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SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN Community College of Rhode Island Warwick, Rhode Island Prepared For: Community College of Rhode Island 400 East Avenue Warwick, Rhode Island 02889 Date: April 25, 2001

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SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN Community College of Rhode Island Warwick, Rhode Island

Prepared For: Community College of Rhode Island 400 East Avenue Warwick, Rhode Island 02889

Date: April 25, 2001

SPILL PREVENTION, CONTROL AND COUNTERMEASURE PLAN

Community College of Rhode Island Warwick, Rhode Island

Prepared For:

Community College of Rhode Island 400 East Avenue

Warwick, Rhode Island 02889

April 25, 2001

TABLE OF CONTENTS

SECTION PAGE

OVERVIEW .................................................................................................................................... i

GENERAL INFORMATION .......................................................................................................... i

PROJECT ADMINISTRATOR APPROVAL................................................................................ ii

PROFESSIONAL ENGINEER CERTIFICATION........................................................................ ii

1.0 INTRODUCTION.....................................................................................................................1

2.0 FACILITY DRAINAGE...........................................................................................................1

3.0 OIL STORAGE.........................................................................................................................2 3.1 Bulk Oil Storage Tanks......................................................................................................2

3.1.1 Diesel Fuel – Boiler Room ......................................................................................2 3.1.2 Diesel Fuel - Field House ........................................................................................3 3.1.3 Diesel Fuel - Pump House .......................................................................................4 3.1.4 No. 2 Oil – Conference Center ................................................................................4 3.1.5 No. 2 Oil - President's House ..................................................................................5 3.1.6 No. 2 Oil – President’s House Garage.....................................................................5 3.1.7 No. 2 Oil - President’s Guest House........................................................................6

3.2 Miscellaneous Oil Storage in Containers...........................................................................7 3.3 Miscellaneous Oil Storage in Equipment ..........................................................................8

4.0 LOADING/UNLOADING PROCEDURES.............................................................................8 4.1 Bulk Oil Deliveries ............................................................................................................8 4.2 Miscellaneous Container Delivery.....................................................................................9

5.0 INSPECTIONS AND RECORDS..........................................................................................10

6.0 SECURITY .............................................................................................................................11

7.0 PERSONNEL TRAINING .....................................................................................................11

8.0 EMERGENCY RESPONSE...................................................................................................12 8.1 Emergency Equipment.....................................................................................................13 8.2 Emergency Procedures.....................................................................................................13

9.0 NOTIFICATIONS ..................................................................................................................14 9.1 Verbal Notifications.........................................................................................................14 9.2 Written Notifications .......................................................................................................15

TABLE OF CONTENTS (CONTINUED)

SECTION PAGE

10.0 SUBSTANTIAL HARM ......................................................................................................17

11.0 PLAN AMENDMENTS.......................................................................................................18

TABLE Table 1 Summary of CCRI’s Oil Storage Locations FIGURES Figure 1 Topographic Map Figure 2 Site Plan APPENDICES Appendix A Inspection Records/Forms Appendix B Spill Equipment List Appendix C Certification of Applicability of Substantial Harm Criteria

REVIEW PAGE In accordance with 40 CFR 112.5(b), a review and evaluation of this SPCC Plan is conducted at least once every three years. The Community College of Rhode Island will amend the SPCC Plan within six months of the review to include more effective prevention and control technology if: (1) such technology will significantly reduce the likelihood of a spill event from the facility, and (2) if such technology has been field-proven at the time of review. Any amendment to the SPCC Plan shall be certified by a Professional Engineer within six months after a change in the facility design, construction, operation, or maintenance occurs which materially affects the facility’s potential for the discharge of oil into or upon the navigable waters of the United States or adjoining shorelines per 40 CFR 112.3(d).

Review Date Summary of Key Changes

SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN Community College of Rhode Island

Warwick, Rhode Island OVERVIEW The purpose of this Spill Prevention, Control, and Countermeasure (SPCC) Plan is to describe the oil storage operations at the Community College of Rhode Island’s Knight Campus (CCRI) located in Warwick, Rhode Island, and to provide information on the prevention of spills, containment of spills, clean-up measures, and reporting procedures to be used in the event of an oil spill at CCRI. This plan is intended to meet the spill prevention and planning requirements of the United States Environmental Protection Agency’s (US EPA) Oil Pollution Prevention Regulations codified as 40 CFR 112 and the Rhode Island Department of Environmental Management’s (RIDEM) Oil Pollution Control Regulations. This plan will be reviewed at least once every three years from the date on which the Chemical Safety Coordinator approves the plan. In addition, this plan will be updated whenever there is a change in the facility design, construction, operation, or maintenance that affects the facility’s potential to discharge oil. All amendments to this plan shall be reviewed and certified by a registered Professional Engineer. GENERAL INFORMATION 1. Name of facility: Community College of Rhode Island - Knight Campus (CCRI)

2. Owner of facility: State of Rhode Island Board of Governors, 301 Promenade Street, Providence, RI 02809, 401-222-6561

3. Type of facility: Educational institution - university

4. Location of facility: 400 East Avenue, Warwick, Rhode Island

5. Designated person accountable for spill prevention, control, and countermeasures at facility: Emanuel Terezakis, PH.D, Chemical Safety Coordinator

6. Spill History: CCRI has had no known oil spills to surface water bodies within the past five years.

7. Flow Prediction: See Figure 2

CCRI SPCC Plan April 25, 2001 Page ii

8. Sensitive Receptor: Pawtuxet River (via the storm drains that discharge to the Warwick Wastewater Treatment Facility)

PROJECT ADMINISTRATOR APPROVAL This Spill Prevention, Control, and Countermeasure Plan will be implemented as described herein. Name and Title: Emanuel Terezakis, Ph.D, Chemical Safety Coordinator

