. Steps taken or planned to reduce, eliminate, and prevent recurrence of the noncompliance. 8. Clean Water Act (CWA) - Reportable Quantities for Hazardous Substances Immediately report discharge of a designated hazardous substance in quantities equal to or exceeding in any 24 hour period the reportable quantity specified in 40 CFR 117 Table 117.3 into or upon the "navigable water of the United States" to: United States Coast Guard National Response Center (800) 424-8802 or (202) 267-2675 North Carolina Division of Environmental Management Water Quality Section 512 North Salisbury Street Raleigh, NC 27604 (919) 733-5083 North Carolina Division of Environmental Management Emergency Response Commission 116 West Jones St. Raleigh, NC 27603-1335 (919) 733-3867 North Carolina Highway Patrol State Warning Point (800) 662-6956 V - 10 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC The regulation does not provide specific guidance on what is to be included in the initial oral notification, but Environmental Affairs recommends the following be included in the notification: a. Type of material released b. Estimated quantity of material released c. Possible sources of the released material d. Date and time of the release e. Actions being taken to control or remediate the release f. Other agencies contacted g.Other agencies that are on the scene or may be coming to the scene h. Any immediate danger to down stream water users i. Estimated impact of discharge. "Discharge includes but is not limited to any spilling, leaking, pumping, pouring, emitting, emptying or dumping but excludes: • discharges in compliance with a permit under section 402 of the CWA • discharges resulting from circumstances identified and reviewed and made part of the public record with respect to a permit issued or modified under section 402 of the CWA and subject to the condition in such permit • continuous or anticipated intermittent discharges form a point source, identified in a permit or permit application under section 402 of the CWA which are caused by events occurring within the scope of relevant operating or treatment systems. The regulations do not require any specific written follow-up report, but the agency may request specific information to be submitted in writing. 9. Toxic Substances Control Act (TSCA) - PCB Materials NOT APPLICABLE TO APGI-TAPOCO'S SANTEETLAH FACILITY. 10. Resource Conservation and Recovery Act (RCRA) - Underground Storage Tank Leaks NOT APPLICABLE TO APGI-TAPOCO'S SANTEETLAH FACILITY. 11. Clean Water Act (CWA) - Discharges to Public Owned Treatment Works POTW's NOT APPLICABLE TO APGI-TAPOCO'S SANTEETLAH FACILITY. V - 11 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC 12. Hazardous Materials Transportation Act (HMTA) - Hazardous Material Incidents and Unintentional Releases Report any release (escape from a container) of hazardous materials (including hazardous wastes) that occurs during the course of transportation (including loading, unloading, or temporary storage) if the event involves: • a death • injuries requiring hospitalization • estimated property damage exceeding $50,000 • an evacuation of the general public or closing of a major transportation artery for a period of one hour or more • fire, breakage, spillage or suspected contamination involving radioactive or etiologic agents • the release of a marine pollutant in quantities exceeding 450 liters of liquid or 400 kg of solid • any other incident that, in the judgment of the carrier, presents a continuing danger to life at the scene of the incident • alteration of aircraft flight pattern or routine. Give oral notification "at the earliest practical moment" to: United States Coast Guard, Washington, D.C. National Response Center (800) 424-8802 or (202) 267-2675 The oral notification should include: • Name of the reporter • Name and address of the carrier represented by the reporter • Phone number where reporter can be contacted • Date, time, and location of incident • Extent of injuries, if any • Classification, name, and quantity of hazardous materials involved, if such information is available • Type of incident and nature of hazardous material involved, and whether a continuing danger exists. If an etiologic agent is involved, instead of contacting the National Response Center, notice may be given to: Director, Center for Disease Control US Public Health Service (404) 633-5313 Within 30 days of the date of discovery of any release of hazardous materials, including incidents described above, the carrier must report in writing, in duplicate, on DOT Form F 5800.1 to: Information Systems Manager, DHM-63 V - 12 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC Research and Special Programs Administration Department of Transportation 400 Seventh Street SW Washington, D.C. 20590-0001 If the incident involved a hazardous waste, a copy of the manifest must be included with the report and an estimate of the quantity of waste recovered from the scene, name and address of the facility to which it was taken, and the manner of disposition must be included in section IX of the DOT Form F 5800.1. The carrier must also make any other records and information pertaining to the incident available to DOT upon request. 13. Occupational Safety and Health Act (OSHA) - Chemical Releases in the Workplace NOT APPLICABLE TO APGI-TAPOCO'S SANTEETLAH FACILITY. 14. TSCA Section 8(e) Emergency Incidents of Environmental Contamination EPA requires notification of emergency incidents of environmental contamination when the pattern, extent and/or amount of contamination released: • Seriously threatens humans with cancer, birth defects, mutation, death or serious or prolonged incapacitation, or • Seriously threatens non -human organisms with large-scale or ecologically significant population destruction. If the incident meets either criterion, and immediate reporting to NRC is not otherwise required under any other regulatory program, then immediately report the situation to: EPA National Response Center (NRC) (800) 424-8802 (202) 267-2675 Oral notification should include: • Name, job title, address, and phone number of the person reporting • Name and address of the establishment with which the person is associated • Identity of the chemical substance or mixture (including the CAS registry number if known) • Summary of adverse effects or risks and nature and extent of effects • Specific source of information and summary and source of supporting technical data V - 13 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC E. REQUIRED ALCOA NOTIFICATIONS Environmental incidents, including spills over 20 liters outside a designed containment area, are to be reported under the Environmental Incident Reporting System within three working days from the date the incident was identified. Releases that qualify as "Major Incidents" must be entered into the Reporting System within 24 hours. If the spill/release results in a condition of non- compliance with applicable federal, state or local regulations or laws, it should be reported as a non-compliance incident, rather than a spill/release. This reporting mechanism supersedes the "Environmental Event/Procedure Report" and "Metric #1': The Intranet address to log onto the system is http //www safety,alcoa.com/safety/login.asp, and the user must have a valid ID and password. For questions regarding what or how to report, call the Environmental Help Desk in Pittsburgh at 412-553-2828; or send an email to the EHSMetricsReporting.Pit@alcoa.com mailbox. For any release that qualifies as a "Major Incident" the Location Manager is responsible for immediately notifying the appropriate Business Unit President and the Corporate Environmental Director. The Business Unit President is responsible for notifying the Executive Council. Refer to the table below: .......... Who ....... _ .. ._.. Notifies ..... ...... ......... How _. .......... When - ..-_ _...-. . . EHS Mgr. .............._._._.____._.__ _ .. ....... __.. .Location Mgr. ..... Best Means _ _ .... Immediately . _ _ _. Loc. Mgr. Appropriate BU 'Phone Immediately ;President & Corp. 'Environmental :Director BU Executive Council 'VMX 8-225-3004 Within 24 hours President/Location Mgr. _I Location Environmental :Incident Within 24 hours Environmental Mgr. 'Incident Report. Management system Local Authorities as Phone .Within reporting appropriate or guidelines required Major Environmental Incidents may include but are not limited to the following: • Spills of oils, liquid chemicals, or toxic liquids in excess of 2,000 liters (500 gallons) that are not contained • Un-permitted airborne releases of gaseous, liquid, or solid emissions considered to be toxic, in excess of 500 kg (1,100 Ibs) in a two-hour period V - 14 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC • Any spill or release that prompts an inspection by an emergency control or regulatory agency • Spills of toxic solids in excess of 4,000 kg (8,800 Ibs) which are not contained • Any fish kills of more than 25 individuals resulting from a direct release into a river/lake/stream or other water body • Any livestock death that had, or is suspected by Alcoa to have, resulted from emissions, discharges, or spills • Any deaths of more than 5 individuals of wildlife considered valuable by the local community that had, or are suspected by Alcoa to have, resulted from emissions, discharges, or spills • Releases from Alcoa operations that cause significant damage (visual damage over one hectare or more, or measurable reduction in yields) to natural vegetation or crops • Any regulatory inspections that result or are likely to result in major fines ($25,000 or more), requirements to cease or curtail operations, or notification to the media that an environmental problem exists. • Any discoveries or contamination of soil, groundwater, or sediments that have resulted from past spills, releases or discharges from Alcoa plants that could result in remediation costs in excess of $100,000. • Any complaints raised within 24 hours by more than five individuals for the same environmental issue. • Any fire or emergency situation that results or had a high potential to result in impacts on environmental control equipment, waste storage areas,or processes that could have released significant quantities of harmful substances to the environment. Any release that has the potential for significant publicity (e.g., may be reported by major newspapers or national TV news services), whether or not considered a "major incident" should be reported to Corporate EHS by telephone, voice mail or e-mail. Each location should develop a written communication process to appropriately inform neighbors and the public in general when a spill, release or other event occurs that could have adverse impacts beyond the plant site. Fors ills over 20 liters outside containment the RPD Business Unit EHS Manager will be notified — Dale Huddleston 865-977-2780. F. EMERGENCY RESPONSE PROCEDURES For each hazardous substance on site (see Table II-1), Table V-1 indicates the Emergency Response Guide (ERG) that should be used for an emergency action. ERG's can be found in numerical order in Appendix E and Section "Spill or Leak" should be referenced. Refer to Table II-1 and the "RPCC Facilities Plan" in Appendix H for location of the substance. V - 15 November 2004 ressed or This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, exp implied, are made as to the accuracy, utility or effectiveness of the methods, processes, p procedures, RPCC for APGI-TAPOCO/SANTEETLAH NC Emergency Response Scenerios: Various release scenerios, based upon Table V-1 substances and actual plant physical conditions, have been evaluated and procedures are presented for each: 1. Releases in Diked Areas a. Stop leak if possible or necessary; b. Observe dike integrity (is spill contained?); c. If spill is greater than 5 gallons, immediately notify supervisor. d. Refer to ERAP A, contact Emergency Response Coordinator(s). e. If spilled material is flammable, use NON -SPARKING TOOLS. f. Recover spilled materials if possible and cleanup residues as per RPCC Section V.H. 2. Releases in Undiked Areas NOT APPLICABLE AT THIS SITE 3. Releases to On -Site Ponds/Lagoons NOT APPLICABLE AT THIS SITE 4. Releases on Soil a. Stop leak if possible or necessary; b. If spill is greater than 5 gallons, immediately notify supervisor. c. Refer to ERAP A, contact Emergency Response Coordinator(s). d. If spilled material is flammable, use NON -SPARKING TOOLS. e. Recover spilled materials if possible and cleanup residues as per RPCC Section V.H. 5. Releases to Receiving Streams a. Stop leak if possible or necessary; b. Refer to ERAP A, contact Emergency Response Coordinator(s). c. Recover spilled materials if possible and cleanup residues as per RPCC Section V.H. 6. Release of Toxic or Hazardous Air Pollutants NOT APPLICABLE AT THIS SITE 7. Releases from UST sites NOT APPLICABLE AT THIS SITE 8. Fires and Explosions a. Dial 911; b. Evacuate personnel; c. Refer to ERAP A, contact Emergency Response Coordinator(s). 9. Release of Compressed Gases V - 16 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC a. Dial 911; b. Evacuate personnel; c. Refer to ERAP A, contact Emergency Response Coordinator(s). 10. Releases from Oil -filled Electrical Equipment a. Stop leak if possible or necessary; b. If spill is greater than 5 gallons, immediately notify supervisor. c. Refer to ERAP A, contact Emergency Response Coordinator(s). d. If spilled material is flammable, use NON -SPARKING TOOLS.. e. Recover spilled materials if possible and cleanup residues as per RPCC Section V.H. 11. Response to Weather -Related Emergencies (i.e., floods, tornadoes, hurricanes, heavy snow, etc.) REFER TO APPENDIX F, EMERGENCY RESPONSE PROCEDURES 12.Off-site Emergencies (e.g., a fire in a neighboring facility or an overturned fuel tanker on a nearby road). a. Dial 911; b. Evacuate personnel; c. Refer to ERAP A, contact Emergency Response Coordinator(s). The release scenerios for V.F.1., V.F.4., V.F.5., V.F.8., and V.F.9.are affected by rainfall runoff, wind direction, rainfall, or freezing conditions. In severe weather conditions, it may take longer for emergency equipment and personnel to reach the site. Cleanup efforts will be more difficult as the plume of release may spread further. NOTE: As mentioned in Section II, the U.S. Department of Transportation's North American Emergency Response Guidebook (NAERG96 is the current edition) is an excellent reference book to use for developing your detailed emergency response procedures. This reference can be accessed on the Internet at http://hazmat.dot.gov/gydebook.htm A software package called "Transportation Emergency Response Information Management System" is available from GSI Computer Services, Inc., telephone 417-334-7071. For guidance on handling materials contaminated with PCB's, see "Alcoa PCB Standards" dated April 1996. There are no PCB materials on this site. V 17 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC TABLE V-1 ERG RESPONSE SCENARIO TABLE NOTE: MINIMUM PPE LEVEL IS DETERMINED BY ON -SITE SAFETY OFFICER MATERIAL AND SYSTEM ERG # (see Appendix E) (01) ACETYLENE 116 (02) CARBON DIOXIDE 120/121 (03) DIESEL FUEL 128 (04) FLAMMABLE CABINET (OIL, PAINT, THINNERS) 127 (05) GREASE (ML 792) 128 (06) HYDRAULIC OIL 128 (07) LUBRICATING OIL (ML 680) 128 (08) OIL-90W 128 (09) OXYGEN 122 (10) PARTS -CLEANER SOLVENT 127 MATERIAL AND SYSTEM ERG # (see Appendix E) (11) SULFURIC ACID 157 (12) TRANSFORMER OIL 128 (13) TRANSFORMER, HYDRAULIC & LUBE OIL 128 (14) WASTE CRANK CASE OIL FILTERS & AEROSOL CANS 128 (15) WASTE HERBICIDE RESIDUES 143 (16) WASTE MULTI -USE LUBRICANTS & GREASE 128 (17) WASTE OIL 128 (18) WASTE PAINT 127 (19) WASTE PAINT SOLVENT 127 G. OSHA EMERGENCY RESPONSE PLAN Santeetlah Personnel are trained to recognize a spill, report a spill, and provide containment. Outside vendors would provide fully trained hazardous cleanup personnel if needed. H. DISPOSAL PLANS Responding to a release will result in the generation of materials and wastes by initial responders and, possibly, cleanup contractors. These may include one or more of the following: 1. Recovered Product 2. Contaminated Soil 3. Contaminated Water 4. Contaminated Equipment and Materials (e.g. drums, shovels, valves, piping, etc.) 5. Contaminated Personal Protective Equipment 6. Spent Absorbents, including booms and pigs 7. Spent chemicals, sludge 8. Decontamination solutions 9. Medical wastes V - 18 November 2004 This information is the properly of Alcoa. It is not to be used, reproduced, or copied without. express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC TABLE V-2 DISPOSAL PLAN SUMMARY This table is required by the Corporate RPCC Guidelines. APGI-Tapoco may use these facilities or may use other facilities that are Alcoa, Inc. approved. LOCATION ALCOA RCRA PERMIT WASTE PROCESS DISPOSAL (Complete APPROVED NOJ- EPA ID MATERIAL DISPOSAL FACILITY Address SITE YES/NO NO. Non Haz Solid Containerize Cherokee Co. Andrews, NC Yes N/A Waste Landfill Landfill Non-Haz Liquid Bulk Waste Mgmt 240 Fleever Mill Yes SNL011030160 Waste Rd. Heiskell, TN Non-Haz Solid Containerize Heritage 7901 W. Morris Yes IND093219012 Transfer St. Indianapolis, IN Haz Waste Containerize Heritage 7901 W. Morris Yes IND093219012 Solid/Sludge Transfer St. Indianapolis, IN Haz Waste Containerize Reynolds Hwy 26 East Yes ARD 006 354 Solid/Bulk Arkadelphia, AR 161 Haz Waste Containerize CWM P.O. Box 55, Yes ALD 000 622 Solid/Bulk Emelle, AL 464 Medical Wastes Containerize Stericycle One Technology Not Required Not Required or Biohazard Place Materials Beaver Dam, KY The generated waste material(s) will be staged on site in suitable containers which are compatible with the waste(s). A determination will be made if the waste(s) is hazardous as defined in 40 CFR 260 and 261. If the waste(s) is determined to be hazardous, it will be managed as a hazardous waste in accordance with applicable regulations. On -site storage of hazardous wastes will be limited to less than 90 days. Santeetlah audited and approved hazardous waste transporters and TSD facilities will be utilized. If the waste is determined to be non -hazardous, it will be managed as a non- hazardous solid waste (possibly as a special waste) in accordance with applicable regulations. ALCOA audited and approved solid waste disposal facilities will be utilized. Applicable records, including manifests and certificates of disposal, is maintained on file by Santeetlah. V - 19 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission.. