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Spill Prevention, Control, and Countermeasures Plan and Installation Spill Contingency Plan
Section 1 - Introduction
This Spill Prevention, Control, and Countermeasures Plan (SPCCP) (Section 1, Section 2, Section 3, Section 4, Section 5, Section 6, and Section 7 of this document) along with the Installation Spill Contingency Plan (ISCP) (Section 8, Section 9, and Section 10 of this document) establishes procedures and guidance for the prevention, detection, and response to spills or releases of oils or hazardous substances on Camp Stanley Storage Activity (CSSA) located near Boerne, Texas, or outside the installation, such as releases of such materials in transit to or from CSSA. The SPCCP identifies potential oil and hazardous substances spill sites and details spill prevention and response procedures, inspection and maintenance programs, and required training of personnel. This plan fulfills the requirements for an SPCCP under federal, state, and Army regulations. In the event that circumstances warrant implementation of the plan, this plan will be used in conjunction with the ISCP. This SPCCP document defines oil and hazardous substances spill prevention, detection, reporting, containment, cleanup, and disposal procedures. The ISCP specifies procedures to be followed when responding to releases, accidents, and spills involving hazardous substances. In addition, the ISCP also defines responsibilities and duties of emergency response teams, the resources available to respond to emergencies, and response actions in responding to a spill.
This plan is prepared to comply with federal regulations such as the Federal Water Pollution Control Act (FWPCA) and National Pollution Discharge Elimination System (NPDES). In addition, the plan also complies with the Texas Oil and Hazardous Substances Spill Prevention and Control Act, and the Army Regulation (AR) 200-1 (March 1997). This SPCCP includes the safety and operational requirements for prevention and identification of spills of hazardous substances.
This plan is applicable to:
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CSSA; |
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All active and semi-active military and Army Reserve units located on or utilizing the facilities at CSSA; |
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Contractors and lessees located on or utilizing CSSA; and |
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Any federal, state, regional, or local governmental or non-governmental agencies, and private or public agencies or organizations who utilize CSSA for any organized or individual actions, projects, or activities. |
The provisions of this SPCCP for CSSA will be implemented immediately whenever there is a potential or an actual discharge or spill of oil or hazardous substances which could threaten human health or the environment. Flow diagrams for response to emergency situations, including oil and hazardous substance spills at CSSA, are provided as Figure 4.2 and Figure 4.3 of this plan.
Federal regulation contained in Title 40 Code of Federal Regulations (CFR) Part 110 defines oil spills or releases that are prohibited under FWPCA. Federal regulation 40 CFR Part 112 provides guidelines for development of an SPCCP to address oil spills or releases prohibited under 40 CFR Part 110. This regulation establishes procedures, methods, and equipment to prevent discharge of oil from non-transportation-related facilities into the environment.
The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) regulation 40 CFR 300.33, the Resource Conservation and Recovery Act (RCRA) regulation 40 CFR 264/5 Subpart D, and AR 200-1 expand the scope of the SPCCP to incorporate hazardous substances as defined in 40 CFR 302.3. In addition, Section 311 of the Clean Water Act (CWA) requires that certain hazardous substance discharges to navigable waters exceeding chemical-specific reportable quantities (RQs) be reported to appropriate government agencies.
Under Superfund Amendment and Reauthorization Act (SARA) Title III, Section 304, the installation must provide immediate notification to the local emergency planning committee (LEPC) and the state emergency response commission (SERC) if there is a discharge or release of a hazardous substance (40 CFR 302.4) that exceeds the RQ for that substance. Appendix A provides a comprehensive list of compounds and hazardous wastes designated as hazardous substances under CERCLA, as well as RQs of hazardous substances. This list is used in determining which spills must be reported within 24 hours, which is required if there is a release equal to or greater than the final RQ designated for each substance.
In accordance with AR 200-1, this SPCCP describes the potential release sites, and equipment and measures available to prevent, control, and respond to releases of oils or hazardous substances. The procedures and policies for the prevention and response of potential or actual emergency situations including releases of hazardous constituents are detailed in the ISCP.