Company: Community College of Rhode Island – Knight Campus Signature: Date: PROFESSIONAL ENGINEER CERTIFICATION I hereby certify that I have reviewed this plan, and being familiar with the provisions of 40 CFR, Part 112, attest that this Spill Prevention, Control, and Countermeasure Plan has been prepared in accordance with good engineering practices. I have relied upon plans, information, and calculations provided by CCRI’s personnel and personnel working under my direction in reviewing the plan. Kelly A. Cowan Printed Name of Registered Professional Engineer Signature of Registered Professional Engineer (Seal) Date:_____________ Registration No: 6833 State: Rhode Island

SPILL PREVENTION, CONTROL AND COUNTERMEASURE PLAN Community College of Rhode Island

Warwick, Rhode Island

1.0 INTRODUCTION The State of Rhode Island Board of Governors owns and the Community College of Rhode Island’s operates an education facility at the Knight Campus in Warwick, Rhode Island (CCRI). CCRI is an educational institution whose facilities are used at times by other agencies and groups for various functions and activities. At CCRI, oils are used to provide heat for the facility and for maintenance purposes. This Spill Prevention, Control, and Countermeasure (SPCC) Plan contains information pertaining to prevention of spills, containment of spills, clean-up measures, and reporting procedures for CCRI. This plan is intended to meet the spill prevention and planning requirements of United States Environmental Protection Agency’s (USEPA) Oil Pollution Prevention Regulations codified as 40 CFR 112 and the Rhode Island Department of Environmental Management’s (RIDEM) Oil Pollution Control Regulations. CCRI is committed to the prevention of discharges of oil to navigable waters and the environment, and maintains the highest standards for spill prevention control and countermeasures through regular review, updating, and implementation of this SPCC Plan. This SPCC plan includes the oil storage locations that are listed in Table 1 and are described in detail in Section 3.0. Figure 1 provides a topographic map for the area surrounding CCRI and Figure 2 is a site plan depicting the CCRI property and associated areas that are covered by this SPCC Plan. 2.0 FACILITY DRAINAGE Throughout the campus there are storm drains that could receive oil in the event of a release. These storm drains, depicted in Figure 2, discharge to the Warwick Wastewater Control Facility and ultimately to the Pawtuxet River. There are also some small wetlands on the property, as well as a small pond near the Conference Center. A rupture in the tanks and secondary containment areas on the site could potentially result in all the oil in a tank being released in a very short time. The amount of oil that would be released would depend upon the type of release and could range from a small drip (from a leaky valve) to over 3,100 gallons (due to massive failure of all tanks simultaneously).

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Clearly, a release from all tanks is not a likely scenario. In addition, it is not likely that oil would reach the storm drains for two reasons. First, adequate secondary containment and other preventative measures have been taken or are planned to prevent such releases. Second, most of the tanks are either located inside the buildings at the campus or are located sufficient distance from the storm drains so that releases from the tanks would be absorbed by the soil between the tanks and the drain. 3.0 OIL STORAGE CCRI has an oil storage capacity of approximately 3,120 gallons of various oils, including No. 2 heating oil, diesel fuel, gasoline, motor oil, hydraulic fluid, and small amounts of other oils. Heating oil and diesel fuel are stored in tanks. All oil storage tanks at CCRI are installed completely above ground with no part of the tank shell in contact with soil. Tanks are constructed of steel or other material compatible with their contents. Pipe supports are constructed of steel, with concrete foundations. CCRI will ensure that all aboveground piping continues to be marked with the product content, origin, and direction of flow. Oil storage areas are listed in Table 1 and are described in the text following the table.

3.1 Bulk Oil Storage Tanks

Diesel Fuel and No. 2 oil are stored in tanks throughout the campus. The storage details and spill prevention measures for these tanks are discussed in this section.

3.1.1 Diesel Fuel – Boiler Room

In the boiler room at CCRI, two 330-gallon single-walled steel tanks are used to store diesel fuel for use with the generators at the facility. The two tanks share a bermed area that is constructed of sealed concrete and which provides secondary containment for over 110% of the capacity of the tanks. The tanks are marked with identification numbers and the appropriate placards are displayed. The tanks are also equipped with level gauges that allow the viewing of the amount of oil in the tanks. The design capacity and working capacity are not marked on the tanks. CCRI will ensure that the design capacity, working capacity, and the words “diesel fuel” are marked on the tanks by May 15, 2001.

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The boiler room is equipped with floor drains designed to protect electrical equipment from a leak or flood. These drains lead to a sump that automatically removes the water and discharges it to the POTW when necessary. The RIDEM has determined that, because the boiler room does not house oil-firing boilers, the drain system is acceptable and requires no modifications. Delivery of diesel fuel is by tank truck at a fill location that is located on the outside of the boiler room wall (on the center of the eastern side of the building under the roof that joins the main structure and the round building). Although the tanks are not visible from the fill location, they are equipped with audible whistles that allow the person delivering the oil to detect when the tank is nearly full. The fill location currently has no containment system but will be equipped with a small spill box (5 gallons) around the fill pipe by October 23, 2001.

As an additional precautionary measure, sorbents and other spill control equipment will be stored in the boiler room to allow for speedy response in the event of a spill or leak. 3.1.2 Diesel Fuel - Field House Outside the northeast corner of the Field House, one 490-gallon double-walled steel tank is used to store diesel fuel for use with a generator. Secondary containment is provided via a double-walled system. CCRI will periodically (during the SPCC inspections) ensure through visual inspection that there is no oil collecting between the two tanks. The tank is marked with the design capacity and the identification number and the appropriate placard is displayed. The tank is also equipped with a level gauge that allows the viewing of the amount of oil in the tank. The working capacity is not marked on the tank. CCRI will ensure that the working capacity and the words “diesel fuel” are marked on the tank by May 15, 2001. Delivery of diesel fuel is by tank truck, directly to the tank. The tank is equipped with an audible whistle that allows the person delivering the oil to detect when the tank is nearly full. There is a small amount of containment provided (via an attached “canister”) around the fill location for the tank. There is one POTW drain approximately three feet from this tank. CCRI will close this drain by October 23, 2001 in order to avoid impacts to surface waters during a release or

