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Spill Prevention, Control, and Countermeasures Plan and Installation Spill Contingency Plan

Section 10 - Emergency Response Actions

10.1 - Emergency Response Procedures

If an oil or hazardous substance release, fire, or explosion is imminent or actually occurs, the IOSC must immediately identify the character, exact source, amount, and areal extent of released materials.  The IOSC should accomplish his/her assessment by observation, supplemented by knowledge of installation operations, characteristics of material(s) released, and available information such as MSDSs.  Concurrently, the IOSC will assess the possible hazards to human health or the environment that may result from the release, fire, or explosion.  This assessment must consider both direct and indirect effects of the release, fire, or explosion (e.g., the effects of any toxic, irritating, or asphyxiating gases that may be generated, or the effects of any hazardous surface water runoff from water or chemical agents used to control fire and heat-induced explosions).

10.1.1   Immediate Actions - Discharge Detection by CSSA Personnel

The immediate responsibility for taking actions rests with the area supervisor, senior employee and IIRT on the scene.  Any employee discovering the emergency will take all steps possible to immediately combat the emergency, reduce the hazard, then contact his/her supervisor as soon as possible. 

The following actions must be taken if safe to accomplish.  These actions are prioritized based on an additional person being on-site to ensure that person’s safety.  If more than one employee is on-site, then the following actions can be assigned to specific employees to reduce the time required to isolate the discharge site, make immediate notifications, and initiate control actions.  When there are several employees on-site, the senior employee is responsible for ensuring these actions are safely accomplished.

1. Warn personnel within the immediate area.  Have nonessential personnel evacuate from downgradient and downwind areas and report to a predesignated meeting place. Evacuated personnel (if any) should prevent any vehicles (other than emergency response) from entering the area.

2. Notify the security desk at extension 911, if the caller is using a base line with the 295 prefix.  If the caller is using a cell phone or outside line, he/she should dial 295-7408 to contact the security desk.

3. Stop the product flow at the closest valve and/or shut down pumps, if it can be accomplished safely.

4. Isolate the discharge spill area and shut off ignition sources, if it can be accomplished safely.

5. Initiate control action to confine and contain the release to the smallest area possible, if it can be accomplished safely.

6. Pass any information to the IOSC or EC when emergency response teams arrive. 

10.1.2   Emergency Containment Procedures

During an emergency situation, the IOSC must take all reasonable measures necessary to ensure that fires, explosions, and releases do not occur, recur, or spread to other oil, hazardous waste, or substance management areas at the installation.  Such measures, as applicable, are as follows:

1. Stop all activities and operations involving hazardous substances or wastes

2. Coordinate with other installation operations which may be affected

3. Contain and collect released wastes

4. Remove or isolate containers with spill residues and wastes

5. Remove bulk flammable liquids from any threatened tanks

If CSSA discontinues operations in response to a fire, explosion, or release, the IOSC will monitor for leaks, pressure buildup, or rupture in valves, pipes, tanks, or other equipment.  This monitoring also includes visual inspection of the storage areas, storage tanks, and truck loading/unloading area to ensure that all liquid transfer operations have been terminated properly.

10.1.3   Spill Containment and Cleanup Procedures

The initial action in containing and cleaning up spilled material is to eliminate the source of the spill by turning off pumps, closing valves or other appropriate action.  Simultaneous effort will be made to contain the material that has already been discharged.  The cleanup procedures that are used would depend on volume of spill and location.  General rules to follow in the event of a spill are:

1. Shut off all valves or pumps to stop the flow of material, if it can be accomplished safely

2. Discontinue all spark-producing activity

3. Be prepared to use fire extinguishing equipment

4. Be prepared to use protective equipment

5. Contain spill with sorbent material

6. Use nonsparking tools for cleanup and covered drums for disposal.

All spill containment should be performed under the direction of the IOSC or an alternate EC.  All spill cleanup should be under the direction of the Environmental Officer.  Small spills may be cleaned up without the assistance of the IOSC with the approval of the shop supervisor and the Environmental Officer.

Spill control equipment include Alconox, nonsparking tools, absorbents, fire blankets, pads and pillows, acid and base neutralizers, mercury absorbents, etc.  A complete list of spill control equipment is presented in Table 9.2.  Personal protective equipment is also located with the spill control equipment and consists of SCBA, full-face and half-face respirators, respirator cartridges, gloves, boots, Tyvek suits, etc.  Any pumpable spills or spill cleanup residues will be transferred to appropriate containers using dedicated pneumatic pumps.

Large-volume oil spills that may occur inside a building or within containment structures will be pumped into 55-gallon wet waste containers.  Any spill situations will be evaluated as to the accumulation of the contents before manually operating the pumps to ensure no liquids will be discharged to drainage areas.

Small-volume spills and pipeline leaks will be contained and cleaned up by use of sorbents.  The spilled material should be contained by a dike of sorbent material.  Additional sorbent material will be used to cover the spilled material.  The sorbent material that has soaked up the spilled liquids will be then placed in appropriate wet-waste containers.  All spill residues will be disposed of at an approved and appropriate facility for treatment or disposal.