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC I. INCIDENT INVESTIGATION AND CRITIQUE OF EMERGENCY RESPONSE Accidents or near -accidents involving hazardous materials are investigated in accordance with Alcoa's Accident Investigation Policy which requires investigation in accordance with procedures outlined in the Major Incident Investigation Manual. These procedures are initiated within 24 hours of the incident. A major incident on Alcoa property is defined as one involving any of the following: 1, a work related fatality 2. an accident with injuries considered to be life -threatening 3. an accident with injuries resulting in hospitalization of three or more people 4. an injury -free event resulting in damage to property, equipment, or community, including but not limited to: • business interruption of a major production line • a major fire, explosion, or structural failure • a major release of any chemical considered toxic or immediately hazardous to human health • an occurrence with high potential for disabling/fatal injury. For any release which requires the activation of this RPCC Plan, an evaluation of the response actions will be conducted for the purpose of improving the RPCC Plan. Changes will be made to the RPCC Plan as needed. As soon as possible after the accidental release, a critique of the emergency response should be undertaken for the purpose of using this information to improve the RPCC plan. A blank form to use for collecting post -emergency assessment information is included in Appendix B. Applicable records, including manifests and certificates of disposal, are maintained on file by Santeetlah. V - 20 November 2004 This information is the property of Alcoa. It is not to be used, reproduced; or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/CALDERWOOD TN SECTION VI - INSPECTIONS AND RECORDS A. GENERAL OVERVIEW Several areas of the plant require periodic inspections, because of their potential for serious environmental, operational, or personal consequences in the event of a failure or malfunction. Hazardous materials and hazardous waste storage areas must be inspected for malfunctions, "operator errors, and discharges which may cause or lead to a release of hazardous waste constituents to the environment or a threat to human health. Inspections must be performed often enough to identify problems in time to correct them before they cause any damage or harm. An inspection schedule has been developed which identifies: areas and equipment to be inspected, types of problems to look for during the inspection, personnel or department responsible for the inspections, the inspection frequency, and the location of records to document inspections. The inspection frequency varies. It is based upon the rate of possible deterioration of equipment, and the probability of an environmental or human health incident if the deterioration or malfunction or operator error goes undetected between .inspections. Hazardous material/waste areas subject to releases, such as loading and unloading areas, must be inspected daily when in use. Hazardous waste regulations stipulate that hazardous waste containers, and areas where the containersare stored be inspected weekly for leaks, deterioration, corrosion and other factors. Emergency Alarm systems should be tested periodically (annually for supervised systems and every two months for unsupervised systems) for reliability and adequacy. Personnel trained in the operation of these systems shall perform testing, servicing, and maintenance. If the facility contains any PCB transformers (transformers that contain 500 ppm or greater PCB's) they must be inspected as specified in 40 CFR 761.30 (a)(1)(ix), (xii), (xiii), and (xiv). EPA regulations published in 40CFR112 require tank integrity testing for certain oil tanks based upon types of tanks. Field constructed tanks require integrity testing. Shop fabricated tanks less than 30,000 gallons which meet certain field conditions will not undergo integrity testing using non-destructive evaluation (NDE) methods but will be subject to visual inspection only based on a determination of equivalent environmental protection, as permitted in 112.7(a)(2). Fifty five gallon drums and totes are shop fabricated tanks and as such would be vI - I November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, gup rntees, or representation; expressed or o implied, are made as to the accuracy, utility or effectiveness of the methods, p products, RPCC for APGI-TAPOCO/CALDERWOOD TN subject to integrity testing using NDE methods if all sides, including the bottom are not visible or if the container is not located such that a barrier layer exists between the tank bottom and the ground so that leakage may be immediately detected and soil contamination is avoided. Tanks that provide wastewater treatment are excluded from regulation under 40CFR112. Oil containers that use oil operationally, `process,' are not required to undergo integrity testing. Therefore, for Santeetlah Powerhouse, the Professional Engineer, evaluated tanks using the following criteria: 1.0perational use of oil, `Process,' tank? 2.Wastewater treatment tank? 3.Field constructed tank? 4.Shop fabricated tank ( 55 gallon drum, tote, tank)? Less than 30,000gallons? 5.Plastic tank? 6.Does a barrier layer exist between the bottom of the tank and ground? Concrete, steel, membrane, or other? 7.Tank on a support? 8.All sides of tank, including bottom, visible? 9.Adequate secondary containment? The Professional Engineer used established industry standards and the visual results from the on site inspection of each tank to determine the inspection schedule. Each tank evaluated and classified by the Professional Engineer using the above criteria ( 1...9), is as follows: 1-1000 gallon tank at emergency generator 4,6,8,9 5- tanks ranging in size from 1000-7000 gallon in powerhouse oil room 1,6,8,9 2-100 gallon tanks turbine main floor 4,6,8,9 2-3920, and 1 —3920 spare transformers 1,4,6,8,9 All other tanks and 55 gallon drums on Table II-2 and on RPCC facility Drawing: 4,6,9 The Professional Engineer used established industry standards and the visual results from the on site inspection of each tank to determine the inspection schedule. A.3 . STANDARDS FOR INSPECTION OF SHOP ERECTED STEEL TANKS LESS THAN 30,000 GALLONS Reference STI-SP001-03, Section 4.0, Standard for Inspection of In Service Shop fabricated AST's, Steel Tank Institute, Lake Zurich, IL, 2003. VI - 2 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, -utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/CALDERWOOD TN For APGI Santeetlah tanks covered by this standard include: 1-1000 gallon tank at emergency generator 4,6,8,9 5- tanks ranging in size from 1000-7000 gallon in powerhouse oil room 1,6,8,9 2-100 gallon tanks turbine main floor 4,6,8,9 2-3920 and 1 —3920 spare transformers 1,4,6,8,9 All other tanks and 55 gallon drums on Table II-2 and on RPCC Facility Drawing: 4,6,9 rh- 4'or shop fabricated bulk oil containers ( 55 gallon drums, totes, and tanks) of 30,000 gallon capacity or less for which all sides (including the bottom) are visible (e.g. the tank is elevated on supports or grillage) or the tank is placed on a barrier and not in contact with soil, the EPA has agreed that visual testing alone will provide equivalent environmental protection. APGI contends that all tanks at Santeetlah meet this definition. 4PGI Santeetlah contends that "visual inspection" of tanks and appurtenances presented in Table VI -I is a deviation from the regulatory requirements and that visual testing alone provides equivalent environmental protection because it will permit detection of leaks or compromised container integrity in a timely fashion at least as effective as employing NDE methods. The PE certifying this Plan agrees that the inspection frequency for "visual inspection" of tanks and appurtenances presented in Table VI -I will permit detection of leaks or compromised container integrity in a timely fashion at least as effective as employing NDE methods. This facility does not have tanks that require NDE methods for tank integrity testing and shall use "visual inspection" as equivalent environmental protection. This facility has no field -constructed above ground bulk oil storage containers Inspection " VISUAL" schedule: i. Monthly inspect (if applicable)_ a. Presence of water in tank b. Interstitial zone in double wall tank C. All pipe and appurtenances ii. Quarterly inspect (if applicable) a Tank coating and exterior b. Vents for operability iii. Yearly inspect (if applicable): a. Site containment drainage b. Emergency vents; VI - 3 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission.Nowarantsproducts, guor arantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, RPCC for APGI-TAPOCO/CALDERWOOD TN C. Tank supports; d. Foundation; e. Cathodic protection system FUTURE STANDARDS FOR INTEGRITY TESTING: Should APGI Santeetlah place in service tanks which require integrity testing, then this RPCC plan shall be revised and the Certifying P.E. shall specify integrity testing methods and time tables that meet the most current professional standards. The revisions to the oil spill regulations, effective July 2002, received another extension. EPA published the extension in the Federal Register on 2004 August 11, volume 69, number 154, pages 48794-48799. The new compliance dates are: Amend SPCC Plan 2006 February 17 Implement SPCC Plan 2006 August 18 B. INSPECTION SCHEDULE Table VI-1 includes a listing of those plant -site facilities that have been identified as requiring periodic, detailed inspections. These facilities were selected because of their potential for serious safety or environmental consequences in the event of a failure or malfunction. VI - 4 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/CALDERWOOD TIN TABLE VI-1: INSPECTION SCHEDULES AREA/EQUIPMENT INSPECTION ITEMS FREQUENCY INSPECTION RESPONSIBILITY REFERENCE DOCUMENTS Above Ground Tanks: - Tank Leakage Monthly APGI Cheoah Records kept at Cheoah -Tank Quarterly Q Y Shop fabricated and Corrosion Annual less than 30,000 gallons - Filled Visual only. 1-1000 gallon - Foundation tank at Failure - Improper emergency Valve, generator Fittings or 4,6,8,9 Piping 5- tanks - Corrosion/ ranging in size Deflection from 1000-7000 - Valves gallon in Unlocked powerhouse oil or Line Caps room 1,6,8,9 Missing 2-100 gallon - Alarms orLeakmain tanks turbine floor Detectors 4,920 Malfunctioning 2 ,and 1 _Evidence of —3920 spare Tampering transformers 1,4,6,8,9 Foundation All other tanks Failure and 55 gallon - Rainwater/ drums on Table Debris 11-2 and on in Diked Area RPCC Facility -Volume of Drawing:4,6,9 rainwater released - Drainage Valves Open - Lighting Inadequate - Evidence of Tampering VI 5 November 210104 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made astothe accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/CALDERWOOD TN Emergency Response Equipment: Oil Drums/Totes Plant Wide - Missing Inventory - Exceedance of Shelf Life - Equipment Non Operational - Incorrect Access Time - Evidence of Tampering - Indiscriminate Drums/Totes - Unidentified Drums/Totes - Leaking/ Spillage - Corrosion/ Cracks - Bulges - Inadequately Secured - Leaking Spigots - No Secondary Containment Area - Stacked Improperly Monthly Daily - If outdoors and not secondarily contained. Monthly, quarterly, annually if secondarily contained or meets the conditions of RPCC Sect. 3 APGI Cheoah APGI Cheoah Records kept at Cheoah Records kept at Cheoah VI - 6 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/CALDERWOOD TN AREA/EQUIPMENT INSPECTION FREQUENCY INSPECTION REFERENCE ITEMS RESPONSIBILITY DOCUMENTS Tank/Car/Truck Daily when in APGI Cheoah Records kept at Cheoah "OUTSIDE" Follow SOP use and not Loading/Unloading (Standard secondarily Areas: Operating contained Procedure for each area.. See Diesel fuel and lube RPCC Section When oils III-D for secondarily guidance. contained, minimum of monthly inspections. Hazardous Waste - Indiscriminate Weekly APGI Cheoah Records kept at Cheoah Storage: Drums/Totes Bldg - Unidentified Drums/Totes - Leaking/ Spillage - Corrosion/ Cracks -Bulges - Inadequately Secured - Leaking Spigots - No Secondary Containment Area - Stacked Improperly vl - 7 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/CALDERWOOD TN Major Oil Filled Electrical Equipment and Operations Subject to Spills/Leaks: Plant Wide - Spillage/ Leakage - Missing Labels - Oil/Rainwater/ Debris - Accumulation in Secondary Containment Malfunctioning Containment Drainage Valves - Evidence of Tampering Monthly I APGI Cheoah I Records kept at Cheoah See RPCC Facilities Drawing in Appendix H. C. EXAMPLE INSPECTION FORMS Examples of inspection forms that are used at this location are included in RPCC, Appendix A. D. RECORDKEEPING Inspection forms shall be kept on file for five years. PCB- related inspection log reports should also be kept for five years after the last report is required. Example inspection log reports are included in RPCC, Appendix A. VI - 8 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures.. RPCC for APGI-TAPOCO/CALDERWOOD TN SECTION VII - PERSONNEL TRAINING A. TRAINING OVERVIEW Personnel handling chemicals or who are involved in environmental protection and product safety activities at this facility receive training in the safe handling of oils, hazardous substances/wastes and spill and release prevention and response (as described in [include all applicable regulations] 40 CFR, Section 265.16 of RCRA; 40 CFR, Section 112.7 of CWA; 29 CFR, Section 1910.119 of OSHA; 40 CFR, Section 68.30 of CAA; 49 CFR, Section 172.700 of HMTA), and emergency action or emergency response (as described in 29 CFR, Section 1910.38 or Section 1910.120 of OSHA), and as required by their assigned jobs. This training covers site -specific information including implementation of the facility's RPCC plan. All new personnel receive appropriate training within one month of the date that they are hired. Likewise, personnel who transfer to new jobs which involve these responsibilities receive appropriate additional training within 1 month of the date of transfer. Everyone who works in an unsupervised position involving hazardous substances receives appropriate training initially. All of these personnel are retrained annual) B. TRAINING PROGRAMS 1. Training Requirements Minimum training requirements are determined by the waste handling/disposal classification of the facility, process safety requirements, and the responsibilities of plant personnel during emergency situations. a. RCRA — NOT APPLICABLE AT APGI-TAPOCO's SANTEETLAH FACILITY b. OSHA Hazard Communication Employees who may be exposed to hazardous chemicals under conditions of normal use or foreseeable emergency must be trained in accordance with the OSHA Hazard Communication Standard (29 CFR 1910.1200), which includes the following: • Operations in the work area where hazardous chemicals are present • Location and availability of written hazard communication plan and material safety data sheets (MSDS) • Methods and observations that can be used to detect the presence or release of a hazardous chemical (e.g., monitoring devices, visual appearance or odor of hazardous chemical when released) • Physical and health hazards of chemicals in the work area • Measures employees may take to protect themselves from chemical hazards (e.g., work practices, emergency procedures, personal protective equipment) VII - 1 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. Nowarranties, .guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/CALDERWOOD TN • Details of the written hazard communication plan, including explanation of the labeling system and the MSDS. c. OSHA Process Safety Management NOT APPLICABLE AT APGI-TAPOCO's SANTEETLAH FACILITY d. OSHA Emergency Action Plan - If all employees are evacuated from the danger area when an emergency occurs, and no employees are permitted to assist in emergency response actions, then minimum training per OSHA 1910.38 should include the following: • fire hazards and other hazards associated with materials and processes that may be encountered • hazard identification and awareness • notification of appropriate persons • the plant's signal for evacuation • emergency shutdown procedures • evacuation routes and regrouping areas • method for accounting for evacuated personnel • rescue and medical duties of those employees assigned to perform them • procedures to be followed by those personnel who must remain after - initial evacuation signal to attend to critical plant operations before evacuating. To assess effectiveness of the Plan, live drills should be conducted at least annually. Integrated emergency response drills incorporating plant -designated emergency medical responders, when applicable, should be conducted. e. OSHA Emergency Response Plan ("Hazwoper" 1910.120) Employees who will participate in emergency response must be trained in accordance with their assigned duties and responsibilities in the response action. The various levels of training in order of increasing levels of responsibility are as follows: "First Responder Awareness Level," "First Responder Operations Level," "Hazardous Materials Technician," "Hazardous Materials Specialist," and "On -Scene Incident Commander." It is suggested that all members of a hazardous materials response team receive minimum training equal to "First Responder Operations Level. " Other members of the response team should receive additional training depending on their technical and/or leadership duties. Training topics for the "First Responder Operations Level" include the following: • fire hazards and other hazards associated with materials and processes that may be encountered • hazard identification and awareness VII - 2 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/CALDERWOOD TN • notification of appropriate persons • site security and control • emergency response procedures (DOT Emergency Response Guidebook) • selection and use of appropriate personal protective equipment, including respirators • basic hazard and risk assessment techniques • basic hazardous materials terms • basic decontamination procedures • basic control, containment, and/or confinement operations within capabilities of personnel and equipment available • standard operating procedures for hazardous materials emergency response. f. DOT Hazardous Materials Transportation For employees involved in loading, unloading, handling, or preparing for transportation of hazardous materials as defined in 49 CFR 171; or employees who operate a vehicle used to transport hazardous materials; or employees responsible for the safety of hazardous materials transportation, mandatory training must include the following (NOTE: Certification under OSHA 1910.120 might fulfill these training requirements): • Awareness/familiarity with the requirements of DOT 172 Subpart G, Emergency Response • Hazard recognition • Immediate hazards to health • Risks of fire or explosion • Immediate precautions to be taken in event of accident or release • Immediate methods of handling small or large fires • Initial methods of handling spills or leaks in absence of fire • Preliminary first aid Methods to avoid accidents (e.g., proper handling of containers). g. CAA Risk Management Program NOT APPLICABLE AT APGI-TAPOCO's SANTEETLAH FACILITY h. Storm Water Pollution Prevention Plan A separate SWPPP is not required. This RPCC serves as the SWPP Plan. L Oil Spill Prevention Control and Countermeasures Plan Oil -handling personnel must be trained annually on the following topics: • Operation and maintenance of equipment to prevent discharges • Discharge procedure protocols • Applicable pollution control laws, rules, regulations vii - 3 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or. implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/CALDERWOOD TN General facility operations S Contents of facility RPCC Plan including description of previous discharges of oil or near discharges, malfunctioning components, and any recently developed precautionary measures. 