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delivery of oil. As an additional precautionary measure, sorbents and other spill control equipment will be stored in the Field House to allow for speedy response in the event of a spill or leak. 3.1.3 Diesel Fuel - Pump House Outside the north side of the Pump House, one 275-gallon double-walled steel tank is used to store diesel fuel for use with a generator. The tank is equipped with a visible and audible leak alarm and a high level alarm. The tank is also equipped with a check valve that will stop the flow of oil from the tank, should a sudden failure in the pipelines occur. The tank is not currently marked with an identification number. CCRI will ensure that the design capacity, working capacity, and identification number are clearly marked on the tank by May 15, 2001. Delivery of diesel fuel is by tank truck, to the fitting on the north side of the building. The tank is equipped with an audible whistle that allows the person delivering the oil to detect when the tank is nearly full. There is a small amount of containment provided (via an attached “canister”) around the fill location for the tank. As an additional precautionary measure, sorbents and other spill control equipment will be stored in the Pump House to allow for speedy response in the event of a spill or leak.

3.1.4 No. 2 Oil – Conference Center Outside the west side of the Conference Center, one 275-gallon single-walled steel tank is used to store No. 2 heating oil for use with the heating system. The tank is equipped with a level gauge that allows the viewing of the amount of oil in the tank. The tank is not currently provided with secondary containment and is not marked with the contents, design capacity, working capacity, and identification number. CCRI will ensure that the design capacity, working capacity, and the words “No. 2 Oil” are marked on the tank by May 15, 2001. CCRI will also install adequate secondary containment (i.e., 110%) for this tank, either by replacing the existing tank with a double walled tank or by installing an impermeable berm, by October 23, 2001. Delivery of diesel fuel is by tank truck, directly to the tank. The tank is equipped with an audible whistle that allows the person delivering the oil to detect when the tank is nearly

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full. The fill location currently has no containment system but will be equipped with a small spill box (5 gallons) around the fill location by October 23, 2001. If the secondary containment that CCRI installs consists of a bermed area, this would be considered adequate fill containment and an additional spill box would not be required. As an additional precautionary measure, sorbents and other spill control equipment will be stored in the Conference Center to allow for speedy response in the event of a spill or leak.

3.1.5 No. 2 Oil - President's House Inside the basement of the President’s House, two 275-gallon single-walled steel tanks are used to store No. 2 heating oil for use with the heating system. The tanks are equipped with level gauges that allow the viewing of the amount of oil in the tank. The tanks are not marked with the contents, design capacity, working capacity, or identification numbers. Secondary containment is provided via the basement walls and the basement floor, which slopes toward the tank. Although the basement floor is not impermeable, a spill from the tanks would be released to the concrete/soils below the tanks and would not discharge to a surface water body (the appropriate cleanup/remediation of the material below the tanks would be required in the event of a spill). In order to avoid such a release, CCRI will construct a dike or berm around the tanks sufficient to contain 110 % or more of the total volume of the two tanks. CCRI will also ensure that the design capacity, working capacity, and the words “No. 2 Oil” are marked on the tank by May 15, 2001. Delivery of oil is by tank truck, to the fill pipe located outside the basement wall. The tank is equipped with an audible whistle that allows the person delivering the oil to detect when the tank is nearly full. The fill location currently has no containment system but will be equipped with a small spill box (5 gallons) around the fill location by October 23, 2001. As an additional precautionary measure, sorbents and other spill control equipment will be stored in the President’s House basement to allow for speedy response in the event of a spill or leak. 3.1.6 No. 2 Oil – President’s House Garage Inside the basement of the President’s House Garage, one 275-gallon single-walled steel tank is used to store No. 2 heating oil for use with the heating system. The tank is

CCRI - SPCC Plan April 25, 2001 Page 6

equipped with a level gauge that allows the viewing of the amount of oil in the tank. The tanks are not marked with the contents, design capacity, working capacity, or identification number. Secondary containment is provided via the basement walls and the basement floor. Although the basement floor is not impermeable, a spill from the tanks would be released to the concrete/soils below the tanks and would not discharge to a surface water body (the appropriate cleanup/remediation of the material below the tanks would be required in the event of a spill). In order to avoid such a release, CCRI will construct a dike or berm around the tanks sufficient to contain 110% or more of the total volume of the two tanks. CCRI will also ensure that the design capacity, working capacity, and the words “No. 2 Oil” are marked on the tank by May 15, 2001. Delivery of oil is by tank truck, to the fill pipe located outside the basement wall. The tank is equipped with an audible whistle that allows the person delivering the oil to detect when the tank is nearly full. The fill location currently has no containment system but will be equipped with a small spill box (5 gallons) around the fill location by October 23, 2001. As an additional precautionary measure, sorbents and other spill control equipment will be stored in the President’s House Garage to allow for speedy response in the event of a spill or leak. 3.1.7 No. 2 Oil - President’s Guest House Inside the basement of the President’s Guest House, one 275-gallon single-walled steel tank is used to store No. 2 heating oil for use with the heating system. Secondary containment is provided via the basement walls and the basement floor. The tank is equipped with a level gauge that allows the viewing of the amount of oil in the tank. The tank is not marked with the contents, design capacity, working capacity, or identification numbers. Although there are numerous rust spots on the tank, the integrity of the tank appears to be intact. However, because the integrity of the tank cannot be verified through visual inspections, CCRI will replace the tank by October 23, 2001. CCRI will also ensure that the design capacity, working capacity, and the words “No. 2 Oil” are marked on the existing tank by May 15, 2001, and on the new tank upon installation. The Guest House is equipped with a sump system that is designed to protect electrical equipment from a leak or flood. The sump, when activated, drains to the lawn outside the Guest House. Water discharged by the sump would be absorbed by the lawn on the west

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side of the building. However, to avoid impacts from oil release to any water body, CCRI will either discontinue use of the sump or will switch the sump to manual operation. This will ensure that any water collected in the Guest House will not be discharged without CCRI personnel ensuring that there is no oil present in the water. Delivery of oil is by tank truck, to the fill pipe located inside the basement bulkhead on the north side of the building. The tank is equipped with an audible whistle that allows the person delivering the oil to detect when the tank is nearly full. Because the fill location is within the bulkhead, and any material spilled during a fill would run onto the basement floor, additional secondary containment around the fill box is not required. As an additional precautionary measure, sorbents and other spill control equipment will be stored in the President’s Guest House to allow for speedy response in the event of a spill or leak.

