**RESPONSE TO COMMENTS**

**National Weather Service River and Weather Forecast Office, Portland
Oregon and**

**Remote Data Acquisition Site, Washington County, Oregon**

**I. Comments from Minh Trinh**

[NWS - Remote Data Acquisition Site in Washington County of
Oregon.]{.underline}

1.  Part IV, Subpart B, Paragraph 1. Is tightness testing every 3 years
    necessary? What is the manufacturers recommendation? I think the
    testing is too conservative. The tightness testing should be done
    only if the structure integrity of the system is compromised by
    either mechanical joint breaching due to repairs, corrosion, and/or
    sign of cracking. I would like to see your rebuttal.

The recommendation for tightness testing has been removed. The
interstitial monitoring devices should signal a problem with the
integrity of the primary tank. Visual inspections of the outside of the
secondary tank for cracks or leaks or other anomalies should serve to
signal a potential problem with its integrity. If a problem is suspected
with either tank, tightness testing should be initiated soon after
discovery.

2.  Part IV, Subpart B, Paragraph 2. Who specifically needs the
    training? "Facility personnel" is a vague body. If they are the
    "Responsible Manager" and the "Spill Prevention Representative",
    then let's spell it out. It does not to define these titles. Is
    there any OSHA training for conducting countermeasures (e.g., use of
    spill cleanup kits)

All personnel who are responsible for supervising the filling of the
tank and who are responsible for the inspection, maintenance, and
operation of the emergency backup power system (tank, piping, alarms,
and generator) are required to have training. Part II.A.5 has been
revised to clarify this issue.

3.  Appendix B. Being a remote site, how often do we go up there? Is
    monthly inspection practical?

According to National Weather Service (NWS) personnel at the Portland
Weather Forecast Office and River Forecast Center (WFO/RFC), technicians
are at the Remote Data Acquisition (RDA) site on a routine basis at
least once a week, and more often if there are issues that need
resolution.

4.  Appendix B, Tank Inspection. Should add a visual check of the tank
    exterior for cracks.

This has been added to the checklist.

5.  General. Should date all pages (as a footer) to reflect the proper
    version of SPCC plan.

The final version will have the date on all page footers.

6.  General. Please ensure the SPCC plan is printed double-side where
    possible.

The final versions of all Spill Prevention, Control, and
Countermeasure(SPCC) plans have been printed double-sided

7.  Do we have a date of initial operation?

The date of initial operation is March of 1995 and is in Part I,
paragraph 3.

8.  General. From your description, it is remotely likely that a spill
    from this site could reach US navigate-able water. Thus an SPCC plan
    is not required. However, that does not mean we shouldn't have a
    spill response plan in place. I think what you've developed is a
    good precautionary measure. But what worries me is the commitment to
    the formal SPCC requirements once we finalize the plan. This is a
    resource intensive commitment and I don't know if it's something
    that NWS is willing to accept. What's your recommendations for this
    site that could preserve/promote the precautionary measure to
    prevent and control spills but at the same time would not sign us up
    to the rigorous requirements of SPCC regulations.

The RDA site is not located [adjacent]{.underline} to navigable water or
waters of the U.S. and there are no storm drains that may directly
convey spilled fuel to these waters. If this site was located in a drier
climate, I would tend to agree that it could not reasonably be expected
to impact navigable waters or waters of the U.S. The site, however, is
located in the hills west of Portland, Oregon that gets relatively large
amounts of precipitation (there were 4 inches of snow when we did the
inspection). The U.S. Geological Survey (USGS) topographic map of the
area shows a tributary to McKay Creek about 1/4 to 1/2 mile from the
site. My contact at the U.S. Environmental Protection Agency (U.S. EPA)
Region 10 on a \"hypothetical site\" like this one, told me that they
assume (under a worst case scenario) that the ground is frozen and the
fuel would runoff down the access road into the ditches along the main
road. If it then warmed up and rained heavily (again worst case
scenario) the fuel could be washed from the ditches to tributaries to
McKay Creek, too small to show up on the USGS map.

I agree that committing NWS to the full SPCC requirements at sites where
there is serious doubt regarding affecting navigable waters or water of
the U.S. is a bad idea. For remote sites in drier climates like Salt
lake City and other areas, we will make a judgment on a site by site
basis whether there is a threat to navigable waters or waters of the
U.S. This likely can only be done after looking at the facility.
Therefore, there may be some sites where we visit a site but not prepare
a formal SPCC plan. For these sites, I would recommend that they use the
inspection checklists (to minimize spills from worn equipment) and a
refueling checklist with training (to minimize spills during refueling).