2. Specific Plant Training Programs SEE TABLE VII-1 VII - 4 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. ccp 0 _C O O O cz cz JY I—r F a � T T 0 ItE Q Q � C3 O > Occ i L\ m (CL W `+ Qz z a I= ci F— LL O cz c cz cz a a) a) m m a� — cn cn Uj C!1 O cn Cn O � i-+ >1 co cz cz cz cn cn O O O 0 a) cn O c 00 m O p C 0 O-0 cz N p a) N> �' _� cz � o N cn (Z O 0 n- i o 0 cz a) C a) -0 a� o cn Q) ctt >+ cn o cn O cn j, a) o a) C i i p E C: c OLn in m 1- C Q coO c i 0-a)(D 0) i Q :� w a a) w0- Q w� �' ��t= w° w 0 iU a> cz cz 0 co 0 z i_ Q Q Q Q Q m Q ^, W Wcn r Y 0 CZ N ��//� V/ 0-0 0 L �}� 0 0 OU L O p ( V 1 - -o Q cn C G c- T a cn (DN O O N Ci O 'O YO o �= E�0 ��o� DO C: o Ecn-0 a>0)o 0) a) c} a'�.�cn �i C a) c C O 0) .� E Cl) 0 _ I (D i O 1 2 O 0 0 Q 0 C� _0 cz U U F O> N a) U cn E O co co Q> O> Q Q (ti cz Q. W Lu W n G 0 O cz "0 a) '0n, W 1 N C �E U TT °T° a'Q� Cm GaD0O U 4) c O cz 0-O czm Q E m O = E a cis uJ rr F— U (n 0 (n uJ OC 2 U OC m m E a E 2� LO 0 3 a O N z N O 6 N RPCC for APGI-TAPOCO/SANTEETLAH NC C. TRAINING PROGRAM OUTLINES Below are two course outlines Santeetlah/Cheoah facility. for training programs performed at the HAZARD COMMUNICATION TRAINING A. History of Hazard Communication Standard B. History of Determination C. Materials Covered by Hazard Communication and Exemptions - Site Specific D. Types of Hazards/Spill Response E. Labels and Other Forms of Warning F. Material Safety Data Sheets G. Employee Information and Training ENTERING AND WORKING IN CONFINED SPACES A. Entering and Working in Confined Spaces Standards B. Entry Procedures C. Employee Protection D. Personal Protective Equipment D. FACILITY RESPONSE TRAINING AND DRILLS Not applicable to the Santeetlah facility. E. TRAINING RECORDS Sample training records are included in Appendix B. Training records are held in the Cheoah Power Facility Main Office, and will be kept on file until closure of this facility. VII - 6 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC SECTION VIII STORM WATER POLLUTION PREVENTION PLANS NOT APPLICABLE At this time, APGI-TAPOCO's Santeetlah Power Facility does not have a separate Storm Water Pollution Prevention Plan. This RPCC serves as the Storm Water Pollution Prevention Plan. VIII - 1 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC SECTION IX - OPA DISCHARGE AND RESPONSE SCENARIOS NOT APPLICABLE APGI-TAPOCO's Santeetlah is not a facility covered under the Oil Pollution Act of 1990 (OPA). Although this facility is not an OPA facility, the CERTIFICATION OF SUBSTANTIAL HARM in Appendix <B must be signed. IX-1 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC APPENDIX A INSPECTION FORMS Examples based upon corporate forms are included The purpose of the inspection program is focused upon finding and correcting leaks or identifying potential leaks The focus of the program is upon tanks, totes, drums, lines, and load/unload areas that are outside buildings and have a potential for release to the environment APP-1 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. 0 Assigned Area Safety Department -Power Inspection Checklist Area- Santeetlah P.H. Period Supervisor Checked By - Items that require inspection Conditions to Look for Inspection Results & Date Generator Floor House Keeping Cluttered Fire Hose Unsound, Nozzle Missing No. 2 Lubricating Oil Pump Leaking Guards around Generator Buss Missing, Damaged Governor Actuator Cabinets Oil leaking Crane Control Cabinets Doors Open, Damaged Crane Access Ladder Damaged Warning Signs Missing, Deteriorated Generator Hand Rails Unsound, Damaged Machine Guards Missing, Damaged Control Room House Keeping Cluttered Electrical Panel Doors Open Warning Signs Missing Parts Washing Station Lighting Out Wiring Unsound, Exposed Liquid Container q Leaking, Damaged 9 9 Lid Open Turbine Floor Stairs Treads Unsound Handrails Unsound Governor Systems Governor Pump Guards Missing, Damaged Hydraulic system Leaking Pressure Guages Non -Functional Brake Air Compressor Guards Loose, Missing, Damaged Relief Valve Non -Functional Pressure Guages Non -Functional Tank Unsound Station Air Compressor Guards Relief Valve Loose, Missing, Damaged Pressure Guages Non -Functional Tank Non -Functional Unsound Carbon Dioxide System Cylinders Unsound, Discharged lose and Piping Unsound Record the inspection findings and date. M-Maintenance. R-Repair or Replace, K-Clean-Up, S-Satisfactory Page 1 Items that require inspection Conditions to look for Inspection Results&Date Turbine Floor Battery Room Lighting Wiring Racks Out Exposed Unstable Flame Guards Missing, Broken No Smoking Signs Cells Missing, Obscured Leaking Goggles Face Shield Missing, Deteriorated Missing, Deteriorated Boots Missing, Deteriorated Apron Eye Wash Station Baking Soda Missing, Deteriorated Missing, Depleted, Out of Date Missing, Depleted Oil Room Tanks Leaking Containers Leaking, Labels Missing Walking Surface Lighting Slippery Out Generator Wheel Pits Lighting Walking Surface Warning Signs Machine Guards Grease System Out Slippery Missing, Deteriorated Missing, Damaged Leaking, Broken Generator Bearing Oil Sumps Tanks Leaking Piping Leaking, Unsound Runner Tunnel Station Sump Pump Wiring Float Unsound Non -Functional Guards Missing, Damaged Grating Missing, Damaged Record the results of Inspections. M-Maintenance, R-Replace or Repair, K-Clean-Up, S-Satisfactory Page 2 or Items that require inspection Conditions to Inspect for Inspection Results & Date Powerhouse Outside Transformer Deck Stairs Unsound Handrails Unsound Confined Space Warning Signs Missing, Deteriorated Warning Signs Missing, Deteriorated Electrical Guards Missing, Damaged Grounds Fencing Unsound Gates Un-operable Guard Railing Missing, Damaged Emergency MG Set Exhaust System Unsound Fuel System Leaking, Low Level Guards Loose, Missing, Damaged Wiring Unsound, Exposed Batteries Leaking Butler Building Housekeeping Cluttered Flamable Storage Cabinet Containers Leaking, Doors Open Lighting Out Hazardous Storage Building Doors Unlocked Ventilation Blocked Roof Leaking 161 KV Substation Fencing Damaged Equipment Identifaction Tags Missing, Deteriorated Warning Signs Missing, Deteriorated Equipment Unlocked Surge Tank Area Emergency MG Set Exhaust System Unsound Fuel System Leaking, Low Level Guards Loose, Missing, Damaged Wiring Unsound, Exposed Batteries Leaking Airconditioner Non -Functional Record Inspection Results., M-Maintenance, R-Replace or Repair, K-Clean-Up, S-Satisfactory Page 3 Items that require inspection Conditions to Inspect for Inspection Results&Date Dow Valve Operators Guards Loose, Missing, Damaged Access Doors Open Wiring Exposed, Unsound Grounds Fencing Unsound Gate Unlocked, Damaged Lighting Out Access Road Caving In Yard Sunken Areas r Record Inspection Results, M-Maintenance, R-Repair or Replace, K-Clean-Up, S-Satisfactory Page 4 Alcoa Power Generating Inc. Tapoco Division Santeetlah Powerhouse Daily Inspection RPCC Plan 1� Week Beginning Transformer Bank I Transformer 1 'Transformer 2 Transformer Bank 2 Transformer 2 Station Service Transformer . �■_-■__■�_ Oil- Storage Tank . RPCC for APGI-TAPOCO/SANTEETLAH NC APPENDIX B Reports and Records Primary Forms 1. RPCC Review Log 2. Environmental Excursion or Event (Triple E) Report 3. Release Incident Report 4. Containment Drainage Form 5. Emergency Response Critique Form 6. Certification of the Applicability of the Substantial Harm Criteria Supplemental Forms (corporate guidance) 7. Extremely Toxic and Hazardous Substances Release Notification 8. Hazardous Materials Release Notification 9. Oil Spill Response Notification 10. Wastewater Excursion Notification Emergency Response Training Record - not included, maintained electronically Hazardous Materials Incident Report (DOT Form 5800.1 - 6/89) - not included APP-2 November 2004 This information is the propertypl implied, It is not as to the accurracytlutil utility orreffecedveniess of thermethods,'processes produclts, or procedures. tr representation, expressed or RPCC for APGI-TAPOCO/SANTEETLAH NC SANTEETLAH RPCC Team Annual Review Record Reviewed by IIIII Date III Comments Based on this review of the RPCC Plan for Santeetlah, we [wilil or [will notl amend the Plan. Signature: Date: Reviewed by Date Comments Based on this review of the RPCC Plan for Santeetlah, we {wild or [will notl amend the Plan. Signature: Date: Reviewed by Date= Comments Based on this review of the RPCC Plan for Santeetlah, we [will] or [will notl amend the Plan. Signature: Date: APP-3 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. actions? What caused or influenced above contributing conditions? kicoa, inc. Tennessee Operations form #: EEE Revision 1/04 ENVIRONMENTAL €XCURSION OR EV�k� [TRIPLE �s REPORT ���o� Please npe or print. Fill oat all shaded areas. if a section does not apply, then Mark "NA." Description of Excursion or Event What caused or influenced above contributii Release Incident Report Aluminum Company of America - Tennessee Operations Blount County, Tennessee Case Numbers: ALCOA # National Response Center # Facility: Santeelah Facility Address: 300 North Hall Road, Alcoa, TN 37701-2516 Mailing Address: 300 North Hall Road, Alcoa, TN 37701-2516 Phone Number: (865) 977-2011 (Switchboard) Plant Contact: Stephanie R. Sparkman Phone Number: (865) 977-3671 Release Information Summary Location: Date of Release: Person Reported: Time Reported: Material Released: Quantity Released: Hazardous Materials: Time of Release: Dept.: Arrival On -site: 2911 Plant Protection Environmental Affairs HazMat Team (City of Alcoa) Emergency Response Contractor Environmental Media Impacted: (check all applicable) Water Releases: Quantity Outfall # Duration: Reportable Quantities: Water Soil Receiving Stream Air Mile Page 1 of 3 Wastes Generated: Quantity On -site Disposal: Location Off -site disposal: Transporter Name Cause of Release: Containment and Cleanup Actions: D — Manifest Number Environmental Personnel On -site: Department Responsible: Contact Person: Regulatory Notifications: Telephone (800) 424-8802 (404) 562-8700 (800) 262-3300 (865) 594-6035 National Response Center EPA Region IV TN Emergency ManagementAssoc. TN Div. of Water Pollution Control TN Div. of Air Pollution Control (865) 594-6035 (865) 594-6035 TN Div. of Solid Waste Management (865) 982-4210 Blount Co. Management Agency City of Alcoa HazMat 9-911 Notes: Contact Name Date/Time Page 2 of 3 (attach additional pages as necessary) Signature of Reporter: Name Title Date Page 3 of 3 Containment Drainage Log Location: * Estimate gallons discharged Release Prevention, Control & Countermeasures Plan Manual; Example Reports and Records Effective Date: 10/95 -- Saros Library I.D. #961220002 EMERGENCY RESPONSE CRITIQUE Prepared by: Date of Event: Signature: Date of Critique: DESCRIBE THE EMERGENCY INCIDENT: INDIVIDUALS/GROUPS INVOLVED: EVENT BY EVENT SUMMARY OF THE EMERGENCY RESPONSE PROCEDURES: WHAT WENT WRONG? RECOMMENDATIONS: This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. Page 2 of 14 RPCC for APGI-TAPOCO/SANTEETLAH NC Certification of the Applicability of the Substantial Harm Criteria Instructions Complete this section if your facility is subject to SPCC requirements. You are subject to these requirements if any of the following conditions apply: • oil storage capacity in underground storage tanks of more than 42,000 gallons (except oil storage tanks subject to all technical requirements of RCRA 280 or State programs under RCRA 281)or • oil storage capacity in above ground tanks with a total aggregate capacity of more than 1,320 gallons, counting only containers of 55 gallon capacity or greater (including equipment that uses oil "operationally") or • PCB liquid storage pending disposal under certain storage conditions specified in 40 CFR 761.65(c)(1)(iv) or 40 CFR 761.65(c)(7)(i). • Answer questions #1 through #5 on the form on the next page. • If you answer "NO" to ALL questions, you do not need to submit a Facility Response Plan. Sign the "Certification of the Applicability of the Substantial Harm Criteria" form, and include the signed copy in Appendix B of your Plan. The person signing this certification should be one of the individuals signing in Section I.C. of your Plan. • If you answer "YES" to ANY of questions #1 through #5, you must prepare and submit a Facility Response Plan to EPA. Refer to the RCT for applicable sections of the Outline. If you have total oil storage capacity of 1 million gallons or more and you use an alternative formula comparable to the one in the regulations (Part 112 Appendix C) to evaluate substantial harm criteria in questions #3 and #4, you must notify the Regional Administrator of EPA that an alternative formula was used. Sign the "Certification of the Applicability of the Substantial Harm Criteria" form, and include the signed copy in Appendix B of your Plan. The person signing this certification should be one of the individuals signing in Section I.C. of your Plan. Document your calculations that demonstrate the reliability and analytical soundness of the alternative formula in Appendix J of your Plan. APP-4 November 2004 This information is the property of. Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCOISANTEETLAH NC Certification of the Applicability of the Substantial Harm Criteria (From Appendix C to 40 CFR 112) Facility Name: APGI TAPOCO- SANTEETLAH Powerhouse Facility Address: SANTEETLAH, NC 1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons? Yes No _X- 2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation within any aboveground oil storage tank area? Yes No _X— 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 (as calculated using the appropriate formula in Attachment C-III to this appendix or a comparable formula 111) such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? For further description of fish and wildlife and sensitive environments, see Appendices I, II, and III to DOC/NOAA's "Guidance for Facility and Vessel. Response Plans: Fish and Wildlife and Sensitive Environments" (see Appendix E to this part, section 13, for availability) and the applicable Area Contingency Plan. Yes No —X- 4. 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 (as calculated using the appropriate formula in Attachment C-111 to this appendix or a comparable formula {1)) such that a discharge from the facility would shut down a public drinking water intake {2)? Yes No —X— 5. 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 discharge in an amount greater than or equal to 10,000 gallons within the last 5 years? Yes No _X— Certification I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate, and ,complete. a -- Date / Zz Signatur a6 Name: (please type or print) Walter Brockway Title: APGI — Hydro Systems Operations Manager {1) If a comparable formula is used documentation of the reliability and analytical soundness of the comparable formula must be attached to this form. {2) For the purposes of 40 CFR part 112, public drinking water intakes are analogous to public water systems as described at 40 CFR 143.2(c). APP-5 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. Release Prevention, Control & Countermeasures Plan Manual; Example Reports and Records Effective Date: 1 o/95 -- Saros Library I.D. #961220002 EXTREMELY TOXIC AND HAZARDOUS SUBSTANCES RELEASE NOTIFICATION 40 CFR 355.40(b) Reporter's Last Name First M.I. Telephone Number(s) Company Organization Type Position Address City State Zip Incident Description "1 +nrinl Chemical Name or Description Reportable Quantity Quantity Released Unit/ Measure EHS?* CAS Number ... wn r-CM 13 A. '2r.r, * Indicate if released material is iisteci as an extrenteiy 11QLC11 tjuJ Ju ✓JIH..