3.2 Miscellaneous Oil Storage in Containers

As shown in Table 1, the following areas are used to store small (less than 55-gallon) containers of oil, gasoline, and diesel fuel: Maintenance, Motorcycle Garage, Basement Trash Room, Food Services Kitchen, Basement Storage Room, Third Floor Chemistry Lab, and the Maintenance Shop.

The potential for surface water impacts due to a spill from these areas is minimal, since all container storage is located within the buildings. In order to minimize potential impacts, CCRI will ensure that the oil containers are stored away from any doorways or sinks and that all drains in the vicinity of the oil are sealed, either permanently or with a temporary cap that will prevent materials from being discharged without manual removal of the cap. If more than 100 gallons of oil will be stored in the same area (such as in the Maintenance Garage), CCRI will provide secondary containment either through the use of spill pallets or impermeable berms that have the capability to contain at least 100% of the capacity of each individual container or 10% capacity of all the containers stored. These precautionary measures, where required, will be implemented by October 23, 2001. Small containers (less than 10 gallons) that contain flammable liquids, and are required to be stored in a flammable storage cabinet, will not require secondary containment. In addition CCRI will immediately ensure that all containers that are used to store oil are clearly marked with the container contents.

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As an additional precautionary measure, sorbents will be stored nearby each of these areas to allow for speedy response in the event of a spill or leak.

3.3 Miscellaneous Oil Storage in Equipment As shown in Table 1, the following equipment at the facility contains oil: 500 kW generator and air compressors in the Boiler Room, 45 kW generator in the Pump House, and the elevator hydraulic system in the Field House. The potential for surface water impacts due to a spill from this equipment is minimal, since all oil storage is located in equipment that is located within the buildings. In accordance with USEPA guidance, secondary containment is not required for equipment containing oil for ancillary purposes. To minimize potential impacts, CCRI will seal all drains that could be impacted by oil spilled from equipment, either permanently or with a temporary cap that prevent materials from being discharged without manual removal of the cap. If drains cannot be sealed, CCRI will provide other means of restricting the outward flow of water, such as a manually-operating sump. Locations where drains or sumps are located include the Boiler Room and President’s Guest House. The drains in the pump house will not require closure, since only a minimal amount of oil can be discharged to these drains due to the control on the Pump House Tank (see section 3.1.1). By disabling the automatic drainage systems in oil storage areas, CCRI will ensure that any water collected in these areas will not be discharged without CCRI personnel verifying that there is no oil present in the water. These precautionary measures, where required, will be implemented by October 23, 2001. As an additional precautionary measure, sorbents will be stored nearby each of these areas to allow for speedy response in the event of a spill or leak.

4.0 LOADING/UNLOADING PROCEDURES

The facility receives heating oil and diesel fuel via tank truck. Maintenance oils are received in 55-gallon or smaller containers. Gasoline and other miscellaneous oils are received in small (five gallons or less) safety cans as needed.

4.1 Bulk Oil Deliveries

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Prior to bulk transfer of oil (i.e., oil that is pumped from a truck), CCRI personnel will insure that the receiving tank has adequate capacity to receive the volume of oil to be transferred. The following delivery procedures will be used for bulk oil:

1. Drivers delivering fuel oil inform the appropriate CCRI personnel of their presence on site. CCRI personnel verify that adequate tank volume is available for the delivery (level gauge).

2. CCRI personnel assist the driver and oversee the delivery.

3. The driver locates the truck near the fill connection.

4. The driver informs CCRI personnel of the location of the emergency stop switch, if available, that will disable the oil transfer pump on the truck.

5. The handbrake is set and the truck wheels are chocked to prevent vehicular departure prior to disconnecting hoses.

6. Drip pans are placed beneath all hose connections.

7. The driver makes the appropriate connection from the truck to the storage tank with the operator monitoring.

8. Once all the above steps have been taken, the driver will proceed to transfer the oil, listening carefully for the whistle to stop (indicating the tank is nearly full). During transfer, the driver and CCRI personnel will stand away from the area immediately adjacent to the hose connections in case of equipment failure, but will carefully observe the truck and hose.

9. Should a transfer hose fail during the loading process, oil would not be released from the tank because the oil is fed into the top of the tank above the fuel oil level. (Oil could be released from the truck hose. In this case, spill response would immediately be initiated.)

10. Upon completion of the transfer, the driver will ensure that the transfer hose is empty before disconnecting. CCRI personnel will oversee this task. If any oil is spilled outside the drip pans, cleanup will begin immediately as summarized in Section 8.0 of this SPCC Plan.

11. Oil from the drip pans will be properly collected in containers in the storage area.

12. The operator will ensure that the appropriate filling pipe cap/blank has been re-secured and will allow the driver to leave the site.

4.2 Miscellaneous Container Delivery

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When materials are transported on site using a forklift, either a drum attachment is used or containers are strapped to the forklift to prevent the containers from falling during movement. The following outlines delivery and transport procedures for small containers (55 gallons or less):

1. Containers are checked for damaged areas or signs of corrosion. If any is detected, the container contents are transferred to an appropriate container prior to moving.