[NW Weather Forecast & River Forecast Center]{.underline}

9.  Comments number 1, 2, 5, and 6 of the RDA SPCC plan in Washington
    County apply.

See responses to comments 1,2,5, and 6, above.

10. Should have a refueling checklist develop to ensure the
    following: 1) the catch basin drain valve is shut prior to fuel
    transfer, 2) if the tank automatic shut-off valve is removed, then
    ensure the fuel supplier is using the self shut-off nozzle (similar
    to the one used at gas station), 3) ensure sufficient spill response
    materials are sufficiently stocked for potential spill, 4) ensure
    power to high level alarm is on, and 5) the catch basin drain valve
    is re-positioned open after refueling operation.

Part II.A.2 (renamed Tank Truck Unloading Operations) in the final
version contains a step-by-step procedure for preventing spills during
refueling. This includes requiring the presence of a NWS employee at all
times during the procedure. A checklist outlining these procedures has
been added to Appendix A.

11. Might consider enlisting a contractor to call upon for assistance in
    a spill situation. Someone who is capable of handling a 2000-gal
    spill and familiar with Oregon environmental regulations in both
    areas of spill response and petroleum soil contamination.

The names and telephone numbers of 3 spill response contractors have
been received from Brian Alley and have been incorporated in the final
version in Part III.B.5.

**II. Comments from Robert Kinsinger**

[SPCC for WFO]{.underline}

12. Page 6 - Spill Reporting: Change the name from Neil Lutz to Bob
    Kinsinger, same phone number, but ext 223.

This change has been made and included in the final version.

13. Page 7: Please provide the name and phone number of at least 1 (2
    preferred) emergency response contractors whom the Portland Office
    could call to assist with clean-up. Brian Alley at Portland may be
    able to assist you with some info he already has.

See response to comment 11.

14. Page 8: For my info only, could you provide the names and part
    numbers of urethane spill barriers you mention?

One of the suppliers we have used is called "New Pig"
([www.newpig.com](http://www.newpig.com/) or 1-800-468-4647). The model
PLR230 is a urethane spill barrier, triangular in cross-section, 2-1/4
inches high and 10 feet long. This supplier also sells urethane mats for
covering catch basin inlets which may prove to be useful.

15. Appendix C: Could a copy of Title 40 CFR Part 112 be incorporated
    into the SPCC as another appendix section? It would be most useful
    for each office to have a copy of such.

A copy of the regulations has been included in the final version after
Appendix C, Training Outline.

[SPCC for RDA]{.underline}

16. Page 6 - Spill Reporting: Change the name from Neil Lutz to Bob
    Kinsinger, same phone number, but ext 223.

See response to comment 12.

17. Page 7: Please provide the name and phone number of at least 1 (2
    preferred) emergency response contractors whom the Portland Office
    could call to assist with clean-up.

See response to comment 13.

18. Appendix C: Could a copy of Title 40 CFR Part 112 be incorporated
    into the SPCC as another appendix section? It would be most useful
    for each office to have a copy of such.

See response to comment 15.

19. Page 9, Table 1: Typo - \"grater\" should be \"greater\".

This correction has been made in the final version.

20. Also when the final versions are ready, please be sure to send one
    copy of each to me at the Region HQ in Salt Lake City as well as to
    the offices.

Five copies of the final version will be produced one each for: the
person at the facility responsible for spill prevention (Brian Alley),
the responsible manager (Steve Todd), the Contracting Officers Technical
Representative (COTR-Minh Trinh), the NWS Regional Environmental/Safety
Coordinator (Robert Kinsinger), and the NWS Environmental Compliance
Officer (Mike Jacob).

**III. Comments From Yelena Platt**

21. Part I: Page 1. Replace "Area Safety Representative" with
    "Environmental/Safety Focal Point"

According to Brian Alley, "Area Safety Representative" is his title.

22. Part I, Section B(1), first paragraph - remove "one" before "tank"
    in the last sentence.

This change has been made in the final version.

23. Part III, Section B: Add NWS Safety Officer, Olga Kebis (301)
    713-1838 ext 173 and NWS Environmental Compliance Officer, Mike
    Jacob (301) 713-1838 ext 165

This change has been made in the final version.

24. Part III, Section B: Add National Response Center 1-800 number.

This change has been made in the final version.