+ ... -� —• •- - - --- Appendix A or Appendix B This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. Page 8 of 14 Release Prevention, Control & Countermeasures Plan Manual: Example Reports and Records Effective Date: 10/95 -- Saros Library I.D. #961220002 - -- Extremely Toxic and Hazardous Substance Release Notification Page 1 of 2 Response Action Actions taken to correct, control, or mitigate incident: Impact Number of Injuries Number of Deaths Were there Evacuations? Yes No Number Evacuated Known or Anticipated Acute Health Risks Known or Anticipated Chronic Health Risks Advice Regarding Medical Attention for Exposed Persons Medium Affected Description More Information about Medium Additional Information Anv information about the incident not recorded elsewhere in the re Caller Notifications NRC Yes No USCG Yes No Community Agency Yes No EPA Yes No State Yes No Other (Describe) Extremely Toxic and Hazardous Substance Release Notification Page 2 of 2 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. Page 9 of 14 Release Prevention, Control & Countermeasures Plan Manual; Example Reports and Records Grra�e, o n.fo 1nf4s __ Sams Library LD. #961220002 HAZARDOUS MATERIALS RELEASE NOTIFICATION Use for: Hazardous Waste , PCB's, Hazardous Substances 40 CFR 302.6, and Excess Air Emissions 40 CFR 61.65 Reporter's Last Name First M.I. Telephone Number(s) Company Organization Type Position Address City State Zip Incident Description Source and/or Cause of Incident Date [Time of Incident: Year Month Day Time of Incident Duration of Release: Location of Incident: Material CAS or Waste Number Chemical Name or Description Reportable Quantity Quantity Released Unit/ Measure Hazardous Materials Release Notification Page 1 of 2 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or 4 o effectiveness of the methods, processes, products, or procedures. w Release Prevention, Control & Countermeasures Plan Manual; Example Reports and Records Effective Date: 10/95 -- Saros Library I.D. #961220002 Impact Number of Injuries Number of Deaths Were there Evacuations? Yes No Number Evacuated Possible Hazards to Health and Environment Outside of the Facilitv Medium Affected Description Response Action Actions taken to correct, control, or mitigate incident: Remedial Action Remedial action taken or planned to minimize environmental damage: Estimated quantity and disposition of material recovered from incident: Caller Notifications NRC Yes No. USCG Yes No State Yes No EPA Yes No Local Yes No Other (Describe) Under TSCA, report spills of 10 pounds or more of materials containing PCB at concentrations greater than 50 ppm to EPA Regional Office. Under CERCLA, report to the National Response Center spills of materials containing PCB when the amount of pure PCB contained in the mixture exceeds one pound. Hazardous Materials Release Notification Page 2 of 2 i his mtormation is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. Page 5 of 14 Release Prevention, Control & Countermeasures Plan Manual, Example Reports and Records Effective Date: 10/95 — Saros Library I.D. #961220002 OIL SPILL RESPONSE NOTIFICATION Reporter's Last Name First M.I. Telephone Number(s) Company Organization Type Position Address City State Zip Were Materials Released? Yes No Confidential Yes No Meeting Federal Obligations to Report Yes No Date Called? Calling for Responsible Party Yes No Time Called? Incident Description Source and/or Cause of Incident Date: Year Month Day Time of Incident AM PM Incident Address/Location Nearest City State County in Distance from City Units Direction from City Section Township Range Container Type Tank Capacity Units Facility Capacity Units Facility Latitude Degrees Minutes Seconds Facility Longitude Degrees Minutes Seconds V II �t. m 1 1C.. Jt1ll - I ry 11 -1- 1 I -yJ- i - - This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, of representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. Page 6 of 14 Release Prevention, Control & Countermeasures Plan Manual; Example Reports and Records Effective Date: 10/95 -- 5aros Library I.D. 4961220002 Material CHRIS Code * Total Quantity Released Unit of Measure Name of Material Released Quantity Entering Water Unit/ Measure - w .Wl twill 1-0 n0401u_RCaNu11ar unurmauun Jysiem, u,J. uoast Vuard Response Action Actions taken to correct, control, or mitigate incident: Impact Number of Injuries Number of Deaths Were there`Evacuations? Yes No Number Evacuated Was there any Damages? Yes No Damage in Dollars (approx.) Medium Affected Description More Information about Medium Additional Information Any information about the incident not recorded elsewhere in the report? Caller Notifications NRC Yes No USCG Yes No State Yes No EPA Yes No Local Yes No Other (Describe) vtf apill response Notlticatlon Page 2 of 2 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. Page 7 of 14 Release Prevention, Control & Countermeasures Plan Manual; Example Reports and Records Effective Date: 10/95 — Saros Library I.D. #961220002 - WASTEWATER EXCURSION NOTIFICATION 40 CFR 122.41(i)(6) Reporter's Last Name First M•l• Telephone Number(s) Company Organization Type Position Address City State Zip Excursion Description NPDES/SPDES Permit No.: Parameter for which effluent limitation exceeded: Describe unanticipated bypass: I Describe upset condition: Describe conditions causing maximum discharqe limitation to be exceeded: [DatelTime of Excursion: Year Month Day Time Wastewater Excursion Notification Page 1 of 2 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, of representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. Page 13 of 14 Release Prevention, Control & Countermeasures Plan Manual; Example Reports and Records Effective Date: 10/95 -- Saros Library]. D. #961220002 Response Action Actions taken to correct, control, or mitigate excursion: duration of noncompliance: Additional Information Any information about the incident not recorded elsewhere in the resort? Caller Notifications EPA Yes No State Yes No Other (Describe) Wastewater Excursion Notification Page 2 of 2 i nis inrormauon is ine property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. Page 14 of 14 RPCC for APGI-TAPOCO/SANTEETLAH NC APPENDIX C AGREEMENTS AND CONTRACTS HEPACO Letters to Local Emergency Response Committee, Fire and Police Departments APP-6 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. EMERGENCY RESPONSE CONTRACT NO. AT-002006-SR Vendor No. ALCOA, TN. December 3, 2002 Contract entered into by and between: A. HEPACO, INC. 279 Shipley Ferry Road Blountville, TN. 37617 a North Carolina corporation (herein called "Contractor" or "Seller") and ALCOA INC. 2300 NORTH WRIGHT ROAD ALCOA, TN. 37707-3141 a Pennsylvania corporation (herein called "Company") The parties hereto agree as follows: SECTION I. STATEMENT OF WORK. Contractor shall complete, and shall furnish all supervision, construction management, labor, materials, tools, equipment, loading, unloading, hauling, taxes, insurance, fees, permits, and other things necessary for the completion of Emergency Response Services as may be requested by Company's Environmental or Procurement contact at Company's Alcoa, Tennessee Operations, as herein specified (herein called the "Work"). SECTION 11. CONTRACT DOCUMENTS. Work shall be performed in accordance with this Contract and the following documents, all of which are made a part hereof (herein collectively called the "Contract"): A. Terms and Conditions for Environmental Remediation Contracts, Pages 1 through 19, revised 12/01 (herein called the "General Terms and Conditions"). (Attached) B. Site Conditions for Alcoa, Tennessee Operations, revised Feb. 2002. (On disk) C. Aluminum Company of America's Corporate Policy on Substance Abuse, Form SF-6350. (Attached) CSR Page 1 of 4 EMERGENCY RESPONSE CONTRACT NO. AT-002006-SR D. Alcoa Engineering Standard for Lockout Tag out, 18.3 (On disk) E. Alcoa Engineering Standard for Confined Space Entry, 18.1.2 (on disk) F. Alcoa Engineering Standard for Fall Control, 18.2.1 (On disk) G. Contracted Services Safety Prequalification Questionnaire, 33.055.1, dated November, 1999. H. Hepaco Emergency Response Rates for Equipment and Labor, Form # 101, Revision 8, dated July18, 2002. SECTION III. SPECIAL AGREEMENTS. A. Contractor agrees that it, its representatives, employees, invitees or subcontractors, while performing work for the Company, shall adhere to the Company's Environmental Policy, which states in part, that:"It is Alcoa's policy to operate worldwide in a manner which protects the environment and the health of our employees and of the citizens of the communities where we have an impact." The Contractor's responsibility is to comply with all applicable environmental laws, regulations and permits, and will employ more restrictive internal standards where necessary to conform to the above policy. B. The Contractor shall pre -qualify subcontractors and material suppliers using a reasonable financial and safety pre -qualification process, in accordance with Alcoa Engineering Standard 33.055.1. Contractor must receive written approval from Company before soliciting bids and/or awarding contracts to any major subcontractors or material suppliers. Major subcontractors and suppliers shall be identified during the initial phase of the project. C. All scrap materials and debris generated during the performance of the Work shall be promptly removed from the site and disposed of by the Seller. At no time shall debris be cause for a safety or fire hazard as defined by local, state or federal standards. All hazardous material or debris generated during the performance of the work will be disposed of at a facility audited and approved by Alcoa Inc. CSR Page 2 of 4 EMERGENCY RESPONSE CONTRACT NO. AT-002006-SR SECTION IV. SCHEDULE. Contractor agrees that the Work governed by this Contract will be released by separate Purchase Order, which will reference the terms and conditions of this Contract and a specific Scope of Work. No invoices will be processed against this Contract. This Contract will remain in effect until cancelled. SECTION V. COMPENSATION. Company will pay Contractor for the performance of the Contract in accordance with the Contractor's Rate Sheet and the terms of the Purchase Order. For Emergency Response activities, identified as such at the time of contact by Alcoa Inc's authorized representative, the Emergency Response Rates will be utilized For non -emergency response activities identified at the time of contact by Alcoa Inc's authorized representative, general Industrial Cleaning rates will be utilized. SECTION VI. SOLE AGREEMENT. The Contract constitutes the entire agreement between Contractor and Company and shall be governed by the laws of the Commonwealth of Pennsylvania. CSR Page 3 of 4 EMERGENCY RESPONSE CONTRACT NO. AT-002006-SR IN WITNESS WHEREOF, the parties have caused the Contract to be executed, in duplicate, as of the date first above written. WITNESS: Hepaco, Inc. B C�. y Typed Typed Name: Tracy Feathers Name: William D C'c�r�nn WITNESS: ALCOA, INC. By Title: Staff Buyer CSR Page 4 of 4 RPCC for APGI-TAPOCO/SANTEETLAH NC APPENDIX D REPORTABLE QUANTITIES SANTEETLAH POWERHOUSE HAZARDOUS SUBSTANCES RQ's 40CFR117 Table 117.3 Hazardous Substances Reportable Quantity Oils-Cutting/Hydraulic/Used Oil/Fuels-Gas, Diesel ... Visible Sheen on Navigable Waters APP-7 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC APPENDIX E MATERIAL SAFETY DATA SHEETS (MSDS) EMERGENCY RESPONSE GUIDES (ERGs) See Table V-1 for ERG vs. Chemical "MSDS books are located in the following location: ADMINISTRATION OFFICE ONSITE and available through Alcoa Intranet Web Site APP-8 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO(SANTEETLAH NC APPENDIX F EMERGENCY RESPONSE PROCEDURES FOR SELECTED MATERIALS SEE SECTION V-F 1994 EMERGENCY PROCEDURES PLAN APP-9 November 2004 This information is the property mpl implied, It is not as to the accuracry,dutlley, orreffectivveness of term thods,'prroces es products, or procedures.r representation, expressed or EMERGENCY PROCEDURES PLAN TAPOCO, INC. CHEOAH AND SANTEETLAH HYDROELECTRIC FACILITIES JANUARY 1994 Prepared by inc. Qconsulting engineers and environmental scientists PLAZA 1, SUITE 410 • 220 ATHENS WAY • NASHVILLE, TENNESSEE 37228 s industry\tapoco\epp-nc.doc 1 OUTSIDE EMERGENCY AGENCIES The Emergency Coordinator shall contact outside Emergency Agencies as necessary to help in an emergency, the following is a listing: ALCOA Tennessee Operations (Dave Fugate) 615-977-2328 ................................................. ..........................................................................................(home) (615) 856-3257 BlountCounty Local Emergency Planning Committee....................................................... Dave Fugate - ALCOA......................................................................... 615-977-2328 Paul R. Hicks - Blount Co. Civil Defense ...................................................... 615-982-4210 Cheoah Powerhouse Control Room.............................................................704-498-2217 Cheoah Powerhouse Main Office............................................................... 704-498-2221 Santeetlah Powerhouse Control Room.......................................................... 704-498-2354 Calderwood Powerhouse Control Room. ....................................................... 615-977-2199 ....................... . . ........................................................................ or 615-856-2346 _..' Calderwood Powerhouse Main Office.......................................................... 615-977-2101 I .......................... or 615-856-2342 ...................................................................... Graham County Ambulance Service............................................................704-479-8342 Graham County (24 hr) Emergency Management Service and Sheriff.........................704-479-3352 Graham County Emergency Services (Business) ................................................704-479-3361 Graham County Fire Department............................................................... 704-479-3333 FergusonHarbour................................................................................ 800-235-1344 (emergency response contractor in case of spills) Lifestar (Emergency Helicopter Service)........................................................ 800-854-1033 National Response Center (U.S. Coast Guard)..................................................800-R2"802 National Weather Service - Knoxville........................................................... 615-970-2784 TAPOCO, Inc. Corporate Office................................................................. 615-977-3321 North Carolina Department of Environment, Health and Natural Resources ................. 704-663-1699I North Carolina Emergency Management Agency..............................................919-733-3867 Tennessee Emergency Management Agency (emergency).....................................800-262-3300 North Carolina Highway Patrol (State Warning Point) ........................................ 800-662-7956 University of Tennessee Hospital Helicopter .................................................... 800-792-1033 US EPA Region IV (Emergency Response Branch).............................................404-347-4062 OSHAEmergency Hotline....................................................................... 800-321-6742 OSHARegion IV .................................................................................404347-3573 industry\tapow\epp-nc-doc ii EMERGENCY PROCEDURES PLAN TAPOCO, INC. CHEOAH AND SANTEETLAH HYDROELECTRIC FACILITIES JANUARY 1994 Prepared by inc. consulting engineers and environmental scientists PLAZA 1, SURE 410 • 220 ATHENS WAY •-NASWLLE. TENNESSEE 37228 KA TABLE OF CONTENTS PAGE First -Plant -Contact List i Outside Emergency Response Agencies List ii I. INTRODUCTION 1 A. Regulatory Requirements and Goals 1 B. Tapoco, Inc. General Information 1 C. General Information - Cheoah Facility 1 D. General Information - Santeetlah Facility 2 E. Plan Review and Amendments 3 II. MANUAL ASSIGNMENTS III. GENERAL EMERGENCY PROCEDURES A. Overview B. Contingency Plan - Preparedness & Prevention 1. Alarm System 2. Communication System 3 Unobstructed Access Maintenance 4. Outside Agencies 5. General Evacuation Plan 6. Community Evacuation Plan 7. External Factors Affecting Emergency Procedures C. Emergency Response Procedures D. Emergency Event History IV. SPECIFIC EMERGENCY PROCEDURES A. Major Injury 1. General Information 2. First Aid a. Pulmonary Resuscitation b. Cardiac Resuscitation C. Heavy Bleeding d. Shock e. Miscellaneous Injuries and Illnesses 4 1.1 6 6 6 6 7 7 7 8 8 9 9 11 11 11 11 12 12 13 13 13 TABLE OF CONTENTS, CONTINUED PAGE B. Fire 14 1. Fire Event - Cheoah 14 2. Fire Event - Santeetlah 14 3. Fire Protection - Cheoah 14 4. Fire Protection - Santeetlah 15 5. Evacuation Procedures for Severe Fire 16 6. General Fire Safety & Preparedness 16 7. Fire Extinguishers_ _ .: 17 C. Earthquake 17 17 1. Preparedness 18 2. During an Earthquake 3. After an Earthquake 19 D. Flood 19 20 1. Before a Flood 2. When Flood Warning is Issued 20 3. During a Flood 21 21 4. After a Flood 21 5. Flash Flood 22 E. Tornado & Severe Storms 1. Tornado Facts that can Save.Lives 22 2. National Weather Service Watch/Warning System 23 - a. Watch _ 23 b. Warning 23 23 3. Emergency Procedures 4. Thunderstorms and Lightning Safety Rules 24 F. Blizzard 24 24 1. Winter Storm Safety Procedures 2. After the Winter Storm 25 G. Oil, Hazardous Material or Hazardous Waste Spill 25 V. MAJOR INCIDENT REPORTING 26 A. Discoverer's Alert Procedures 26 1. Contact 26 2. Pass Along Information 26 B. First Plant Contact Responsibilities 26 C. Emergency Event History 27 II TABLE OF CONTENTS, CONTINUED II VI. TRAINING A. Plan Review B. Training Program C. Training Program Outline D. Training Records VII. SECURITY --- A. Site Security B. Inspection Schedules 1. Security Inspections 2. Maintenance Inspections C. Record Keeping PAGE 28 Wj 30 31 31 31 31 LIST OF APPENDICES APPENDIX A OSHA REGULATION- 29 CFR 1910.38 APPENDIX B CHEOAH INFORMATION, FIGURES AND FLOOR PLANS Table 1- Description of Cheoah Powerhouse Figure 1- Cheoah Dam and Powerhouse Location Map Figure 2 - Cheoah Powerhouse Site Map Figure 3 - Cheoah Powerhouse Floor Plan @ Elevation 989 Figure 4 - Cheoah Fire Protection Equipment Location Map APPENDIX C SANTEETLAH INFORMATION, FIGURES AND FLOOR PLANS Table 2 - Description of Santeetlah Powerhouse Figure 5 - Santeetlah Powerhouse Location Map Figure 6 - Santeetlah Dam Site Map Figure 7 - Santeetlah Powerhouse Site Map Figure 8 - Santeetlah Fire Protection Equipment Location Map Figure 9 - Santeetlah Turbine Floor Plan - Elevation 1158 Figure 10 - Santeetlah Generator Floor Plan - Elevation 1169 APPENDIXI) ANDREWS HOSPITAL LOCATION MAP Figure 11- APPENDIX E CERTIFICATION OF AMENDMENTS TO PLAN EMERGENCY PROCEDURE PLAN REVIEW RECORD 0 1 industry\tapoco\epp-ncdoc 1 The Emergency Coordinator shall contact outside Emergency Agencies as necessary to help in an emergency, the following is a listing. ALCOA Tennessee Operations (Dave Fugate) ............................................. 615-977-2328 .......................'...........................,.....................................(home) (615) 856-3257 Blount County Local Emergency Planning Committee...................................................... Dave Fugate ALCOA......................................................................... 615-977-2328 Paul R. Hicks - Blount Co. Civil Defense ...................................................... 615-982-4210 Cheoah Powerhouse' Control Room............................................................. 704-498-2217 Cheoah Powerhouse Main Office............................................................. 704-498-2221 Santeetlah Powerhouse Control Room ......................................................... Calderwood Powerhouse Control Roost ....................................................... 615-977-2199 .............. ...:......................:.......'..................................... or 615-856-2346 Calderwood Powerhouse Main Office.......................................................... 615-977-2101 ..................... ................................................................. or 615-856-2342 Graham County Ambulance Service......................................................... _ . 704-479-8342 Graham County (24 hr) Emergency Management Service and Sheriff .:....................... 704-479-3352 Graham County Emergency Services (Business) ................................................ 704-479-3361 Graham County Fire Department...............................................................704-479-3333 FergusonHarbour................................................................................ 800-235-1344 (emergency response contractor in case of spills) Lifestar (Emergency Helicopter Service)...................................................... 800-854-1033 National Response Center (U.S. Coast Guard) .................................................. 