2. CCRI personnel ensure that the container is closed prior to moving.

3. The container is secured on forks or pallets to prevent it from falling during movement. 5.0 INSPECTIONS AND RECORDS Maintenance procedures are conducted by CCRI personnel on a regular basis to ensure the integrity of each tank. Monthly inspections will be performed on visible portions of the oil tanks, containers, equipment, drains that may be impacted by oil, secondary containment system, and level gauges/alarms. If an inspection reveals a tank failure, monitoring equipment failure, excessive thinning of a tank shell, or any other deficiency, remedial actions will be taken immediately. A sample inspection checklist is provided in Appendix A. Records of all inspections will be signed by an appropriate supervisor or inspector and will be maintained on-site for at least ten years. All records of inspections will include the following information, where appropriate: • Date and time of inspection

• Signature and address of the inspector

• Identification numbers for the tanks

• Results of the inspection, including deficiencies and corrective actions necessary

• Remedial or preventative actions taken

• Explanation of why remedial actions were not completed, if applicable

• Certification by the inspector that the inspection was performed in accordance with the Rhode Island Oil Pollution Control Regulations

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An annual inspection report will be submitted to RIDEM by December 31st of each year. The report will include a summary of the monthly inspections (using the checklists provided in Appendix A or equivalent forms), records for any tests performed, and records of maintenance and upgrades. 6.0 SECURITY The campus is staffed 24 hours a day by the Department of Security and Safety and Campus Police. The CCRI Police Department is an investigative body of officers with the sole purpose of maintaining security and safety, and to assist the student/faculty in any problems or questions that may arise. Normal hours of operation at CCRI are from 7:00 a.m. to 10:00 p.m., Monday through Friday, with shorter hours of operation on Saturdays and Sundays. After hours and during weekends and holidays, the building is locked and entry is monitored through the receiving/security door located on the south side of the main building. The security/college police force is responsible for the following: • Patrolling and safety of the campus - This is a constant around the clock practice and each

officer is trained to check doors, look for anything out of the ordinary, list and report unusual conditions where and when they occur. The patrols are done on foot and by marked vehicle.

• Assembling security reports and making arrests and investigations of all criminal incidents, as well as safety matters - The officers are trained to challenge persons found on campus grounds, during and after hours of operation.

• Verifying that lighting is working, and reporting any failures, when found - Lighting at CCRI is adequate to perform inspections, identify leaks, and prevent spills due to vandalism.

• Answering security alarms when necessary.

• Monitoring the gates inside and outside the building and checking the outbuildings, i.e.; Motorcycle storage shed, garage and the farm structures located on the campus grounds.

7.0 PERSONNEL TRAINING

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Personnel involved in the use and surveillance of oil on campus may include the Chemical Safety Coordinator, the Physical Plant Director, the College Engineer, campus police officers, operation and maintenance personnel, and a secretary. The Chemical Safety Coordinator is the primary individual responsible for overseeing the facility’s SPCC training, inspection, and spill response procedures. Additional individuals assist the Chemical Safety Coordinator with SPCC Plan implementation. These individuals are familiar with the SPCC plan and the procedures that must be followed, as dictated by the plan. If additional individuals will be assigned responsibilities relative to SPCC activities, the Chemical Safety Coordinator will ensure that these individuals are adequately trained in the proper operation and maintenance of equipment as well as in procedures to follow in the event of an emergency. Specific personnel in charge of inspections will be trained for inspection requirements and for assessing methods to be used for release prevention and remedial action. Training will be conducted initially and SPCC briefings will be held annually to ensure personnel are updated with any changes to the SPCC plan. 8.0 EMERGENCY RESPONSE This section describes the emergency equipment that is stored on site and the emergency response procedures that will be following in the event of a release of oil.

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8.1 Emergency Equipment Communication devices, sorbents, absorbent booms, flashlights, shovels, brooms, and personal protective equipment will be stored on-site to handle any incidental spills. A complete list of the types of spill control equipment that will typically be stored on site is provided in Appendix B. CCRI personnel are only authorized to clean up minor oil leaks and spills (those involving a gallon or less of material in accordance with CCRI’s Hazardous Substance Release Emergency Response Plan). Any larger spill of oil may only be handled by one of the following emergency cleanup vendors: American Environmental Technologies, Inc, Clean Harbors Environmental Services, Lincoln Environmental, Inc., General Chemical, and CYN Environmental Services. Any one of these companies may be contacted without further authorization by the Purchasing Department, by the Department of Security and Safety and Campus Police, the Physical Plant Director, the College Engineer, or the Chemical Safety Coordinator. 8.2 Emergency Procedures Warning signs are posted at each oil storage tank, at each smaller oil and gasoline storage location, and at each oil delivery location: The warning signs read as follows:

If a release of oil occurs, the following a

1. Cease oil transfer operations until removed.

2. Contact the Chemical Safety Coordcontainment and removal of the Coordinator cannot be immediately response measures and continue atte

REPORT ALISESE

IMPORTANT! L OIL SPILLS OR LEAKS MMEDIATELY TO CURITY OFFICE CURITY OFFICE

ctions will be taken.

the release is stopped and oil spill debris material is

inator to determine the course of action to take for oil and waste material. If the Chemical Safety

reached, continue with the necessary notifications and mpts to contact the Chemical Safety Coordinator.

CCRI - SPCC Plan April 25, 2001 Page 14

3. Verbally report the incident to authorities, as described in Section 9.0 of this SPCC Plan, where applicable.

4. Clean up oil and chemical releases using mechanical methods, unless directed otherwise by the RIDEM.

5. Initiate other remedial, monitoring, and clean-up actions, if required by applicable regulatory authorities.

6. Submit written reports to authorities as described in Section 9.0 of this SPCC Plan, where applicable.

7. Update notified authorities with new information related to a spill. Oil-contaminated debris resulting from oil releases to the environment (land or water) will be stored in the appropriate designated area pending disposal, and disposal will be performed in accordance with all applicable hazardous waste and/or solid waste regulations. If the debris is determined to be non-hazardous, it will be stored on-site pending disposal at a facility licensed to accept such waste. Records documenting the date the contaminated debris was removed from the site and the location of ultimate disposal will be submitted to RIDEM as necessary and in accordance with pertinent regulatory requirements.