25. Part III, Section B: First sentence states that [all]{.underline}
    oil spills are to be reported. Later, the instructions are given on
    how to report all significant spills. It is not clear, what quantity
    of spill should require reporting and to whom. What is "threatened"
    release? Does EPA need to be notified and under which circumstances?
    A name and phone number of the local emergency response contractor
    needs to be included

Part III.B has been revised to provide instructions on whom to notify
and when. It should be noted that Title 40 CFR Part (entitled "Oil
Pollution Prevention") does not [require]{.underline} that
[immediate]{.underline} spill notification information be in SPCC plans,
since these plans are primarily designed to [prevent]{.underline}
spills. In regards to notification, the SPCC regulations only require
that EPA be notified within 60 days if [either]{.underline} of the
following occurs:

-   *A discharge of more than 1,000 gallons of oil into or upon
    navigable waters or adjoining shore lines in a single event, or*

-   *Two spill events that cause visible sheens upon navigable waters or
    adjoining shore lines within any 12-month period*

However, Title 40 CFR Part 110.6 (Discharge of Oil-Notice) requires the
National Response Center (or the U.S. Coast Guard) be notified as soon
as anyone has knowledge of any discharges of oil in quantities that "may
be harmful." Title 40 CFR Part 110.3 defines "may be harmful" as:

-   Violates applicable water quality standards; or

-   Causes 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

The requirement to notify the National Response Center is usually put in
SPCC plans for convenience. Detailed internal procedures for responding
to spills are beyond the scope of this SPCC plan.

26. Part IV, Section B(1): Regulations do not require tightness testing
    every 3 years.

See response to comment number 1.

27. In some places, SPCC plans are written as audit reports:
    deficiencies were observed and documented and corrective actions
    were recommended. The style of presentation could be modified.
    Recommendations may be included as a separate attachment.

The style of the text has been made more consistent with a "plan."
Recommendations have been moved to the cover letter.

**IV Comments From Olga Kebis**

28. Page iii, Management Approval: Second paragraph states that
    reporting to EPA should be done when single event occurs or when two
    spill events in harmful quantities occur within 12 months. This
    paragraph could be moved to Part III, Section B, Spill Reporting,
    unless it is required to be on a signature page. Harmful quantities
    should be defined or an excerpt from regulations (Title 40 CFR 110)
    shall be added to the plan as an attachment.

The Management Approval Page and Part II.B have been revised to clarify
these issues.

29. Part I, Section B(1), first paragraph: Check the size of an
    emergency generator. I believe it should be 150 kW instead of 1,500
    kW.

According to Tom Page, NWS Salt Lake City, the generator is rated at 300
kW. This change has been made in the text.

30. Part I, item 6: The phone number shown here is the number during
    business hours. I believe that MIC is on 24-hour call (or may be
    other designated personnel). Therefore, I suggest to include an
    alternative phone number that allows to reach somebody after regular
    duty hours.

After business hours, the same number is called, then extension zero is
keyed in at the prompt. The caller is then routed through to someone
actively working at the facility. This information has been included in
the final version. This information has been added to Part I, Paragraph
6.

31. Part I, item 2: River and weather forecast office - start with
    capital letters

Part I.A.1 has the name of the facility beginning with capital letters.
Item 2 merely describes what they do at the facility and is not a name.

32. Part II, Section A(1): The fuel oil tank, piping, valves and
    associated alarm system diagram shall be part of this plan. The plan
    calls for training on tank monitoring system, however, we do not
    even know the parts of the system. The requirement is also part of
    SOW.

The example SPCC format in the SOW was taken from a plan Tetra Tech
prepared for the National Marine Fisheries Service (NMFS) in Little Port
Walter, Alaska. This site had multiple storage tanks and day tanks and
the piping diagram was necessary for clear presentation of the operation
of the facility. The information in the piping diagram was provided to
Tetra Tech from NMFS and was redrafted to include some updates. If the
NWS has similar diagrams, they can be incorporated into these plans to
assist in the required training.

33. Part II, Section A(2): The bulk transfer operations shall be
    described in a bullet format as a checklist. Add a bullet stating
    that any oil spilled in the spill box should be cleaned up
    immediately.

See response to comment 10. A bullet that includes cleaning up oil in
the spill box has been added.

34. Part II, Section B(1): Word "elements" should be replaced with more
    appropriate word.

The word has been removed.

35. Part III, Section B: It is done very poorly. This section should
    describe what to do in case of small and big spills (e.g., to call
    fire department, 911 or clean up company first). It looks like
    bullet No. 1 is out of place. It also should describe what to do
    with used absorbent material.

See response to comment 25. Proper disposal of used absorbent is beyond
the scope of an SPCC plan. I recommend calling the local garbage
collection contractor to see if, and how much, they will accept. The
spill cleanup contactors listed in the final plan can also help on this
issue.