800-424-8802 National Weather Service - Knoxville........................................................... 615-970 2784 TAPOCO, Inc. Corporate Office ................................................... North Carolina Department of Environment, Health and Natural Resources................. .... .... 615-663 1621 99 North Carolina Emergency Management Agency..............................................919-733-3867 Tennessee Emergency Management Agency (emergency).....................................800-262-3300 North Carolina Highway Patrol (State Warning Point) ........................................ 800-662-7956 University of Tennessee Hospital Helicopter ................................................... 800-792-1033 US EPA Region IV (Emergency Response Branch).............................................404-347-4062 OSHAEmergency Hotline..................................... .................................. 800-321-6742 OSHARegion IV.................................................................................404-347-3573 industry\tapoco\epp-ncdoc u I. INTRODUCTION A. Regulatory Requirements and Goals of Emergency Procedures The intent of this emergency procedures plan is to achieve employee safety and health in the event of an emergency at the Cheoah or Santeetlah powerhouse or dam. This plan will describe potential incidents and conditions which could threaten the safety and health of TAPOCO personnel as well as describe procedures that should be taken in the event of such an emergency. The regulatory requirement for an emergency procedures plan is set forth by OSHA - in 29 CFR 1910.38 (included as Appendix A). B._ General Information - Tapoco Inc. TAPOCO, Inc. is an incorporated hydropower company with three (3) dams and four (4) powerhouse facilities along a 23-mile stretch of the Little Tennessee River in western North Carolina and eastern Tennessee. Cheoah Dam is located on the Little Tennessee River upstream of the Cheoah River fork. The dam creates Cheoah Lake. The Cheoah Powerhouse is located on the same property and slightly downstream of the dam. A fourth dam (Santeetlah) is located on the Cheoah River in North Carolina and discharges shortly downstream of Cheoah Dam into the Little Tennessee River. TAPOCO, Inc., a wholly owned subsidiary of Aluminum Company of America (ALCOA), has located its company headquarters in Alcoa, Tennessee. Its primary purpose is to supply power to ALCOA's. manufacturing process. The power generated at the powerhouses are distributed by a series of transformers and oil circuit breakers (OCBs) to ALCOA's Tennessee Operations in Alcoa, TN for consumption in their manufacturing processes. C. General Information - Cheoah Facility The Cheoah Powerhouse is an eight -acre site located on the south bank of the Little Tennessee River near river mile 51.5, which is at the head of Calderwood Lake in North Carolina. The powerhouse is bordered on the east and southeast by mountains, by the Little Tennessee River on the north, and by the Cheoah River to the west and southwest. The Cheoah Powerhouse is located approximately half a mile north of Tapoco, NC. Access to the facility is from U.S. Highway_ 129. Figure 1, located in Appendix B, is a USGS map showing the location of the Cheoah Powerhouse and the surrounding area. Figure 2 is a site plan of the facility. Table 1, in Appendix B, provides general facility information on the Cheoah Powerhouse. industry\tapom\epp-ncdoc 1 Geologically, the Cheoah Powerhouse is located in the BlueRidge region of western North Carolina. This province is characterized by rugged terrain, heavily forested slopes, and rushing streams and water falls. Valleys in this region range from 1,000 to 1,500 feet above mean sea level, with some mountain peaks' exceeding 6,000 feet above mean sea level. The major and only production process at the Cheoah facility is the hydroelectric generation of electricity. The dam located adjacent to the powerhouse and a connecting pipeline provides mechanical energy (water pressure) which is converted to electrical energy by five generators. D. General Information - Santeetlah Facility The Santeetlah Powerhouse is a four -acre site located on the south bank of the Little Tennessee River near ever mile 56.7, approximately three miles west of the Tennessee Valley Authority (TVA) Fontana Dam. The powerhouse is bordered on the south and west by wooded mountains, by the Little Tennessee River on the north, and by wooded areas on the east. The Santeetlah Powerhouse is located approximately seven miles from the city of Robbinsville, NC. Figure 5, located in Appendix C, is a USGS map showing the location of the Santeetlah Powerhouse and the surrounding area. Figure 6 is a site plan of the dam and the site map for the powerhouse is depicted in Figure 7. Table 2, located .in Appendix C, provides general facility information on the Santeetlah Powerhouse. Geologically, the Santeetlah Powerhouse is located in the Blue Ridge region of western North Carolina. This province is characterized by rugged terrain, heavily forested slopes, and rushing streams and water falls. Valleys in this region range from 1,000 to 1,500 feet above mean sea level with some mountain peaks exceeding 6,000 feet above mean sea level. The major and only production process at the Santeetlah facility is the hydroelectric generation of electricity. The Santeetlah Dam is located five miles remote from the powerhouse and a connecting pipeline provides mechanical energy (water pressure) which is converted to electrical energy by two generators. The Santeetlah Powerhouse is an unmanned, automatically operated facility. Support for the facility (both operations and maintenance) is provided by the Cheoah Powerhouse, which is a fifteen -minute drive from Santeetlah. industry\tapoco\epp-mdoc 2 E. Plan Review And Amendments i This plan will be reviewed as necessary and at a minimum annually to satisfy or determine the following conditions: 1. That appropriate plant personnel have received their annual training review, and any subsequent necessary revisions were made to the training program. 2. The plan must be updated following each emergency procedure occurrence such as a natural disaster, fire, major injury, or hazardous waste spill/release. The event shall be reported in the format delineated in Section IIIP), page 9, and included as an amendment to the plan. 3. The plan must be amended if any of the following conditions occur: a. Ineffective emergency response procedures; b. If there are changes to the design, construction, operation, or maintenance of the facility which affects the potential for fires, injury, or releases of oils, hazardous materials or wastes; t C. If the emergency equipment or coordinators change; and d. If the facility permit is modified, or if the regulations are revised. These changes shall be incorporated into this plan as soon as possible, but no later than six (6) months after the change. If there are no emergency events, and amendments are not required for any of the conditions listed in No. 3 above, then the plan shall be revised every three years. A "Certification of Amendments to Plan" is located in Appendix E. industry\tapoco\epp-ncdoc 3 II. MANUAL ASSIGNMENTS The persons listed in the distribution list should have a copy of this plan. Everyone on the distribution list will receive a copy of all amended pages as soon as they are available. Cheoah and Santeetlah Facilities O Doug Frushour North Carolina Area Superintendent TAPOCO, Inc. 14 Meadow Branch Road Robbinsville, North Carolina 28771 Phone: (704) 498-2221 O Burlin Gladden Maintenance Coordinator TAPOCO, Inc. 14 Meadow Branch Road Robbinsville, North Carolina 28771 Phone: (704) 498-2221 a Julian Polk Vice President TAPOCO, Inc. P.O. Box 9128 Alcoa, Tennessee 37701 Phone: (615)* 977-3327 0 Hail Sakoian Environmental Control and Industrial Hyygg'�ene Manager ALCOA Tennessee Operations, ALCOA West Plant P.O. Box 9128 Alcoa, Tennessee 37701 Phone: (615) 977-2780 0 TAPOCO, Inc. Security North Carolina Dams TAPOCO, Inc. 14 Meadow Branch Road Robbinsville, North Carolina 28771 Phone: (704) 498-2026 _ O Power Dispatching Office ALCOA South Plant P.O. Box 9128 300 S. Hall Road Alcoa, Tennessee 37701 Phone: (615) 977-3322 industry\tapoco\epp-nc.doc 4 o Santeetlah Powerhouse Control Room N.C.S.R.1247 Rymers Ferry Cheoah Lake 14 Meadow Branch Road Robbinsville, North Carolina 28771 Phone: (704) 498-2354 O Cheoah Powerhouse U.S. Highway 129 North of Tapoco 14 Meadow -Branch Road Robbinsville, North Carolina 28771 Phone: (704) 498-2221 o Offices of TAPOCO, Inc. 300 S. Hall Road P.O. Box 9128 Alcoa, Tennessee 37701 Phone: (615) 977-3321 industry \tapoco\epp-ncdoc 5 III. GENERAL EMERGENCY PROCEDURES A. Overview The Emergency Procedures Plan is designed to minimize hazards to human health or the environment from fires, natural disasters, or any unplanned sudden or non -sudden release of hazardous waste or hazardous waste constituents to air, soils, or surface waters. The provisions of this plan must be carried out immediately whenever there is an emergency event. B. Contingency Plan - Preparedness and Prevention This section of the Plan reviews the availability of equipment, and the practices that are required to maintain the readiness of the response elements. 1. Alarm Systems The Cheoah Powerhouse is manned on a 24-hour basis.There are automatic, audible fire alarms which will detect a fire in the powerhouse. The Santeetlah Powerhouse is an unmanned, automatic facility. Emergency response and maintenance activities are supplied from TAPOCO, Inc. Cheoah Powerhouse. The Cheoah Powerhouse is located fifteen minutes from the Santeetlah Powerhouse and is manned on a 24- hour basis. Unauthorized entry to the Santeetlah Powerhouse is detected by an alarm system, which signals the TAPOCO, Inc. Cheoah Powerhouse of such an intrusion. If a fire should break out in the powerhouse, an automatic alarm system will trigger, notifying personnel at the Cheoah Powerhouse of an emergency situation. In addition, an audible alarm will sound at the Santeetlah Powerhouse. 2. Communication Systems Telephones are available for summoning emergency assistance from local police and fire departments, or stateorlocal emergency response teams. There are telephones in the Cheoah Control Room where an operator is always present and also in the Main Office. Any incidents requiring emergency actions should be reported immediately. There are phones in the Cheoah and Santeetlah Powerhouse Control Rooms, the phone numbers for which are listed below: industry\tapoco\epp-nr-doc 6 _ Telephone Cheoah Powerhouse Control Room (704) 498-2217 (615) 977-3393 Cheoah Powerhouse Main Office (704) 498-2221 (615) 977-3394 Santeetlah Powerhouse (704) 498-2354 In addition to the telephone system, two-way radios are permanently secured in the Cheoah Powerhouse Control Room and Main Office, as well as in all TAPOCO, Inc. vehicles. TAPOCO personnel would use these radios to summon assistance if phone access is not possible. The PA system can be used for announcements on -site. Since the Santeetlah facility is an unmanned site, a company vehicle will always be present if personnel are on site. 3. Unobstructed Access Maintenance Non -equipment areas should be kept free from unnecessary objects which may impede access by emergency crews as well impede the exit in an emergency evacuation. 4. Outside Agencies to Assist in Emergencies Outside agencies are available to respond to an emergency. Should an emergency occur which exceeds the plant's emergency response capabilities, call the appropriate agencies listed in Table 2 for assistance. 5. General Facility. Evacuation Plan In the event of a severe natural disaster, severe fire, etc., refer to each individual specific event procedure for the proper evacuation plan. Floor plans are included in Appendix B for Cheoah and Appendix C for Santeetlah. These plans show all stairways and exits from the facilities. The following evacuation plan is general and could be used in most instances. The person receiving the call or finding the emergency situation should notify the area superintendent or his representative. Area Superintendent shall: a. Notify all employees on site by telephone or by radio. b. Notify all employees in the field ( away from the site) about the emergency via company two-way radio. industry\tapoco\epp-nc.doc 7 C. Notify the Alcoa dispatching center via phone. i d. Notify the proper civil authorities. Maintenance personnel on site shall: Immediately cease work, shut down maintenance equipment, and go to the Tapoco Lodge parking lot to await further instructions via two-way radio. Maintenance personnel in the field shall: Immediately cease work and stay at their present location with a radio and wait for further instructions. Operating personnel shall: Shut down all units (time permitting) and go to the Tapoco Lodge parking lot to await further instructions via two-way radio. Area Superintendent shall then: a. Count all employees. b. Verify number and location of all employees away from the Tapoco Lodge parking lot by radio. C. Verify that all employees are accounted for or search for the missing. d. Confer with civil authorities and company officials on next course of action. 6. Involvement in Community Evacuation Plans Since the facilities have no acutely hazardous materials, they are not involved in any community evacuation plans. However, flood/ dam failure would require downstream evacuations and is covered in TAPOCO, Inc.'s EAP for Dam Failure. 7. External Factors Affecting Emergency Response Procedures During natural disasters, i.e. flooding, earthquake, blizzard, etc, it may be difficult to properly respond to an emergency situation such as a major bodily injury. industry\tapOM\epp-ncdoc 8 If high winds or a storm interrupts a telephone communication, the mobile 2-way radio units in the company vehicles or hand held units can be utilized. C. Emergency Response Procedures The emergency procedures detailed in this section apply to natural disasters, the. release/spill of oils or hazardous substances, fires, or major injuries. These procedures are meant to supplement any others which TAPOCO, Inc. or ALCOA may have, such as those delineated in an RPCC Plan or Emergency Action Plans For Dam Failure. The emergency procedures would be used in conjunction with the Community's Emergency Response Plan if the situation mandates this action. The emergency procedures addressed herein shall be reviewed annually and amended as needed to address changes or additions to the facility, its processes and operations, hazardous substances, and personnel which would adversely impact their effectiveness. Following the occurrence of a natural disaster, release/spill, fire, or major injury that requires implementation of this plan, the Primary Emergency Coordinator (as listed on the First -Plant -Contact List) must immediately notify the proper r agencies. (� This Emergency Procedures Plan is intended to provide specific information and instructions in order to properly respond in an emergency situation. However, certain unforeseen circumstances may arise in which deviations from this plan may be -necessary. In the event this happens, the individual should use best individual judgment on a case by case basis. D. Emergency Event History If an emergency procedures event occurs in the future, this plan should be amended. A brief written description of the event should be provided which includes the following information: 1. Date, 2. Type of Emergency, 3. Plant location and area of emergency, 4. Cause of emergency 5. Personnel and agencies notified or involved industry\tapoco \epp-nc.doc Z 6. Remedial action taken to effectively handle the emergency, 7. Plans for preventing a reoccurrence. industry\tapoco\epp-ncdoc 10 IV. SPECIFIC EMERGENCY PROCEDURES A. Major Injury 1. General Information Locate District Memorial Hospital, Andrews North Carolina on Figure 11, Appendix D, and post as well as instruct individuals as to the shortest route to the nearest hospital. The following is a list of pertinent phone numbers in the event of a major injury. District Memorial Hospital - Emergency Room 704-321-1260 District Memorial Hospital - General Information 704-321-1200 Graham County Ambulance 704-479-8342 Graham County Fire Department 704-479-3333 Graham County Sheriff 704-479-3352 Lifestar Helicopter 800-854-1033 University of Tennessee 800-792-1033 Hospital Helicopter North Carolina Highway Patrol 800-662-7956 These phone numbers should be posted next to all phones as well as be available for review in this manual. In the event of a major injury, dial 911 immediately. Personnel should verify that they are on a 498 extension or one of the North Carolina phone lines. When using PBX lines, personnel should dial 3393 (Cheoah control room), 3394 (Doug Frushour's office), or 3322 (dispatchers office). If PBX phone- is not available, notify appropriate personnel via vehicle radio. All on -site personnel should be trained in the use of CPR and basic first aid in order to correctly respond to an injured person. This training would be beneficial in aiding a severely injured individual. The American Red Cross can provide this training on -site or at the Red Cross office in Maryville. The District Memorial Hospital is located at 71 Witaker Lane, Andrews, North Carolina. From Cheoah or Santeetlah, follow U.S. Route 129 South to Andrews. Highway 129 intersects Witaker Lane. 2. First Aid In the event of a major injury, apply first aid immediately. First aid is intended to prevent death or further injury and relieve pain until medical aid can be obtained. The initial responsibility for first aid rests with the person(s) at the scene, who should react quickly but in a calm manner. Professional medical help should be summoned immediately with clear industry\tapoco \epp-ncdoc 11 and specific descriptions of the type of injury. The injured person should not be moved except where necessary to prevent further injury. All personnel should be trained in basic first aid and CPR. The following is some categories of major injuries with some basic first aid steps to'follow. a. Pulmonary Resuscitation If the patient is unresponsive and no breathing movements are apparent, begin mouth-to-mouth resuscitation immediately. I. Place the patient flat on his back and kneel at the side. 2. Establish an airway. Check the patients mouth with your fingers to be sure that no obstruction is present and then tip the pat ent's'head back until the chin points straight up. 3. Pinch the patient's nostrils and begin mouth-to-mouth resuscitation by taking a deep breath and placing your mouth over the patient's mouth so as to make a leakproof seal. Blow your breath into the patient's mouth until you see the chest rise. 4. Remove your mouth and allow the patient to exhale. 