9.0 NOTIFICATIONS In the event of a release, the procedures described in this section should be followed to ensure that the appropriate individuals and agencies are notified.

9.1 Verbal Notifications

The following individuals and authorities will be immediately notified in the event of an oil release or spill:

1. William Mercer, CCRI Physical Plant Director- (401) 825-2111

2. Dennis Melander, CCRI College Engineer - (401) 825-2380

3. Emanuel G. Terezakis, CCRI Chemical Safety Coordinator- (401) 333-7140 office, (401) 333-0678 home, (401) 785-6018 pager

4. The CCRI Department of Security and Safety and Campus Police - (401) 825-2109

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5. Stephen Marginson, CCRI Dean of Administration - (401) 825-2449

6. National Response Center/Coast Guard (if spill causes a film or sheen upon water surface) - (800) 424-8802

7. RIDEM Office of Compliance and Inspection: (401) 222-1360 or (401) 222-3070, if after hours (The Office of Compliance and Inspection will then notify appropriate RIDEM offices)

8. Local Emergency Planning Committee - (Warwick Fire Chief): (401) 468-4000 (Notification to the LEPC is not required by the SPCC regulations but is often recommended by local authorities.)

9. Rhode Island Emergency Management Agency - (401) 946-9996 from 8:30 to 4:00 and (401) 498-1336 all other times (Notification to the SERC is not required by the SPCC regulations but is often recommended by state authorities.)

10. Licensed Cleanup Contractor (for spills that are greater than 55 gallons or that can not be properly contained), contact one of the following:

• American Environmental Technologies, Inc. – (860) 887-1932 or (800) 562-7611

• Clean Harbors Environmental Services – (401) 461-1300 or (800) 641-0007

• CYN Environmental Services – (401) 942-3555 or (888) 827-7455

• General Chemical – (508) 872-5000

• Lincoln Environmental, Inc. – (401) 232-3353 or (800) 659-3353

The following information, at a minimum, will be provided: • Location of the discharge

• Date and time of the discharge

• Characteristics of the discharge (volume, concentration, etc.)

• Any corrective actions taken

• Any other information requested by the authority

9.2 Written Notifications

CCRI - SPCC Plan April 25, 2001 Page 16

Written notifications for spills will be provided to authorities as soon as possible (10 days for RIDEM) and will include the following information:

• Facility name

• Facility owner or operator name

• Facility telephone number

• Facility location and address

• Date and year of initial facility operation

• Maximum storage or handling capacity of the facility and normal daily throughput

• Description of the facility, including site maps, flow diagrams, and topographical maps, if requested

• A complete copy of the SPCC Plan with any amendments, if requested

• Date, time, and place of release

• Amount and type of material released

• Names, addresses, and telephone numbers of all persons potentially responsible for or liable for the release and description of third party damages

• The cause of the spill, including a failure analysis of the system or subsystem in which the failure occurred, and the amount and type of material released

• Description of containment and removal operations, including costs of these operations

• The corrective actions and/or countermeasures taken, including an adequate description of equipment repairs and/or replacements (including any third-party damages and costs of containment and removal operations)

• Additional preventative measures taken or contemplated to minimize the possibility of recurrence

• Any other information the authority may reasonably require pertinent to the SPCC Plan or spill event

In addition, a written report must be submitted to the US EPA Regional Administrator and the RIDEM whenever the facility has:

CCRI - SPCC Plan April 25, 2001 Page 17

• Discharged more than 1,000 gallons of oil into or upon navigable waters of the state or adjoining shorelines in a single spill event.

• Discharged oil in harmful quantities into or upon navigable waters of the state or adjoining shorelines in two spill events within any 12-month period. Harmful quantities include releases that violate applicable water quality standards or cause a film or sheen upon the surface.

The report must be submitted within 60 days and shall contain the information required by 40 CFR 112.4(a). Information submitted to the Regional Administrator should be sent to: Regional Administrator c/o Chief Emergency Response EPA Region 1 E1 Congress Street, Suite 1100 Boston, Massachusetts 02114-2023

10.0 SUBSTANTIAL HARM Non-transportation on-shore facilities that, due to their locations, could reasonably be expected to cause substantial harm to the environment by discharging oil into or on navigable waters or adjoining shorelines must prepare and implement a facility response plan in accordance with 40 CFR 112.20. Facilities that meet certain criteria are considered to pose substantial harm to the environment. A checklist of criteria for substantial harm is provided as part of the regulation and was used to determine that CCRI does not meet the requirements for posing substantial harm to the environment. A certification form and a copy of the checklist are located in Appendix C.

CCRI - SPCC Plan April 25, 2001 Page 18

11.0 PLAN AMENDMENTS This plan will be reviewed and evaluated at least once every three years from the date on which the Chemical Safety Coordinator approves the plan. Within six months of the review, the plan will be amended to include more effective prevention and control technology if: • Such technology will significantly reduce the likelihood of a spill event from the facility.

• Such technology has been field proven at the time of the review. In addition, this plan will be updated within six months of a change in the facility design, construction, operation, or maintenance that affects the facility’s potential to discharge oil into or upon waters of the state. All amendments to this plan will be reviewed and certified by a registered Professional Engineer.

TABLE

Table 1

Summary of CCRI’s Oil Storage Locations

(ID numbers refer to locations on Figure 2) ID No. Location Description 1 Boiler Room Two 330-gallon diesel fuel tanks are located in this area. In

addition, approximately five gallons of motor oil are stored in the 500 kW generator and an additional eight gallons of oil are stored in compressors.

2 Pump House One 275-gallon diesel fuel tank is located in this area. In addition, approximately six quarts of motor oil are stored in the 45 kW generator.

3 Conference Center One 275-gallon No. 2 heating oil tank is located in this area.

4 President’s House Two 275-gallon No. 2 heating oil tanks are located in this area.

5 President’s Guest House

One 275-gallon tank of No. 2 heating oil is located in this area.

6 President’s House Garage

One 275-gallon tank of No. 2 heating oil is located in this area.