10.1.4   Specific Potential Emergencies

10.1.4.1   Fire and/or Explosion

If a fire or explosion should occur, principal emphasis will be placed on evacuation of threatened personnel.  After evacuation is complete, emphasis will be placed on preventing the fire from spreading to nearby areas.  If it can be accomplished safely, nearby combustibles and flammables threatened by the fire will be removed.  CSSA receives fire protection support from Camp Bullis.  This support will respond to CSSA emergencies on a 24-hour basis.  The Camp Bullis Fire Department has also entered into mutual fire protection assistance agreements with the Bexar County Volunteer Fire Department and the City of San Antonio Fire Department.  These departments will provide additional assistance under the direction of the ISOC in the event off-post equipment or capabilities are required to contain or extinguish fires.

The major fire and explosion hazards exist at:

	Truck loading/unloading areas,
	Solvent and waste transfer areas,
	Flammable liquids and chemicals storage areas, and
	Hazardous waste container storage areas.

The Camp Bullis Fire Department, which is organized, trained, and equipped to fight fires under hazardous conditions, is on call to CSSA 24 hours a day, seven days a week.  In addition to fire fighting, the Camp Bullis Fire Department will provide rescue services which may require the use of self-contained breathing apparatus (SCBA) and first aid services.

Upon discovery of a fire, employees not trained in the use of portable extinguishers will evacuate immediately.  Employees trained in the use of portable extinguishers shall attempt to extinguish fires in their early stages only.  When fires are beyond the starting stage, all personnel will evacuate.

10.1.4.2   Container Spills and Leaks

Container spills may occur in many locations within the installation.  The major locations of concern are:

	Hazardous waste storage area, Building 86
	Chemical and flammable liquids storage areas, Building 90, 93, etc.
	Within the installation during transit of materials or wastes
	Within the installation during receiving of materials from off-post facilities.

The main types of containers used are 55-gallon drums and 5-gallon containers.  Small volume spills will be treated as described above under the spill containment and cleanup procedures (Section 10.1.2).  Leaking drums will be placed in secure overpack containers.  The leaking drum and overpack are then properly disposed of in accordance with EPA and TNRCC regulations.

10.1.4.3   Tank Spills and Leaks

The aboveground storage tanks (ASTs) at CSSA are used to store diesel and gasoline.  The ASTs are double-walled tanks, which provide secondary containment.

Only trained personnel are authorized to fill the CSSA ASTs.  A CSSA escort, equipped with a mobile spill kit, will accompany the fuel truck and provide guidance and support during transfer operations.  All fuel transfer operations are to follow CSSA AST Refueling Procedures.  These procedures are listed in Table 4.2.  All bulk liquid handling operations will take place during the daytime and during normal working hours, except when necessary during emergencies.  In the event of a leaking or ruptured tank, the affected tank will be emptied below the area of the leak, and the necessary repairs will then be made.  However, it may be necessary to remove all fuel from the tank if any heat/spark producing repairs to the tank are deemed necessary.  Depending on the amount of liquid to be pumped from the leaking tank, an additional tank may have to be used to transfer the contents while repairs are being performed.

10.1.4.4   Bulk Loading/Unloading Area

Bulk loading or unloading is performed at the diesel and gasoline storage tanks.  Loading and unloading of oil occurs in the presence of trained and designated personnel.  Any spills during these activities will be controlled, contained, and managed using procedures described under Section 10.1.2.

10.2 - Evacuation Plan

In the event of a major emergency, an established set of procedures must be followed.  The internal telephone is used to notify key personnel of the nature of the emergency and recommended plan of action.  Evacuation may be initiated by the IOSC, the Commander, a supervisor, or the Environmental or Safety Officers.  In the event an evacuation is called for, the following actions will be taken. 

	A call for evacuation will be initiated.
	No further entry of visitors, contractors, or trucks will be permitted.  All nonessential traffic within the post will cease, to allow safe exit of personnel and movement of emergency equipment.
	IOSC will use the internal telephone system to inform the area supervisors of the nature of the emergency.  In the event of an evacuation, CSSA personnel will exit the base through Gates 2, 5, 8 or 9.  The departure gate will be selected to avoid the areas where a hazardous condition may exist. All employees will be accounted for by their immediate supervisors.
	All personnel, visitors, and contractors will evacuate according to the evacuation plan provided in this section.
	During exit, each supervisor is responsible for keeping his or her group together.  Immediately after exiting through a gate, the highest ranking supervisor will prepare a list of all personnel.
	No personnel will remain on or reenter the site unless specifically authorized by the IOSC.  The IOSC assumes responsibility for those personnel remaining or allowed within the site perimeter, which will normally be only emergency response personnel.
	Upon completion of the employee list by each supervisor, the emergency coordinator will be notified.
	The site will be reentered only after clearance is given by the emergency coordinator.  At his or her direction, a signal or other notification will be given for reentry into the area.
	In all questions of accountability, immediate supervisors will be held responsible for those persons reporting to them.  Visitors are the responsibility of those persons administering the individual contractors.  Truck drivers are the responsibility of the area supervisor where the trucks are loading or unloading.
	A security guard at the gate will maintain an updated list of all personnel, visitors and contractors to aid in the accountability procedure.  Security personnel will aid in accounting for visitors, contractors, and truckers by referring to the sign-in records at the security gate, Building 79.
	Drills will be held to practice the implementation of all of the above procedures as part of the general training effort.  Evacuation of individual buildings is rehearsed in annual fire and spill response drills.