36. Part III, Section B: The first paragraph should state: "\...all oil
    spills that result from facility operations to NWS/NOAA
    representatives and to local, State, and Federal agencies if
    applicable." Local Emergency Commission is not mentioned in the
    plan. Have reporting procedures been checked with local authorities?

See response to comment 25. The Oregon Emergency Management (OEM)
Division listed in the plan is the local emergency commission. Under the
Federal Emergency Planning and Community Right-to Know Act (EPCRA), the
OEM should know that the facility is storing more than 10,000 pounds of
number two diesel (approximately 1,450 gallons). The local fire
department should also be aware of the fuel storage at the facility.
These notifications are beyond the scope of an SPCC plan.

37. Appendix D: Is this a standard State of Oregon form? If not, we
    would like to add additional box - NOAA/NWS points of contact. A
    note should be added somewhere in the document that copies of spill
    reporting forms must be sent to NOAA RECO and NWS Environmental
    Compliance Officer.

This is not a State of Oregon form but one Tetra Tech developed to do
the notifications. The NOAA/NWS points of contact have been added. A
note has been added in the plans and to the form specifying that copies
of the forms must be sent to the NOAA RECO and NWS Environmental
Compliance Officer.

**V. Comments From Jeff Walker**

[Comments to SPCC Plan for NWS RDA Site, Washington County,
Oregon]{.underline}

38. Table 2, Potential Spill Sources and Volumes does not include a
    scenario for a leak or break in the overhead piping between the
    Convault tank and generator building. Is this a valid scenario?

The likelihood of a break in the overhead piping appears to be low and
it is secondarily contained in another pipe. This has been described in
the final version.

39. Are there any scenarios in which the generator room pump could keep
    operating after a leak or rupture develops and drain the entire
    Convault tank?

Table 2 has been revised to include a scenario when a line fails and the
pump drains the entire tank.

40. In Part II.A.1, the explanation of the 10‑gallon spill box is
    confusing. Does the spill box drain [to]{.underline} the primary
    tank or drain the primary tank? Also, why isn't the generator tank
    considered in the plan?

The explanation regarding the spill box has been clarified. The
generator is fed directly from the day tanks. The 1,000-gallon tank that
is referred to as the "Generator Tank" feed the day tanks. The name of
this tank has been changed to "Storage Tank" to avoid confusion.

41. Is there a procedure for reacting to a day tank high‑level alarm
    from the WFO/RFC?

There are currently no written procedures for this particular
occurrence. The revamped spill reporting section (III.B) is written such
that it includes spills caused by the day tank.

42. In Part II.A.2, 3rd part, consider rewording "\...the main tank is
    scheduled to have an audible alarm \..." to "\... the main tank is
    scheduled for installation of an audible alarm\...". Make similar
    change to Table 1, Additional Information, for the Generator tank.

These changes have been made.

43. In Part IV.A.1, consider increasing the quantity of spill kit
    material. Supplies for a four‑gallon spill seem inadequate for a
    site with 1500 gallons.

This recommendation has been incorporated in the final version.

44. In Part IV.B.3, the term "portable tank" is used in reference to the
    Convault tank. This is confusing. Also, it appears that the term
    "generator tank" is used to describe the Convault tank. Tank names
    should be consistent.

See response to comment 40.

45. The text infers that a NWS employee has been present when the
    contractor fills the Convault tank. If this is true, I think we
    should state it as normal procedure.

See response to comment 10.

46. The issue of this being an unmanned site is not addressed. The point
    is that a leak or spill may go undetected for some time. Is there a
    normal frequency of checking this tank? Should we try to find a way
    to increase the frequency?

The primary purpose of this plan is to **[prevent]{.underline}** spills
from occurring. Also, See response to comment 3.

47. In Table 1, "\... grater \..." should be "\... greater \...".

See response to comment 19.

48. App. C.A, "\... Tile 40 \...\" should read "\... Title 40 \..."

This change has been made in the final version.

49. In App. E, some of the paragraph references in the column "Plan
    Location" are incomplete (e.g., "Part I 3\" should be "Part I
    B.3\").

These changes have been made in the final version.

[Additional Comments for WFO/RFC SPCC Plan]{.underline}

50. Are there no day‑tanks at the WFO/RFC?

Information on the day tank has been included in the final plan.

51. Comments for the RDA SPCC Plan should be checked for applicability
    to the WFO/RFC plan.

Applicable changes to the RDA SPCC have also been made to the WFO/RFC
SPCC.