7 Field House One 490-gallon tank of diesel fuel is located in this area. 8 Maintenance Gasoline and various oils are stored in this area, including

gasoline, motor oil, used motor oil, transmission fluid, and hydraulic oil. These materials are stored in containers ranging from 5-55 gallons. Approximately 15-20 containers are stored at any given time.

9 Motorcycle Garage Five to ten five-gallon cans of gasoline are typically stored in this area.

10 Basement Trash Room

One 55-gallon drum of used cooking oil is typically held for disposal or recycling in this area

11 Food Services Kitchen

Two ten-gallon drums of fresh cooking oil are typically stored in this are.

12 Field House Elevator

100 gallons of elevator hydraulic fluid are used in this equipment.

13 Basement Chemical Storeroom

One gallon of mineral oil is typically stored in this area.

14 Third Floor Chemistry Lab

Two gallons of vegetable oil and two gallons of mineral oil are typically stored in this area.

15 Maintenance Machine Shop

One gallon of cutting oil is typically stored in this area.

FIGURES

Figure 1 is a topographic map of the site surrounding the facility Figure 2 is a site plan depicting oil storage locations

APPENDIX A

Inspection Records/Forms

INSTRUCTIONS FOR OIL STORAGE TANK MONTHLY INSPECTION Conduct the inspection once per month. If an inspection is not done because there is no oil in the tank, make a notation to this effect on the log. Fill in the date and time of the inspection, the inspector’s name, and the inspectors business address at the top of the log at the time the inspection is performed. For each item, if no deficiencies are noted, state “None” box. If the item is deficient, state the deficiencies and record all corrective actions taken. Record the final resolution or outcome of each corrective action. ALL DEFICIENCIES MUST BE CORRECTED AS SOON AS POSSIBLE. Use the following guidelines for inspecting the tank system, completing the inspection log, and taking corrective actions. The numbering in the following list corresponds to the item numbers on the inspection log. 1. Inspect the area for adequate housekeeping. If there is trash, clutter, or waste in the area, clean it up. 2. Inspect the tank condition (accessible portions of the tank). Check for signs of release of oil or corrosion. Releases of

oil may be evident by observation of liquid in the secondary containment system, or moisture at the seams or other locations on the tank itself. If this is observed, ensure that no additional oil is added to the tank. Steps must be taken to empty the tank and correct the problem. If any signs of rust are observed on the exterior of a tank wall, note the size and location in the inspection log and have the tank repaired/repainted the next time the tank is emptied. In the meantime, continue to watch for any increase in size of the rust spot and any signs of release.

3. Inspect accessible portions of the area immediately surrounding the tank and the secondary containment system to

detect signs of release (e.g., wet spots, stains, etc.). If signs of a release are observed, ensure that no additional oil is added to the tank. Steps must be taken to empty the tank and correct the problem. Inspect the secondary containment system to ensure it is in good condition (e.g., no cracks or gaps in concrete dikes, no signs of corrosion in steel dikes). In addition, the floors and walls should be examined for signs of cracks or deterioration. If deterioration is noted the area should be repaired.

4. Inspect all ancillary equipment. Ancillary equipment includes piping, fittings, pumps, valves, gauges, etc. used to

distribute, meter, or control the flow of oil or to view the level of oil. Inspect all visible portions of the ancillary equipment. Check for signs of releases (e.g., drips, corrosion, damage, missing or loose parts, etc.). If these problems are detected, ensure that no additional oil is transferred to the ancillary equipment. Steps must taken to correct the problem.

5. If any items are noted in the log as deficient, they must be documented and corrected immediately. Describe corrective

actions in the space provided. If more space is needed, use the comment section at the bottom of the table, with a cross-reference to the date and item number. If the integrity of the tank or containment structure is compromised, and/or if there is evidence of a release or potential release of oil, the system must be shut down until the deficiency is corrected, and re-inspected prior to resuming operations.

6. Enter the date that corrective action described above was completed. If corrective action cannot be completed on the

same day as the inspection, indicate the date that it is anticipated to be completed, and, once completed, make a notation to confirm that it was completed and the actual date of completion.

A copy of all inspections will be kept for ten years from the date of the inspection.

OIL STORAGE AREAS MONTHLY INSPECTION CHECKLIST

This inspection was performed in accordance with the Rhode Island Oil Pollution Control Regulations.

Date: Time: Inspector’s name:

Inspector’s Business Address:

Boiler Room (1) Pump House (2) Conference Center (3)

President’s House (4)

President’s Guest House (5)

OK Deficiencies OK Deficiencies OK Deficiencies OK Deficiencies OK Deficiencies Adequate housekeeping (no trash, clutter, or waste in the area)

Tank condition OK (No signs of corrosion, release of oil, etc.)

No signs of release surrounding tank/secondary containment intact (including floors)

Check ancillary equipment from tank to point of oil use

Sensors/gauges functioning properly

Adequate spill response equipment

Corrective Actions (If more space is needed, use comments section)

DATE CORRECTIVE ACTIONS COMPLETED

Additional comments:

OIL STORAGE AREAS MONTHLY INSPECTION CHECKLIST (CONT’D.)

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President’s House

Garage (6) Field House (7) Maintenance (8) Motorcycle Garage (9)

Basement Trash Room (10)

OK Deficiencies OK Deficiencies OK Deficiencies OK Deficiencies OK Deficiencies Adequate housekeeping (no trash, clutter, or waste in the area)

Tank condition OK (No signs of corrosion, release of oil, etc.)

No signs of release surrounding tank/secondary containment intact (including floors)

Check ancillary equipment from tank to point of oil use

Sensors/gauges functioning properly

Adequate spill response equipment

Corrective Actions (If more space is needed, use comments section)

DATE CORRECTIVE ACTIONS COMPLETED

Additional comments:

OIL STORAGE AREAS MONTHLY INSPECTION CHECKLIST (CONT’D.)

