JRW Environmental Consultant's Inc.

DANFORTH AEROSTRUCTURES AVIATION SERVICES

    FACILITY RELEASE AND RESPONSE PLAN

    Note: These are introductory excerpts of a "sanitized" written SPCC Plan

Prepared For: Danforth Aerostructures Aviation Services, 500 Stackley Way, Sterns, Virginia

February 1995; Revised November 1995

TABLE OF CONTENTS

1.0 Introduction, Ownership, Facility Description

2.0 Certifications

3.0 Emergency Contacts

4.0 Personnel Roles, Lines of Authority, Training, and Communication

5.0 Potential Emergency Situations

6.0 Spill Prevention and Control

7.0 Personal Protective Equipment and Emergency Equipment

8.0 Alerting and Notification Procedures

9.0 Response Procedures

10.0 Evacuation Rates and Procedures

11.0 Decontamination and Return to Work Procedures

12.0 Critique of Response and Follow-up

13.0 Past Spill Experience

14.0 Review Dates of this Plan

ATTACHMENTS

Appendix 1    Facility Map

Appendix 2    Hazards Material/Waste List

Appendix 3    Hazards Material Storage Location Maps

Appendix 4    Facility Release Scenarios

Appendix 5    Containment Assessment

Appendix 6    Hazards Material Response Matrix

Appendix 7    Hazards Material Response Checklist

Appendix 8    Evacuation Plan

Appendix 9    Incident Critique Form

Appendix 10  Spill Report Form

Appendix 11  Hazards Waste/Chemical Storage Areas Inspection

1.0 INTRODUCTION, OWNERSHIP, FACILITY DESCRIPTION

Danforth Aerostructures Aviation Services (DAAS) is a repair and overhaul shop for aircraft auxiliary equipment, i.e., landing gear, propellers, hydraulic equipment, and gearboxes. Operations at the facility include equipment tear down, non-destructive testing, paint stripping, blasting, plating, painting, and assembly. A Facility Map is presented in Appendix 1. Repair and overhaul of propellers is performed at an ancillary site. A separate Plan has been prepared for that facility's operations.

Site Name: Danforth Aerostructures Aviation Services Site Owner: TOC Group

Site Address: 45360 Stackley Way

Owner's Address: 400 Park Avenue, Sterns, Virginia 22170 Syracuse, NY 10152

County: Lance Owner's Phone Number: (212) 218 7520

Site Phone Number: (212) 772-8200

Site General Manager: Thomas Whittaker, President

A variety of hazards materials are stored and used at the facility, including oils, lubricants, mineral spirits and other solvents, and plating chemicals. Hazards waste is generated from site operations. The facility is considered a Large Quantity Generator of hazards waste. The only pipelines leading to the facility are natural gas and city-supplied water.

This Facility Release and Response Plan (hereinafter referred to as the Plan) has been developed to satisfy the following Federal, and associated state, requirements:

1. Spill Prevention Control and Countermeasure (SPCC) Plan, 40 CFR 112.3, required under the Clean Water Act (CWA) for facilities that store petroleum-based liquids aboveground in amounts greater than 1,320 gallons (or 660 gallons in a single container) or underground in amounts greater than 42, 000 gallons;

2. Hazards Waste Contingency Plan, 40 CFR 265.51, required under the Resource Conservation and Recovery Act (RCRA) for facilities that generate greater than 1,000 kilograms (2,200 pounds) of waste per month;

3. Emergency Response Plan, 29 CFR 1910.120(q), required under the Occupational Safety and Health Administration (OSHA) for facilities whose employees respond to releases of hazards materials; and

4. Emergency Action Plan, 29 CFR 1910.38(a), required under OSHA for facilities that may potentially have an emergency situation.

In addition, DAAS recognizes its obligations under section 302 of the Superfund Amendments and Reauthorization Act (SARA) Title III and has included facility maps identifying the locations of Extremely Hazards Substances (EHS), as defined under SARA.

DAAS's policies and procedures are designed to minimize the possibility of spills, fires, or explosions. Storage areas and containers are regularly inspected according to Federal Aviation Administration (FAA), OSHA, Environmental Protection Agency (EPA), and National Fire Protection Association (NFPA) guidelines.

Most releases can be handled by facility personnel without external assistance. However, in the event of a fire or large release, the Emergency Coordinator will immediately notify appropriate authorities as detailed in this Plan.

In addition to satisfying specific regulatory requirements, this Plan has been developed to:

1. Protect the health and lives of employees

2. Minimize damage to facilities and materials;

3. Protect the environment and community; and

4. Help to restore facilities and business operations in a timely manner.

This Plan will be reviewed at least annually and, if necessary, amended whenever the following occurs:

1. Regulations are revised which affect this Plan;

2. The Plan fails in an emergency or simulated emergency training exercise;

3. The facility significantly changes its operations;

4. Emergency coordinators and responders are replaced; and/or

5. Emergency response equipment is updated or additional equipment is purchased.

2.0 CERTIFICATION

I hereby certify that I have examined the facility, and, being familiar with the provisions of 40 CFR Part 112, attest that this Plan has been prepared in accordance with good engineering practices.

ENGINEER:

                (please print)

SIGNATURE:

REGISTRATION NUMBER:

STATE OF REGISTRATION:

DATE:                                                     place stamp here

For a consulting proposal (for your project, environmental permit, or written spill plan), call John Wiemhoff at:

JRW Environmental Consulting, Inc., 990 Ponderosa Lane, Barrington, IL  60010     Phone: (847) 705 7781                                   e-mail: jwiemhoff@jrwenviro.com               Web Site: http//www.jrwenviro.com

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