1.3.2 Definition of Discharge or Spill
A discharge or spill is defined by the State of Texas Oil and Hazardous Substances Spill Contingency Plan, Texas Water Commission, now known as Texas Natural Resources Conservation Commission (TNRCC), dated October 1988, as "an act or omission by which oil, hazardous substances, or other substances in harmful quantities are spilled, leaked, pumped, poured, emitted, entered, or dumped onto or into waters in this State or by which those substances are deposited where, unless controlled or removed, they may drain, seep, run, or otherwise enter water in this State." However, the state rules exclude from classification as a spill the discharges that are "authorized by a permit issued pursuant to federal law or any law of this State or that is regulated, with the exception of transportation spills and spills in coastal waters, by the Railroad Commission of Texas (RRC)."
An indoor spill of oil or a hazardous substance onto the floor would not be considered a spill "into the environment" provided that the spill were wholly contained within the facility. However, if a portion of the spilled substance were to enter the environment (e.g., by seeping into the ground, spilling into the storm sewer system, or volatilizing into the atmosphere), it would be considered a release into the environment. If such a spill occurred in a quantity greater than the reportable quantity, or in a harmful quantity for that substance, the release should be reported to the appropriate authorities listed in Figure 9.1 (page 9-5). During working hours, reportable releases should be reported to the state spill response center in Austin 512/463‑7727. During non-working hours, the local TNRCC District 8 office in San Antonio can be contacted at 210/490-3096; EPA Regional Response Center is 214/665-2222. Spills or leaks of nonvolatile liquids or solids onto impervious surfaces or into secondary containment areas do not require implementation of the plan. Discharges of slug flows of oil to the municipal sewer could result in endangerment or release to the environment and therefore may require implementation of this plan.
According to the Texas Oil and Hazardous Spill Prevention and Control Act, Subchapter G, Chapter 26, Texas Water Code, a discharge or spill of harmful quantities means "any quantity of hazardous substance discharge or spill which is determined to be harmful to the environment or public health or welfare, or may reasonably be anticipated to present an imminent and substantial danger to the public health or welfare by the Administrator of the Environmental Protection Agency (EPA) pursuant to federal law and by the executive director."
The TNRCC further stipulates (in Title 30 of the Texas Administrative Code (TAC), Section §334.75 and §334.129) that owners and operators of aboveground or underground storage tanks must report a spill or overflow of oil that results in a release to the environment exceeding 25 gallons or that causes a sheen on surface water. However, the State of Texas Oil and Hazardous Substances Spill Contingency Plan requires that any quantity of oil spilled in the State's water must be reported. Otherwise, the reportable quantity for oil spills is defined as 5 or more barrels (210 gallons). Although this requirement differs from that established in 30 TAC §334.75 and §334.129, 25 gallons should be used as the reportable quantity for oil and fuel spills, as it is a more stringent requirement. However, any oil spill in the state's waters, including those that are less than 25 gallons, must be considered as a reportable spill in accordance with the state's contingency plan.
According to 40 CFR 110 (EPA regulations on the discharge of oil) and the Federal Water Pollution Control Act, Section 311(b), discharges are defined as any discharge of oil into or on the navigable waters, water of the contiguous zone, and waters seaward of the contiguous zone in such quantities that 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.
For hazardous substances besides oil, reportable quantities (RQs) are defined by the EPA in 40 CFR 302, Table 302.4. A copy of this table is provided in Appendix A. In 40 CFR 302, a release is defined as "any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment." Environment is defined to include navigable waters, surface water, groundwater, drinking water supply, land surface or subsurface strata, or ambient air.
1.4 - General Installation Information
Camp Stanley Storage Activity is a Department of Defense (DoD) installation owned by the Department of the Army and operated under the jurisdiction of Red River Army Depot.
The name and address of the operator of the installation are:
Commander,Camp Stanley Storage Activity
25800 Ralph Fair Road
Boerne, Texas 78015-4800
Phone: 210/295-7416
The designated person in charge of oil and hazardous substances and related issues at the installation is:
Environmental Officer, Camp Stanley Storage Activity
Phone: 210/295-7453 and/or 210/698-5208
Cell Phone: 210/861-5217
The Environmental Officer has full authority to implement this plan.