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Food Services Kitchen (11)

Field House Elevator (12)

Basement Chemical

Storeroom (13)

Third Floor Chemistry Lab

(14)

Maintenance Machine Shop

(15) OK Deficiencies OK Deficiencies OK Deficiencies OK Deficiencies OK Deficiencies

Adequate housekeeping (no trash, clutter, or waste in the area)

Tank condition OK (No signs of corrosion, release of oil, etc.)

No signs of release surrounding tank/secondary containment intact (including floors)

Check ancillary equipment from tank to point of oil use

Sensors/gauges functioning properly

Adequate spill response equipment

Corrective Actions (If more space is needed, use comments section)

DATE CORRECTIVE ACTIONS COMPLETED

Additional comments:

APPENDIX B

Spill Equipment List

The following provides a list of the typical quantities and types of spill control equipment that will be stored at the facility. The actual spill equipment stored may vary slightly from this list, but will be adequate to respond to a small leak or spill of oil.

Location Description

Boiler Room Five forty-pound bags of oil-dry™ or similar universal absorbent for cleaning up floor spills. Two 30-gallon open head plastic drums for storing contaminated absorbent prior to disposal. One flat shovel for distributing and collecting absorbent. One push broom for spreading absorbent. ten 3m chemical sorbent mini-booms ™ or similar product for keeping oil out of floor drains.

Pump House Five forty-pound bags of OIL-DRY™ or similar universal absorbent for cleaning up floor spills. Two 30-gallon open head plastic drums for storing contaminated absorbent prior to disposal. One flat shovel for distributing and collecting absorbent. One push broom for spreading absorbent. Ten 3M Chemical Sorbent Mini-Booms ™ or similar product for keeping oil out of floor drains.

Conference Center

Five forty-pound bags of OIL-DRY™ or similar universal absorbent for spreading on soil. Four 30-gallon open head plastic drums for storing contaminated absorbent prior to disposal. One spade shovel for distributing and collecting absorbent and contaminated soil.

President’s House

Five forty-pound bags of OIL-DRY™ or similar universal absorbent for cleaning up floor spills. Two 30-gallon open head plastic drums for storing contaminated absorbent prior to disposal. One flat shovel for distributing and collecting absorbent. One push broom for spreading absorbent.

President’s Guest House

Five forty-pound bags of OIL-DRY™ or similar universal absorbent for cleaning up floor spills. Two 30-gallon open head plastic drums for storing contaminated absorbent prior to disposal. One flat shovel for distributing and collecting absorbent. One push broom for spreading absorbent. Five 3M Chemical Sorbent Mini-Booms ™ or similar product for keeping oil out of sump drain.

President’s House Garage

Five forty-pound bags of OIL-DRY™ or similar universal absorbent for cleaning up floor spills. Two 30-gallon open head plastic drums for storing contaminated absorbent prior to disposal. One flat shovel for distributing and collecting absorbent.

Field House Sorbents, as appropriate for the amount of oil stored. Maintenance Five forty-pound bags of OIL-DRY™ or similar universal absorbent for cleaning

up floor spills. Two 30-gallon open head plastic drums for storing contaminated absorbent prior to disposal. One flat shovel for distributing and collecting absorbent. One push broom for spreading absorbent. Ten 3M Chemical Sorbent Mini-Booms ™ or similar product for keeping oil out of floor drains.

Motorcycle Garage

Five forty-pound bags of OIL-DRY™ or similar universal absorbent for cleaning up floor spills. Two 30-gallon open head plastic drums for storing contaminated absorbent prior to disposal. One flat shovel for distributing and collecting absorbent. One push broom for spreading absorbent. Ten 3M Chemical Sorbent Mini-Booms ™ or similar product for keeping gasoline inside building.

Basement Trash Room

Two forty-pound bags of OIL-DRY™ or similar universal absorbent for cleaning up floor spills. One 30-gallon open head plastic drums for storing contaminated

OIL STORAGE AREAS MONTHLY INSPECTION CHECKLIST (CONT’D.)

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Location Description absorbent prior to disposal. One flat shovel for distributing and collecting absorbent. One push broom for spreading absorbent. Five 3M Chemical Sorbent Mini-Booms ™ or similar product for keeping oil out of floor drains.

Food Services Kitchen

One forty-pound bag of OIL-DRY™ or similar universal absorbent for cleaning up floor spills. One flat shovel for distributing and collecting absorbent. One push broom for spreading absorbent.

Field House Elevator

Sorbents, as appropriate for the amount of oil stored.

Basement Chemical Storeroom

Five forty-pound bags of OIL-DRY™ or similar universal absorbent for cleaning up floor spills. Two 30-gallon open head plastic drums for storing contaminated absorbent prior to disposal. One flat shovel for distributing and collecting absorbent. One push broom for spreading absorbent.

Third Floor Chemistry Lab

Two forty-pound bags of OIL-DRY™ or similar universal absorbent for cleaning up floor spills. One 30-gallon open head plastic drum for storing contaminated absorbent prior to disposal. One flat shovel for distributing and collecting absorbent. One push broom for spreading absorbent.

Maintenance Machine Shop

Five forty-pound bags of OIL-DRY™ or similar universal absorbent for cleaning up floor spills. Two 30-gallon open head plastic drums for storing contaminated absorbent prior to disposal. One flat shovel for distributing and collecting absorbent. One push broom for spreading absorbent.

APPENDIX C

Certification of Applicability of Substantial Harm Criteria

CERTIFICATION OF THE APPLICABILITY OF THE SUBSTANTIAL HARM CRITERIA

(per 40 CFR 112.20)

Facility Name: CCRI

Facility Address: 400 East Avenue, Warwick, RI

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 formula1) 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 10, for availability) and the applicable Area Contingency Plan.

Yes No X (capacity is < 1 million gallons)

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-III to this appendix or a comparable formula1) such that a discharge from the facility would shut down a public drinking water intake2?

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 spill 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. Emanuel Terezakis, Ph.D. Signature Name (please type or print)

Chemical Safety Coordinator, CCRI

Title Date

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).