5. Repeat at a rate of once every 5 seconds. b. Cardiac Resuscitation In the unresponsive patient, check for a cardiac pulse by locating the larynx (Adam's apple) with the tips of your fingers and slide them into the groove between it and the muscle at the side of the neck. If no pulse is felt, circulation must be restored within 4 minutes to prevent brain damage. 1. With the patient flat on his back, kneel at the waist, facing the head. 2. Place the heel of your right hand over the heel of your left hand on top of the patient's breastbone about 3 cm above'its lower tip. 3. Shift. your weight to the patient's chest and compress it at least 4 cm, then remove the pressure. 4. Continue at a rate of 80 compressions / minute. industry\tapoco\epp-nc.doc 12 c. Heavy Bleeding Heavy bleeding is caused by injury to one of more large blood vessels. Lay the individual down. Control bleeding by applying firm pressure directly over the wound with a clean handkerchief, cloth, or your hand. A tourniquet should be applied only in cases of an amputation or other injury to a limb in which there is no other way to stop the bleeding. If a tourniquet is used, a record of the time it was applied must be kept. d Shock Shock usually accompanies severe injury. The signs of shock include pallor, a cold and clammy skin, beads of perspiration on the forehead and hands, weakness, nausea, vomiting, shallow --breathing, and a rapid pulse. The following procedures for treating shock should be followed: 1. Correct the cause if possible (i.e. control bleeding). 2. Keep the individual lying down. 3. Keep the individuals airway open. If he or she is about' to vomit, turn the head to the side. 4. 'Keep the individual warm. e. Miscellaneous Injuries and Illnesses 1. Back and neck injuries - Keep the patient absolutely quiet. Do not move the patient or lift the head unless absolutely necessary. 2. Chest Pain - Keep the patient calm and quiet. Place the patient in the most comfortable position. 3. Convulsion - Place the patient on the floor. Do not restrain the patient's movements except to prevent injury. Do not place a blunt object between the patient's teeth, put any liquid in the mouth, slap the patient, or douse him/her with water. 4. Electric Shock - Throw the switch to turn off the current. Do not touch the victim until he/she is separated from the industry\tapoco\epp-nr-doc 13 current source. Begin CPR if breathing and cardiac pulse have ceased. 5. Unconsciousness - Keep the victim warm, lying down, and quiet until he/she regains consciousness. Do not move the victim's head if there is bleeding from the nose, mouth, ear, or eyes. Do not give anything by mouth. Keep the victim's airway open. Do not cramp the neck with a pillow. NOTE: ALL PERSONNEL SHOULD BE TRAINED IN BASIC FIRST AID AND CPR BEFORE ATTENDING TO A VICTIM. SEVERITY OF INJURY CAN BE INCREASED WITH IMPROPER FIRST AID. B. Fire 1. 2. 0 Fire Event At Cheoah If a fire should break out in the powerhouse, an automatic, audible alarm system will trigger, notifying personnel at the TAPOCO, Inc. Cheoah Powerhouse of the emergency. If the fire is relatively small, fire extinguishers located throughout the facility should be used to extinguish the 'fire. In case of a generator fire, high pressure carbon dioxide is an automatic extinguishing source that is in place at the facility. Water outlets for fire fighting hoses and other fire suppression equipment are available as shown in Figure 4. Water sprinklers are also located at several locations -in the powerhouse. Fire Event At Santeetlah If a fire should break out in the powerhouse, an automatic alarm system will trigger, notifying personnel at the TAPOCO, Inc. Cheoah Powerhouse of an emergency. A local audible alarm will also trigger. If the fire is relatively small, fire extinguishers located throughout the facility should be used to extinguish the fire. In case of a generator fire, high pressure carbon dioxide is an automatic extinguishing source that is in place at the facility. Water outlets for fire fighting hoses and other fire suppression equipment are available as shown in Figure 8. Fire Protection - Cheoah The following equipment is available at the Cheoah site for fire protection. Storage locations for all fire protection equipment are identified on the plant map in Figure 4. industry\tapom\epp-ncdoc 14 Powerhouse - Main Generator Floor o One 2-3/4-ton CO2 System, connected to each of 5 generators, to pipe trench, and oil room o One Dry Chemical Extinguisher, wheel mounted o Seven CO2 Wall Mounted Extinguishers,1 in Control Room Transformer Deck - South of Powerhouse O One Dry Chemical Extinguisher, wheel mounted 0 250 feet of Fire Hose o Sprinkler System, located along entire south wall of the powerhouse for use on Transformer Nos.14* Switch Gallery o One Dry Chemical Extinguisher, wheel mounted o Four CO2 Extinguishers - wall mounted Transformer Deck - East of Powerhouse o Spprinkler System, located above Transformer Bank No. 5 and OCB 6510 Lunch Room o Two CO2 wall -mounted extinguishers Shop o Two CO2 wall -mounted extinguishers, plus one outside near fueling station WARNING: DO NOT ATTEMPT TO FIGHT A FIRE IF YOU ARE UNSURE OF THE TYPE OF EXTINGUISHER OR HOW TO USE IT, OR IF THE FIRE IS SPREADING OR BLOCIUNG YOUR ESCAPE. 4. Fire Protection - Santeetlah The following equipment is available at the Santeetlah site for fire protection. Storage locations for all fire protection equipment are identified on the plant map in Figure 8. industry\tapoco\epp-ncdoc 15 Powerhouse Main Floor 0 3 Dry Chemical Extinguishers - wheel mounted 0 5 CO2 Wall Mounted Extinguishers 0 90 psi Water Hose Fittings, located on the east and west walls of the powerhouse (outdoors) with 100 feet of fire hose stored in the powerhouse Powerhouse Basement 0 5 CO2 Vessels, which service the Oil Room 0 16 CO2 Vessels, which service two generators 0 - 4 CO2 Extinguishers - wall mounted Storage Buildings East and West of Powerhouse 0 1 CO2 Extinguisher in each building 5. Evacuation Procedures For Severe Fire Contactlocal fire department, notify appropriate TAPOCO personnel (see First -Plant -Contact list), and sound the alarm if not already sounding. Vacate facility via the nearest, safest route, following exit signs. Heat and smoke rise, leaving cleaner air near the floor, therefore if evacuation must be made through a smoke filled area, crawl low. Also when evacuating, check doors before opening. Kneeling or crouching at the door, reach up as high as you can and touch the door, the knob, and the space between the door and its frame with the back of your hand. If the door is hot, use another escape route. If the door is cool, open it cautiously, continue along your escape route being sure to close doors behind you in an effort to contain the fire behind. Once outside, move away from the facility, account for all personnel, check for injuries, and allow trained fire fighters to combat the fire. Refer to general evacuation procedures in Section III(5). 6. General Fire Safety and Preparedness Fires can be prevented and injury and loss can be minimized, if employees follow simple on-the-job fire safety practices. Several easy steps to fire prevention in the workplace are as follows: a. Cigarette smoking should be in designated areas only with disposal of cigarette butts and ashes in approved containers. industry\tapoco\epp-nc.doc 16 b. Replace any electrical wiring that has cracked insulation or a broken connector. C. Leave space for air to circulate around heavy equipment. d. Keep exits, storage areas, and stairways free from debris. Early planning is critical to minimize injury. Personnel should be familiar with their surroundings in each facility. During a fire, electrical power may be disconnected and therefore an individual may have to locate exits in the dark Knowing the locations of the nearest fire alarms, fire extinguishers, fire hydrants, etc. will expedite response to a fire. Also, knowing the quickest evacuation route as well as an alternate evacuation route in case of fire blockage of the primary route is an essential element of fire safety. All personnel should conduct regular evacuation drills for fires as well as other emergencies. 7. Fire Extinguishers A fire extinguisher is the best defense against fires that have just begun. Fire extinguishers can buy enough time to get out of a burning area and can completely extinguish fires if used properly. However, using the wrong type of extinguisher can worsen a fire situation. It is very important to know the type of extinguishers located at the Cheoah and Santeetlah facilities. The extinguishers present at each facility are dry chemical types and CO2 types. These types of extinguishers can fight Class A fires, Class B fires (flammable liquids, gases, and greases) and Class C fires (electrical equipment and wires). There is a symbol on every fire extinguisher that designates the type. All fire extinguishers are placed in plain sight and are inspected regularly to ensure proper working order. An inspection log is kept on file. C. Earthquake 1. Preparedness for an Earthquake There will be no early warning for a natural disaster like an earthquake. It will strike very suddenly, therefore preplanning and preparedness is essential for survival and immediate action is critical. Personnel should become aware of potential hazards and safety measure to take during the earthquake. Most injuries incurred during an earthquake are a result of partial building collapse, falling objects and debris and not a result of ground movement. The following list of guidelines should be followed for earthquake preparedness: industry\ tapoco\epp-ncdoc 17 a. Knowing the surrounding environment is very important. During an earthquake, stay away from heavy furniture and equipment, windows and glass, shelving, and masonry. A hallway is one of the safest places while kitchens and garage areas are the most dangerous areas since there is generally a lot of shelving and heavy objects in these areas. A safe place should be designated in each section of the powerhouses and dams such as sturdy table, workbench or against an inside wall. In addition, employees should be familiar with the facility escape routes. b. All personnel will meet at the Tapoco Lodge parking lot following the earthquake. C. Conduct safety practice drills, i.e. locating safe refuges where you are at a particular time. d. Learn first -aid and CPR. e. Keep a copy of the emergency phone list handy. f. All personnel should be instructed in, and know the locations of all essential shut-off valves (i.e. gas, water, electricity, carbon dioxide, etc.). g. Secure heavy objects and machinery that could move enough to cause severe injury or damage. h. Keep breakables and heavy objects on bottom shelves. i. Keep flammables or hazardous materials secured. j. A flashlight, portable radio, batteries, and first -aid kits will be kept on hand. Individual personnel are responsible for a supply of clothing and food. 2. During an Earthquake If indoors, stay there and locate the safest place of refuge in the particular section of the facility you are in at that moment (i.e. hallway, under sturdy table, in a corner, next to inside wall, away from glass and possible falling objects). The three words DUCK, COVER, and HOLD are words that should be remembered during an earthquake. Individuals should DUCK to the floor and take COVER under a sturdy gable, bench, etc.. If that is not possible, seek COVER against an interior wall and protect your head and neck with your arms. After seeking COVER under some sturdy industry\taporn \epp-ncdoc 18 object, HOLD on to it and be prepared to move with it or HOLD the safe position until the ground stops shaking and it is safe to move. If outdoors, get into an open area away from trees, buildings, walls, and power lines. If you are too close to a building to safely get away from it, then duck into a doorway to protect yourself from falling bricks, glass, and other debris. If driving, pull over to the side of the road and remain in vehicle until the shaking has stopped. Avoid overpasses and power lines. 3. After an Earthquake Check for injuries and apply first -aid if necessary. Do not move seriously injured individuals unless they are in immediate danger. After accounting for all personnel and attending to any injured, check for hazards. The following is a list of possible hazards and other things to consider: a. Check for water leaks, gas leaks, and other utility damage. b. Check for powerhouse and dam structural damage. C. Check food and water supply for integrity. d. Turn on portable radio for instructions and news. e. Do not use vehicles unless there_is..a seriously injured person that needs immediate attention. f. Be prepared for aftershocks. g. Stay calm and cooperate with other personnel as well as public safety officials. As previously mentioned, earthquakes are unpredictable, therefore preparedness is the key to survival in such an instance as well as in other major natural disaster events. D. Flood An Emergency Action Plan for flood/dam failure is discussed in detail in TAPOCO, Inc.'s Emergency Action Plan For Dam Failure, Tallassee Project FERC No. 2169, Major Revision December 1993. All emergency actions related to flooding due to dam failure should be obtained from that document. The industry \ to p oco \ epp-n c doc 19 emergency procedures discussed in this document will be for river flooding and I overland flooding not related to dam failure. Floods are a natural and inevitable part of life along rivers. There are two types of floods to be discussed. These are seasonal floods which result from excessive rain causing river basins and small tributaries to fill with too much water. This type of seasonal flooding occurs when soil and vegetation cannot absorb the falling rain fast enough and when the water runs off the land in such quantities that it cannot be carried away quickly enough in normal stream channels or be retained in lakes or reservoirs. Flash floods are the second type of flooding event. Flash floods are raging torrents which rip through river beds and mountain canyons after heavy rains. The National Oceanic and Atmospheric Administrations (NOAA) local National Weather Service Offices issue flood warnings. The local National Weather Service office is located in Knoxville and can be contacted at the following phone number: National Weather Service 615-970-2784 There are also NOAA radio stations located across the country operating on a 24 hour basis. These radio stations provide up to the minute information on impending weather conditions and flood warnings. Taped weather messages are repeated every 4-6 minutes and will include watches, warnings, and statements. The radio frequencies to tune into for the Cheoah/Santeetlah Facilities are listed below. NOAA Weather Radio Network 162.550 MHz (Chattanooga) _ _--- .-_-__ _- —.. _-162.475 MHz (Knoxville) 162.400 MHz (Asheville) 1. Before A Flood: a. Tune in regularly to the weather radio during the rainy season. b. Know the elevation above flood stage for safe refuge (refer to EAP for Flood/Dam Failure,1993). C. Know the evacuation route. This will be U.S,highway 129 in most instances. 2. When a flood warning is issued: a. If time permits, move essential items to higher ground, b. Grease immovable machinery, industry\tapoco\epp-nc.doc 20 C. Fill fuel tanks to keep them from floating away, d. Move to a safe area before access is cut off by flood water, e. Store drinking water since water service may be interrupted. 3. During a Flood: a. Avoid areas of sudden flooding, b. Do not attempt to cross a flowing stream where water is above your knees, C. Do not attempt to drive over a flooded road. 4. _After A. -Flood: a. Boil drinking water. Wells should be pumped out and the water tested for purity before drinking. b. Seek necessary medical care. C. Avoid disaster areas until area has been cleared. d. Do not come in contact with live electrical equipment; electrical equipment should be dried and checked before being returned to service. e. Report broken utility lines to appropriate authorities. f. Check for injuries and apply first -aid if necessary. g. Account for all personnel 5. Flash Floods: Flash flood waves, moving at incredible speeds, can roll boulders, up -root trees, destroy buildings and bridges, and scour out new channels. Killing walls of water can reach heights of 10 - 20 feet. Prior warning of these sudden, deadly floods may not occur. However, when a flash flood warning is issued for your area or the moment a flash flood becomes imminent, act quickly. The following is a list of procedures to follow in the event of a flash flood. r- a. Get out of area subject to flooding. This includes dips, low spots, --- canyons, washes, drainage basins, etc. industry\tapom\epp-nc.doc 21 b. Avoid already flooded and high velocity flow areas. C. Be very cautious when driving. Road beds may be washed out. d. If the vehicle stalls, abandon it immediately and seek higher ground. e. Be especially cautious at night when it will be harder to recognize flood dangers. E. Tornado and Severe Storms The national weather service provides information on this type of storm. A radio tuned to the weather service band (the frequencies are listed in the flood section of this document) could pre-warn-TAPOCO, Inc. personnel of an impending storm of this magnitude. By definition, a tornado is a violent rotating column of air in contact with the ground. There are three types of tornadoes described by NOAA. A weak tornado has winds approaching 100 MPH, a strong tornado has winds approaching 200 MPH, while a violent tornado has winds approaching 300 MPH. Tornadoes usually develop from strong or severe thunderstorms, therefore, thunderstorm safety and procedures will also be covered in this section. 1. Tornado Facts That Can Save Lives a. Tornadoes travel at an average speed of 30 MPH, but speeds can reach 70 MPH and generally move from southwest to northeast. As a result, do not attempt to flee to safety in a vehicle. It is best to remain where you are or .locate a sturdy structure. If a sturdy structure is not available, seek out a ditch or ravine. b. While hail may or may not precede a tornado, the portion of a thunderstorm adjacent to large hail is often the area where strong to violent tornadoes are most likely to occur. Therefore seek appropriate shelter when hail begins and remain in the shelter for 15 to 30 minutes after the hail ceases. C. The tornado's atmospheric pressure drop plays a minor role in the damage process. Opening a window, once thought to be a way to minimize damage by allowing inside and outside pressure to equalize, is not recommended.. If a tornado gets close enough for the pressure drop to be experienced, the strong winds will have already caused significant damage. Opening the wrong window can, in some instances, increase damage. Therefore, do not take the time to open or close windows. industry\tapoco\epp-ncdoc 22 d. While most tornado damage is caused by the violent winds, most tornado injuries and deaths result from flying debris. Therefore, seek shelter in a lower portion of the powerhouses and dams where small debris is minimal. e. Tornado wind speeds increase with height within the tornado. As previously stated, seek shelter in a lower level of the facilities or, if outside at the time, seek a ditch or ravine and stay as close to the ground as possible. f. Tornado winds may produce a loud roar similar to that of a train or airplane. Therefore, at night or in a heavy rain, this roar will serve as a clue to an impending tornado. 