CSSA is located approximately 19 miles northwest of downtown San Antonio in northwest Bexar County, in south central Texas. The installation consists of 4,008 acres immediately east of State Farm-to-Market (FM) Road 3351, approximately 0.5 miles east of Interstate Highway 10. Its eastern boundary and parts of its northern and southern boundaries are contiguous with the Camp Bullis Military Training Reservation. The northern boundary is formed by Dietz Elkhorn/Old County Road and the western boundary is formed by FM 3351. The surrounding area to the west is primarily rural and zoned for residential use. Some commercial development is also present within a half-mile to the west, northwest, and southwest of the installation.
The location and layout of CSSA are shown in Figure 1.1.
1.4.2 Description of Activities
The primary mission of the installation is receipt, storage, and issuance of ordnance materiel as well as quality assurance testing and maintenance of military weapons and ammunition. The management, administration, and functional operations of CSSA must comply with AR 740-1 and other applicable regulations, in support of the DoD Military Assistance Program and other missions as directed by military headquarters.
Operations conducted at CSSA require the use of both hazardous and nonhazardous materials which result in solid wastes that are hazardous and nonhazardous. CSSA is a small quantity generator and the waste generated is largely dependent on workload. These operations are of a batch type and are highly variable in duration and intensity.
1.4.3 Site Topography and Drainage
CSSA is located in south-central Texas on the Balcones Escarpment. Northwest of the installation, the terrain generally slopes upward to the Edwards Plateau; to the southeast, the terrain slopes downward to the Gulf Coastal Plains.
CSSA is characterized by a rolling terrain of hills and valleys in which nearly flat-lying limestone formations have been eroded and dissected by streams draining primarily to the east and southeast. Topographic relief across CSSA ranges from about 1,100 ft to 1,500 ft above mean sea level. Soil cover at CSSA is generally thin (0 to 4 ft. in thickness) and outcrops of porous or fractured limestone formations are common.
Sinkholes are present at CSSA, primarily in areas where porous and fractured limestone formations are exposed. Such sinkholes, fractures and porous rock could provide a conduit for spilled substances to groundwater beneath the facility.
Intermittent creeks and streams dissect the rolling surface features at CSSA. Most major rivers and streams originating in the Edwards Plateau tend to follow northwest-southeast regional fracture patterns. Most of the surface drainage from CSSA flows in a southerly direction into Salado Creek. Industrial areas near the southwestern corner of the facility drain into the Leon Creek watershed. The Cibolo Creek watershed drains from a small, undeveloped area near the northeast corner of the facility. Approximately 75 percent of CSSA is in the Salado Creek watershed, 15 percent in the Cibolo Creek watershed, and 10 percent in the Leon Creek watershed. All of these streams are intermittent at CSSA. Some creeks receive discharges from facilities such as the on-base wastewater treatment plant (WWTP). Intermittent flow may be found in these creeks.
The climate in the area is classified as modified subtropical, predominantly marine during the summer months and continental during the winter months. Summers are hot with daily temperatures above 90°F over 80 percent of the time, and winters are mild with below freezing temperatures occurring an average of only about 20 days per year. Temperature extremes have ranged between 0°F and 108°F.
CSSA is situated between a semi-arid region to the west and the coastal area of heavy precipitation to the southeast. Average annual rainfall is approximately 29 inches. Precipitation is fairly well distributed throughout the year, with the heaviest amounts occurring in May and September. Approximately 61 percent of the rainfall occurs over the period from April through September and is primarily due to thunderstorms. During this period, large amounts of precipitation may fall in a short period of time. Most of the winter precipitation occurs as light rain or drizzle; however, thunderstorms accompanied by heavy rain have occurred in all months of the year.
Northerly winds prevail during most of the winter. Southeasterly winds from the Gulf of Mexico are predominant during the summer but also occur frequently during the winter. The average annual prevailing wind direction is from the southeast, and the average annual wind speed is 9 miles per hours (National Weather Service, San Antonio Airport data).