2. National Weather Service Watch/Warning System a. Watch A watch is issued when and where severe thunderstorms and/or tornadoes are most likely to occur. A severe thunderstorm watch implies that the storms may develop to significant strength to produce large hail and/or damaging winds. A severe thunderstorm watch does not exclude the occurrence of a tornado. A tornado watch means that conditions are favorable for both tornadoes and thunderstorms. b. Warnings Warnings are issued by local National Weather Service offices when severe thunderstorms or tornadoes are indicated on radar or reported by individuals. A warning will outline the area at risk. All personnel should seek appropriate refuge if a warning has been issued for the Cheoah and Santeetlah general vicinity. 3. Emergency Procedures All personnel should seek refuge inside the powerhouses or dams depending on their location at that time. A refuge in one of the lower sections of the facility would provide sufficient protection. The turbine floor or lower hallway in the Cheoah powerhouse and the basement for away from windows at the Santeetlah powerhouse. A few guidelines are listed below. ,' a. Stay away from windows, doors, and outside walls. industry\tapoco\epp-ncdoc 23 b. Protect your head. C. Go to the lower floors away from areas that contain a lot of small objects. d. If there is no nearby shelter, he flat in the nearest ditch or ravine with your hands shielding your head. e. Always be informed. Listen to NOAA Weather Radio. After the tornado ceases, proceed to check for structural damage and bodily injury to personnel. Also, contact all appropriate TAPOCO personnel located at the dams and powerhouses to account for all personnel. 4. Thunderstorms and LightningSafety Rules If personnel plan to be outside, always check the weather beforehand. At signs of an impending storm (thunderheads, darkening skies, lightning, high winds) tune to NOAA radio for information. When a severe storm is threatening, always seek shelter indoors or inside your vehicle. If you are caught outside, do not stand under tall isolated trees or telephone poles. Also avoid projecting above the surrounding landscape. Shelter can be obtained in a low area under a thick growth of vegetation or a low ravine. Get away from open water, tractors, machinery, metal pipes, and guardrails. Lightning may strike away from the storm. If you are caught in an open area and you feel your hair stand on end, lightning may be about to strike. Drop to your knees and bend forward, putting your hands on your knees. Do not lie flat on the ground. F. Blizzard The national weather service radios will also be beneficial in predicting a storm such as a blizzard. The key to protection from a severe winter storm is to keep posted on weather conditions. A few hours of warning can be the key to avoid being stranded. A blizzard is the most dangerous of all winter storms combining cold air, heavy snow, and strong winds. 1. Winter Storm Safety Procedures a. Keep ahead of the storm by listening to the latest weather warnings and bulletins. b. Check battery powered equipment before the storm arrives. industry\tapoco\epp-ncdoc 24 C. Check the supply of heating fuel. d. Prevent fire hazards if portable heaters are used. e. Stay indoors during the storm. f. Wear dress appropriate for the season. Wear loose fitting, lightweight, warm clothing in several layers. The layers can be removed as necessary. g. Be mentally and physically prepared for isolation. h. Avoid overexertion. i. Travel only if necessary. Make sure your vehicle is in good condition, preferably equipped with chains, snow tires, or four wheel drive. Never travel alone and have a sufficient amount of gas. Have emergency supplies in the vehicle such as sand, shovel, windshield scraper, tow chain, rope, flashlight, blankets or sleeping bags, gloves, overshoes, extra socks, and winter headgear. Travel should be by daylight if possible and do not get in a hurry. If your vehicle breaks down, stay calm. Think the problem through and proceed with the safest and best alternative. Do not leave your vehicle except for an extreme emergency because you could become lost, confused, and disoriented. If you must leave your vehicle, stay on the road, do not attempt to make short cuts by trekking overland. 2. After the Winter Storm Check for injured personnel and apply first -aid. Frost bite will be the most common injury following a winter storm. After accounting for all personnel and attending to any injured, check for safety hazards (i.e. deep snow drifts, snow overhangs, snow/ice slides, electrical equipment). G. Oil, Hazardous Material or Hazardous Waste Spill If the release or spill of any oil, hazardous material or hazardous waste occurs at Cheoah or Santeetlah, refer to the respective individual RPCC plan. industry \ to poco \ epp-n c. d oc 25 V. MAJOR INCIDENT REPORTING A. Discoverer's Alert Procedures If a natural disaster, fire, spill or release of hazardous material, or major injury occurs, the individual discovering the incident should attempt to locate and eliminate the source. If possible, he/she should try to stop or at least contain the release or fire. In the event of a natural disaster or bodily injury, one must deal with these circumstances on an individual basis. These measures should only be undertaken if they can be accomplished without any risk to the individual. If the source is not immediately obvious or if these measures are not effective and the situation is beyond control, then the discoverer should initiate the following emergency procedures: 1. --ontact --- --- ----- -- - - - Refer to the First -Plant -Contact list (located in front of document in hot tab) for appropriate personnel to contact in the event of an emergency. 2. Pass along the following information: a. Exact location of the emergency event; b. Type and description of the emergency; C. Estimate of the severity of the emergency, amount of material released, or the size of the fire; d. Extent of injury or property damage incurred; e. Extent of the actual and potential environmental damage; and f. Remedial actions taken, if any. B. First -plant -contact's Responsibilities After being alerted by the discoverer of an emergency situation, the first -plant - contact will make a determination of the severity of the situation and instruct the necessary plant personnel to implement appropriate emergency procedures, if these have not already begun. The first plant contact will also: 1. Determine the type of emergency situation, — 2. Instruct personnel as to the emergency procedures to follow, industry\tapmo\epp-ncd- 26 3. Determine the severity of the emergency, 4. Contact appropriate agencies and personnel, 5. Instruct TAPOCO Security to secure area from nonessential personnel and a i R f ,�., 2 3 t0 1) , :` "� z;'.is? } 0, 6. In the case of a hazardous substance spill or release refer to RPCC plan for appropriate action, 7. Initiate remedial actions to be taken, C. Emergency Event History If an emergency procedures event occurs in the future, this plan should be amended. A brief written description of the event should be provided which • included the following information: 1. Date, 2. Type of Emergency, 3. Plant location and area of emergency, 4. Cause of emergency 5. Personnel and agencies notified or involved 6. Remedial action taken to effectively handle the emergency, 7. Plans for preventing a reoccurrence. industry\tapom\epp-ncdoc 27 VI. TRAINING A. Plan Review p� y This flan.. }l l : P r ,v t?wec a s ne�cQ c I p % n rt. of c S + '. ! ^ ��� ,� - _ , _, T ►. -, .:� ,� �, ,�: . i Yf t. 1p i a q,e _,i i_E,.' All new personnel shall receive appropriate training within one month of the date that they are hired. Likewise, personnel who transfer to new jobs which involve these responsibilities receive appropriate additional training within one month of the date of transfer. Everyone who works in an unsupervised position involving hazardous substances receives appropriate training initially. B. Training Programs The training programs will be conducted by a TAPOCO, Inc. supervisor in conjunction with the TAPOCO corporate office located in Alcoa, Tennessee. The training programs will also address the correct actions to be taken in the event of a natural disaster, fire, spill/release, or major injury, the appropriate people to be contacted, and other pertinent information presented in this plan. C. Training Program Outline The following topics will be discussed during training programs: o Major injury and appropriate actions o Health Concerns and Safety Precautions O Emergency Response Operations O Communication Procedures and Systems O Oil and Hazardous Materials Spills O Dealing with the News Media O Natural disasters and appropriate actions O Follow-up Actions and Reporting Training materials are available on many of the topics covered in this plan. The following is a list of those providing training materials and assistance: Tennessee Emergency Management Agency (TEMA) 3041 Sidco Drive Nashville, TN 37204-1502 1-800-262-3402 industry\tapoco\epp-nc.doc M North Carolina State Emergency Management Agency 116 West Jones Street Raleigh, NC 27603-1335 (919) 733-3867 1-! r?414 , z, �> Atfrt: Ed "win Hogan ��, r# 500 James Robertson Parkway - 3rd Floor Nashville, TN 37243-0577 (615) 741-2981 Central United States Earthquake Consortium 2630 Holmes Road, East Mempphis, TN 38118 (901) M-0932 or (800) 762-4313 National Weather Service Knoxville Office (615) 970-2784 Blount County Red Cross East Lamar Alexander Parkway Maryville, TN 37801 {615) 983-0281 D. Training Records Actual training records for the Cheoah and Santeetlah Powerhouses are maintained on computer file at the Tapoco, Inc.'s main office in Alcoa, Tennessee. industry\tapom\epp-ncdoc 29 VII SECURITY A. Site Security Site security, is an integral part of a facility's operation and should be made a fart . o the aes gn o the ia`c ty. "bite psecuri'ty is 'r'equired by`the ono'wing� aw and` their associated regulations: o Occupational Safety and Health Act - Emergency Action The Cheoah Powerhouse is accessible only from the bridge which crosses the Cheoah River south of the facility as shown on the location map (figure 1). A locked gate is used to prevent unauthorized entry into the facility. The facility is surrounded by water on the north, west, and south sides and a steep hill to the east, which provide natural barriers to unauthorized entry. Since the facility is manned on a 24 hour basis, personnel are always available to identify unauthorized entry to the facility. The Santeetlah Powerhouse is accessible only from the roadway to the west of the facility as shown on the location map (figure 5). A locked gate and fencing is used to prevent unauthorized entry into the facility. The facility is surrounded by water on the north and east sides and a steep hill to the south, which provide natural barriers to unauthorized entry. An alarm system, which signals the Cheoah Powerhouse, is in place to detect unauthorized entry. The possibility of uncontrolled access to any areas containing hazardous materials or waste is remote. The shift mechanic inspects the Cheoah facility during the first shift on weekdays and the Santeetlah facility is inspected twice a week The primary purpose of inspections is to monitor for oil releases, with a secondary purpose of checking for and preventing vandalism. There are automatic, time -activated flood lights in the various substations at the facility which include the Transformer area east and south of Cheoah Powerhouse. Time -activated flood lights are also located at the Santeetlah facility. These are positioned at the switchyard, the transformer banks, and the oil circuit breakers behind the powerhouse. The security system is designed to prevent accidental or unauthorized entry onto the property so that a release or injury incident related to vandalism, theft, or sabotage is avoided. Security personnel inspect the Santeetlah Powerhouse and Dam once a day. The primary purpose of inspections is to monitor for oil releases, with a secondary purpose of checking for and preventing vandalism. industry \tapoco \epp-nc.doc 30 B. Inspection Schedules 1. Security Inspections Security inspections are performed once a day. The inspections are e f"C Y <t . f , . r'4' i[ ), and Ta teetlah Powerhouses. 2. Maintenance Inspections Daily inspections are required for those facilities that could potentially cause environmental and bodily harm (see RPCC Plan Section VI(B) pages 69-70 for Cheoah and pages 66-68 for Santeetlah). Site inspections are performed daily at Cheoah and Santeetlah for those areas listed. Twice a week (Monday and Friday) the Maintenance Staff performs a detailed inspection of the complete operations of the Cheoah and Santeetlah Powerhouses during the first shift. C. Record Keeping The inspection report forms for the Cheoah and Santeetlah Powerhouses (both security inspection and maintenance. inspection) are filed in the Cheoah Powerhouse office. General security reports are retained only when unusual circumstances arise. industry\tapom\epp-ncdoc 31 §;* Dn� APPENDIX A OSHA REGULATION 29 CFR 1910.38 a a i U.JU tQ reach the nearest exit is not immediately (ii) If the employee storm system is used for alert. aplarent, ing fire brigade members, or for other purposes, a �� distinctive signal for each purpose shall be used. (6) Eeery exit sign shall be suit/ce. d by a reliable ight source giving a vathan (4) Evacuation. The employer shall establish in the 5 toot can es on the illuminateficial emergency action plan the types of evacuation to be lights giving lumination to exit sthe used in emergency circumstances. internally illu inated types shens, terAiscs oly}� eajjses f (51 gaining tit Before implementin the other specified des approach. th 25 square inches . e� g emer c,.�,j.ir�`x �¢'���lip�'hov3�h�1�`�e�nnAtr+ F� 1_*T$`3+ tray 'a'suf iciest number o ;olor on the side of the persons to assist In the safe and orderly emergency evacuation of employees. (7) Each internally ' I inated. exit sign shall be provided in all occ ancie here reduction of nor- mal illumination permitted. (8) Every it sign shall have a word "Exit" in plainly legible letters not less the 6 inches high, with t principal strokes of letters of less than th7FR fourths-inch wide. _. 1323502. June 27, 1974, as amended at FR 60703, Sept.12, 1980) 11910.38 Employee emergency plans and fire prevention plans. (a) Emergency action plan—{1) Scope and applica- 66n. This paragraph (a) applies to all emergency action plans required by a particular OSHA standard. The emergency action plan shall be in writing .(except as provided in the last sentence of paragraph (a) (SXiii) of this section) and shall cover those designated actions employers and employees must ake to ensure employee safety from fire and other emergencies. (2) Elements. The following elements, at a min- imum, shall be included in the plan: (i) Emergency escape procedures and emergency escape route assignments: (ii) Procedures to be followed by employees who remain to operate critical plant operations before they evacuate; (iii) Procedures to account for all employees after emergency evacuation has been completed; (iv) Rescue and medical duties for those employees who are to perform them; (v) The preferred means of reporting fires and other emergencies; and (A) Names or regular job titles of persons or departments who can be contacted for further in- formation or explanation of duties under the plan. (3) Alarm system. (i) The employer shall establish an employee alarm system which complies with §1910.165. (ii) The employer shall review the plan with each employee covered by the plan at the following times: (A) Initially when the plan is developed, (B) Whenever the employee's responsibilities or designated actions under the plan change, and (C) Whenever the plan is changed. (iii) The employer shall review with each employee upon initial assignment those parts of -the plan which the employee must know to protect the employee in the event of an emergency. The written plan shall be kept at the workplace and made avail- able for employee review. For those employers with 10 or fewer employees the plan may be communi- cated orally to employees and the employer need not maintain a written plan. (b) Fire prevention plan—(1) Scope and applica- tion. This paragraph (b) applies to all fire prevention plans required by a particular OSHA standard. The fire prevention, plan shall be in writing, except as provided in the last sentence of paragraph (bX4Xii) of this section. (2) Elements. The following elements, at a min- imum, shall be included in the fire prevention plan: (i) A list of the major workplace fire hazards and their proper handling and storage procedures, poten- tial ignition sources (such as welding, smoking and others) and their control procedures, and the type of fire protection equipment or systems which can con- trol a fire involving them; (ii) Names or regular job titles of those personnel responsible for maintenance of equipment and sys- temi installed to prevent or control ignitions or fires; and (iii) Names or regular job titles of those personnel responsible for control of fuel source hazards. (3) Housekeeping. The employer shall control accumulations of flammable and combustible waste materials and residues so that they do not contrib- ute to a fire emergency. The housekeeping proce- dures shall be included in the written fire prevention plan. SUBPART E Page 5 (4) Training. (i) The employer shall apprise am- cdures The use of floor plan► or workplace maps which Nearly show the escape routed should be tnciuded in the emergency ployees of the fire hazards of the materials and pro emergency action plan. Color coding will aid employees on determining their cesses to which they are exposed. route assignments. (ii) The employer shall review with each employee The employer should also develop and explain in detail what and medical first aid duties are to be performed and by upon initial assignment those parts of the fire prev- rescue whom. All employee& are to be told what scttons they are to take to ention plan which the employee must know to pro- these emergency Situations that the employer anticipa►e$ may tect the employee in the event of an emergency. The occur to the workplace written plan shall be kept in the workplace and 2. Emergency ewcuetion At the lime Of an emergency. •m- made available for employee review. For those otoveat:_fi�uld,knQw eta I<rP4 ol.yscyauo{y��:,n•Cess�ry Not "I fit sac.. ".vPlere ins►. h`,�rttr�,yaS; employers witf:.r . ►�3t.' to employees and the w.::,ti,et ►rr Earrytrt� bti,.i ie+e� .o,rli emergency is very grove. totst red immodtste evacuation of all a evacuation may be communicated orally employees is necessary. In other emergencies. partial employer need not maintain a written plan. of nonessential employees wtlh a delayed evacuation of others may only (5) Maintenance. The employer shall regularly and be necessary for continued plant operation. in some cafes. those employees in the immediate area of the fire may be expected properly maintain, according to established pro- tp evacuate or move to a sale area such as when a local Optics- cedures, equipment and systems installed on heat lion fire suppression system discharge employee storm it sounded. be surethat ed of the producing equipment to prevent accidental ignition _ nma � e ehmust emergency t of row Heir ce.n m of combustible materials. The maintenance pro- order to provide assurance of their safety from lire or other emer- eShall be included in the written fire proven- gency. tion plan. (45 FR 60703. Sept. 12, 19801 §1910.39 Sources of standards. The entire subpart is promulgated from NFPA 101-1970, Life Safety Code. §1910.40 Standards organizations. Specific standards of the following organization have been referenced in this subpart. Copies of the standards may be obtained from the issuing organization: National Fire Protection Association. 470 Atlantic Avenue. Boston, Massachusetts 02210. 139 FR 23502, June 27, 1974, as amended at 40 FR 18426, Apr. 28, 1975) APPENDIX TO SUBPART E — MEANS OF EGRESS This appendixserve$ itireassist empors in cmplyingwh the appropriate requirements of Sub - pan E. I1910.38 Employaa e171er9cricy Pans. 1. Emergency action plan elements. The emergency action plan should address emergencies that the employer may reasonably expect in the workplace. Examples are: fire: toxic chemical releases; hurricanes; tornadoes: blizzards: floods; and others. The elements of the emergency anion plan presented in paragraph 1910.3MAX2) can be supplemented by the following to more eHec- lively achieve employee safety and health in an emergency. The employer should list in detail the procedures to be token by those employees who hsve been selected 10 remain behind to care for essential plant operations until their evacuation becomes absolutely necessary. Essential plant operations may include the monitoring of plant power supplies, water supplies. and other essential services which Cannot be shut down for every emergency alarm. Essential plant operations may also include chemical or manufacturing pro- cesses which must be shut down in sieges or steps where censin employees must be present to assure that Safe shut down proce- dures ore completed. The designation of refuge or safe areas for evacuo ,;fin should be determined and identified in the plan. In a building divided into fire tones by fire walls, the refuge area may still be within the same. building but in 1 different zone from where the emerpongy occurs. Exterior refuge or sale areas may include parking lots. open Melds or Streets which bra located away from the site of the emergency and which provide sufficient space fo accommodate the employees. Employees should be instructed to more away from the exit dis- charge doors of the building, and to avoid congregating close to the building where they may homper emergency operations. 3. Emergency action plan training. The employer should assure that an adequate number of employees are available at all times during working hours to set as evacuation wardens so that employees can be swiftly moved from the danger location to the sale areas. Generally, one warden for each twenty employees in the workplace should be Sble to provide adequate guidance and instruction at the time of a fire emergency. The employees selected or who volunteer to serve as wardens should be trained in the complete workplace layout and the various alternative escape routes from the workplace. All wardens and fellow employees should be mode surer• of handicapped employees who may need unra assistance. such as using the buddy system, and of hszbrdous areas to be avoided during emergencies. Before leaving, wardens should check rooms and other encl*W spaces in the workplace for employees who may be trapped or otherwise unable to evscwte the area. Aher the desired degree of evacuation is completed. the wardens should be able to account for or otherwtse verify that all employees are in the sate areas. In buildings with several places of employment, employers are encouraged to coordinate their plans with the other employers in the building. A building wide or standardized plan for the whole building is acceptable provided that the employers inform their respective employees of their duties and responsibilities under the plan. The standardized plan need not be kept by each employer in the multi -employer building, provided there is an accessible locs- lion within the building where the plan can be reviewed by affected employees. when multi -employer building•wids plans are not leas - Ibis, employers Should coordinate their plans with the other employers within the building to assurs that conflicts and confu- sion are avoided during times of emergencies. In multi -story build. ings where more than one employer is on a single floor, it is essen- tial that these employers coordinate their plans with each other to avoid conflicts and confusion. SUBPART E Page 6 0.—_.w 4. fire prevention houseieeping. The Standard Calls for the Von- trol of accumulations of flammable and oornbustible waste materials. It is the intent of this standard to assure that hazardous aot:umu- lat,ons of combustible waste materials era COntfolted 50 1W a fail developing fire, rapid spread of toxic smoke. W an explosion will , not occur. This does not necessarily mean that each room has to be swept each day. Employers and employees should be &Were of the hazardous properties of materials iin their workplaces, and the 4 cal. Of n 3� Q t apt_ ed ran .Ave - a : f I ri a rFikait 'bNfafetrliy'''trw`rt" genera °f»b+r u �+ "= �i. HOW ever, large accumulations of wall$ paper or Corrugated boxes, asp.. Can posh a significant fire hazard. Accumulations of materials which can cause large fires or general* dents smoke that are ass• fly ignited or may scan from apontonsous Combustion, are the types of materials with which this standard is concerned. Such combust• able materials may be easily ignited by matches. wNder's sparks, cigarettes end similar low level energy ignition sources. S. Maintenance of equipment under the lire prevention plan. Car- — tain equipment is oflen installed in workplaces to Control halt sources or to detect fuel leaks. An example is a temperature limit switch often found on deep•fai food fryers found in restaurants. There may be similar switches for high temperature dip tanks. or Harris failure and flashback arrester devices on furnaces and sim- ilar heat producing equipment. If these devices are not properly maintained or if they become inoperative, a definite fire hazard exists. Again employees and supervisors should be aware of the specific type of control devices on equipment involved with com- bustible materials in the workplace and should make sure, through periodic inspection or testing, that these Controls are operable. Manufacturers' recommendations should be followed to assure proper maintenance procedures. 145 FR 60714, Sept. 12,19801 SUBPART E Page-7 ,,884 @ �', , is �.�'?. ;F��,��$�,-��°$:i �i! ii;�', S '�f��la it'd''"��3"� r,J�'���.'���1'���§.'3� ��: �'. tiitiiv`il~''�i�.iil = fa `1FiELtj; nc ` l.eo3l owerilouss LOCATION OF FACILITY U.S. Highway 129, Calderwood Lake MAILING ADDRESS 14 Meadow Branch Road CITY, STATE, ZIP Robbinsville, North Carolina 28771 COUNTY - Graham County TELEPHONE NO. Cheoah Powerhouse Control Room: (704) Cheoah Powerhouse Main Office: NAME OF OWNER TAPOCO, Inc. P.O. BOX P.O. Box 9128 CITY, STATE, ZIP Alcoa, Tennessee 37701 TELEPHONE NO. (615) 977-3321 YEAR FACILITY OPENED 1919 TYPE OF FACILITY Hydroelectric Plant LATITUDE 350 26' 53" N LONGITUDE 830 56' 19" W DESIGNATED RESPONSIBLE PERSONS: PERSONNEL Name: Doug Frushour Phone: (704) 498-2221 W TAPOCO MANAGEMENT or (615) 977-3394 W (704) 479-6657 H Name: Burlin Gladden Phone: (704) 498-2221 W or (615) 977-3394 W (704) 479-2262 H Name: Julian Polk Phone: (615) 977-3327 W (615) 983-4833 H 498-221 498-222 stry\tapoco\epp-nc.doc �J � , , (. \�`, �'-•:` �.. f.��.. � � /i , �j / i/ .mac �.� -��' � rJ ': � � � � . , •l`• 1 '' � ,� �` fir, _ '-�'�•"�\ r^lr, ��-^, �_ LIZ CHEOAH POWERHOUSE l fib/ �_ { �` �-'•��ri � 1 �` : _ CJ (��•__-_- •✓.,% _' - an,u/lrny nyo,wa ane rrvkvrv�a+ ,dr,tlrb CHEOAH POWERHOUSE TAPOCO, INC. FIGURE 1 LOCATION MAP 5149 1'=2000' 9/20/93 • '� - ( -�:� '}: j 1 JOB NO. SCALE D.I O I'g�lal I�° pn d z pp—1 j O b - e q o � Y C 2 a dC G Uy49 g g� 0 �- Z J I :.'. ,' n�T+: !d�.# +,,tk t. .I�f 111 �:.: t'�'�, IIY'h. i'A.-zitt 4 ;�;.:7 i s r .. APPENDIX C SANTEETLAH INFORMATION, FIGURES, AND - --FLOOR PLANS i}1 ;C 6'•-: NAME OF FACHM LOCATION OF FACILITY MAILING ADDRESS CITY, STATE, ZIP COUNTY TELEPHONE NO. TAPOCO, Inc. - Santeetlah Powerhoust N C S.R.1247, Rymers Ferry, Cheoah l 14 Meadow Branch Road Robbinsville, North Carolina 28771 Cheoah Powerhouse NAME OF OWNER TAPOCO, Inc. P.O. BOX P.O. Box 9128 CITY, STATE, ZIP Alcoa, Tennessee 37701 TELEPHONE NO. (615) 977-3321 YEAR FACILITY OPENED 1928 TYPE OF FACILITY Hydroelectric Plant LATE 350 26' 52" N LONGITUDE 830 51' 52" W DESIGNATED RESPONSIBLE PERSONS: PERSONNEL Name: Doug Frushour Phone: (704 498-2221 W TAPOCO MANAGEMENT or 5 977-3394 W �61 704 479-6657 H Name: Burlin Gladden Phone: (704) 498-2221 W or (615) 977-3394 W (704) 479-2262 H Name: Julian Polk Phone: (615) 977-3327 W (615) 983-4833 H 498- lustry\tapoco\epp-nc.doc ��x�;: I'iI 151 11 pp, 0 cn Uj r-,) Z: U ( cn w nr- n b- CK -T- Of < < cn >- 0.0 m C3 WC, 0 uj St n I J$t, t' v z GI 119 06; sr, L 4 lon ci le 91 s ur RE 0- r. ILI wo IL 14 a 0 c lum, E IL 0 Ci 0 rL IL %J tj c 4) 0 U) :V3#, -it, 4W ria ❑ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - F.ZI 14— r�— ci z § w w to q 1 211, "'t, pwko L.— r- L — r- L — APPENDIX D ANDREWS HOSPITAL LOCATION MAP I At, cr 129h��;:,'NORTH 'M O-U- f� TA-f-Ail's e oe� 28 ff" 6W i I Til� d 129 SIC 143 lit J. t CO J. r A7rZ 129 ID lk Is UWWYAR. h '46 Op Am ol. AN ap, JVASH= *Z?CQWM 74 A Ung wVk,"m and wi4mnmwnW adwithb 129 14 CHEOAH & SANTEETLAH DAMS — TAPOCO, INC. Y FIGURE 11 HOSPrTAL LOCATION MAP ANDREWS �,.,. ��o� �\ . v•�T r� ,� ^ / _ 5149 :150,000 9/21/93 JOB NO. SCALE DATE. ZIA V3. APPENDIX E CERTIFICATION OF AMENDMENTS TO PLAN EMERGENCY PROCEDURES PLAN REVIEW RECORD CERTIFICATION OF AMENDMENTS TO PLAN I hereby certify that I have examined TAPOCO's (ALCOA's) Cheoah and Santeetlah Powerhouse facilities located off of U. S. Highway 129 on the Little Tennessee River and C]heoah River, and being familiar with the the provisions four jr 411 e S`4 • ••. 5§-"-j1'F �.ldF `��"�' aR} .i`� fl _ t � 1910.38) attest that the plan and amendments to this plan dated have been prepared in accordance with good engineering and environmental safety practices, and that to the best of my knowledge and belief such information is true and accurate. Such amendments include, in summary, Name Signature Title Date aryVapoco\epp-nc.doc EMERGENCY PROCEDURE PLAN REVIEW RECORD nH , tp.:P;t f G r� � i ft 4.I 5P 9- 'f �'wil PY ((``P�11rn �yn�,�i,n� 3t� } _ . y�, {i'►� and Santeetlah Facilities, including comments noting any amendments made to the plan in the spaces provided.. The Emergency Procedures Plan Administrator or Primary Emergency Coordinator should sign as reviewer. Reviewed By Date Comments y\tapoco\epp-nc.doc RPCC for APGI-TAPOCO/SANTEETLAH NC APPENDIX G :EVACUATION PLAN APP-10 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. Santeetlah Powerhouse Evacuation Plan For an Emergency (i. e. — bomb threat, severe earthquake, fire, etc.): The person receiving the call oufinding the emergency situation shall notify the Maintenance coordinator or his representative. Maintenance Coordinator Shall: 1. Notify all employees on site via by phone, PA system or company radio about the emergency. 2. Notify all employees in the field (away from the site) about the emergency via company two-way radio. 3. Notify the Alcoa Dispatching Center via phone or two-way raido. 4. Notify the proper civil authorities (if not already notified). Maintenance Personnel on site Shall: Immediately cease work, shut down maintenance equipment, and go to the Tapoco Lodge parking lot via vehicle or on foot. Maintenance Personnel in the field Shall: Immediately cease work and stay at their present location with a two- way Raido and wait for further instructions. Dispatching Personnel Shall: Shut down all operating units. Maintenance Coordinator Shall Then: 1. Count all employees in the Tapoco Lodge Parking lot. 2. Verify number and location of all employees away from the parking lot Via two-way company radio. 3. Verify that all employees are accounted for or search for the missing. 4. Confer with civil authorities and Company officials on the next course of action. RPCC for APGI-TAPOCO/SANTEETLAH NC APPENDIX H MAPS AND DRAWINGS FIGURE 1 - RPCC FACILITY PLAN USGS LOCATION MAP WIND ROSE APP-1 1 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. S J W W W X mQ W z W Y LU J W = m � 0 L J = � U cm r `m T L H o fA 0 O 0000000 a Opp 000 0 �- o ' qNq C� z b U� W d. 0¢ Ete 30 z Z oa Z V z_ cc w U v� W Fw- w la O `SU % H=o CL Zco }JT e,' U- U~ YL• Q �Q 0 O ❑ ❑ m c W a 0 c E° c —00 m a N R 7 � -c�`�' O w�a IL O Hl�o`j` a r m x RPCCISANTEF,TLAH SEPTEMBER 2001 FIGURE MN GN 1 V2. 27r�TL§ 3 LS j/ LITM GRID AND 1978 MAGNETIC _ � I ����\ _�� � _ - �-, } � o I� � ; �J� )fly.. G 10. -. -- u �) :� /'� o_ JI _-� �J L Pfll d1% -0 1p�� `'�,% ,JJ11 ��-� Ji� �4< - ���U , ram-- f � , � `�` ." %/���� j!�^� X � ,�� >>�``� S (" �`/�,� G \ C Z. J �i ., . , � �JJ �� � � �: )ff,� Q, -45 q i E[ \ ~J t�� \, �)QQ e�� I 5 \)l �FQ itz- Vt\�jr f -1 SCALE 1:24 000 1 MILE 1-3 RPCC/SANTEETLAH SEPTEMBER 2001 U F+I(sRE 1B n �� • , IMN r _1 ° 42' i' 27 M I LS L - UTM GRID AND 1978 MAGNETIC NORTH' to IafiC�+ r — v I - - - _ 4& - c it i L' R 978� ' J ' Elev-�'ISAN'FEETCAH - Ahi )1940 _ ) Y (L}GB E\LEV'1940 ) BM LHT 9S7 2600 , 1 -_ / Q\ Elev 1940 ?aco 2 BM LH t ' bbrisvllle 5, l,5 IMMIQ 2208 _,17 Ti Elev 19=T0 S A +AT Mile 11 T SCALE 1.24 000 1 MILE ] o 2 l Elev 19 ap — POOL 1-4 RPCC/SANTEETLAH SEPTEM 3ER 2001 FIGURE 2 ALQOA AMBIENT MET DATA -RESULTANT WIND ROSE as .0 210 20 2:! EAST ---> JANUARY 1983 - DECEMBER 1993 AVERAGE WIND SPEED = 2.052 m/s HOURS OF CALM WINDS (< lm/s) = 24, 645- 1-5 RPCC for APGI-TAPOCO/SANTEETLAH NC APPENDIX ACRONYMS USED IN THE RPCC PLAN ACP Area Contingency Plan ANSI American National Standards Institute ASME American Society of Mechanical Engineers ASTM American Society of Testing and Materials BMP Best Management Practices CAA Clean Air Act CAAA Clean Air Act Amendments (1990) CAS No. Chemical Abstract Service Registry Number CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations CHRIS Code Chemical Hazard Response Information System Code COTP Captain of the Port CQA Construction Quality Assurance CSHIB Chemical Safety and Hazards Investigation Board CWA Clean Water Act (Federal Water Pollution Control Act) DOT Department of Transportation DUNS No. Dun's Universal Numbering System (Dun & Bradstreet Number) EHS Extremely Hazardous Substance EPA Environmental Protection Agency (US) EPCRA Emergency Planning and Community Right -to -know Act (SARA Title III) ERAP Emergency Response Action Plan FWPCA Federal Water Pollution Control Act (also known as Clean Water Act) HAP Hazardous Air Pollutant HMTA Hazardous Materials Transportation Act ICS Incident Command System IDLH Immediately Dangerous to Life or Health LEPC Local Emergency Planning Committee MMS Minerals Management Service (Department of Interior) MSDS Material Safety Data Sheet MTR Marine Transportation -related NAICS North American Industry Classification System NCP National Contingency Plan NESHAP National Emissions Standards for Hazardous Air Pollutants NFPA National Fire Protection Association NIOSH National Institute for Occupational Safety and Health NPDES National Pollutant Discharge Elimination System NRC National Response Center OPA Oil Pollution Act (1990) OSC On -Scene Coordinator OSHA Occupational Safety and Health Administration OSRO Oil Spill Removal Organization PCB Polychlorinated Biphenyl This information is the property of Alcoa. It is not to be used, reproduAPP-12 November 2004 ced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC POTW Public Owned Treatment Works PPE Personal Protective Equipment PSM Process Safety Management Conservation and Recovery Act RCRA RPCC Resource Release Prevention, Control, and Countermeasures RQ Reportable Quantity Research and Special Projects Administration (DOT) RSPA SARA Superfund Amendment and Reauthorization Act SDWA Safe Drinking Water Act SERC State Emergency Response Commission SIC Standard Industrial Classification SPCC Spill Prevention, Control, and Countermeasures SWPP Storm water Pollution Prevention TPQ Threshold Planning Quantity TSCA Toxic Substances Control Act TSD Treatment, Storage, and Disposal TTO Total Toxic Organics United States Geological Survey USGS UST Underground Storage Tank APP-13 November 2004 - This information is the property of Alcoa. It is not to be used, reproduced, or copied without express p permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC APPENDIX J OIL POLLUTION ACT (OPA) WORKSHEETS (NOT APPLICABLE) This information is the property of Alcoa. It is not to be used, reproducedAPP 14 led withexpress permission. No warranties, guarantees, or representation, o embe expressed200 o implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC APPENDIX K SITE SPECIFIC HEALTH AND SAFETY PLAN (NOT APPLICABLE) This information is the property of Alcoa. It is not to be used, reproducedAPP copied without express permission. November No warranties, guarantees, or representation, lexpressed P 00or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures. RPCC for APGI-TAPOCO/SANTEETLAH NC APPENDIX L STORM WATER PERMIT (NOT APPLICABLE) APP-16 November 2004 This information is the property of Alcoa. It is not to be used, reproduced, or copied without express permission. No warranties, guarantees, or representation, expressed or implied, are made as to the accuracy, utility or effectiveness of the methods, processes, products, or procedures.