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Spill Prevention, Control, and Countermeasures Plan and Installation Spill Contingency Plan
Section 2 - Spill History [40 CFR 112.7(a)]
2.1 - History of Spill Events [40 CFR 112.7(a)]
In accordance with the provisions of 40 CFR 112.7(a), a record of past spills at CSSA is maintained by the Environmental Office. The records of spills include written descriptions of spills, corrective actions taken, and plans for preventing recurrence.
Any future spills in exceedance of the reportable quantity at the installation requiring implementation of this plan will be recorded as a permanent log and will be filed in Appendix B of this document. An example spill log is also included in Appendix B. The log will contain the following information:
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Site of spill; |
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Amount and type of spill; |
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Time of spill, if known, or time of spill detection; |
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Person detecting spill; |
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Person(s) involved in cleanup; |
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Process of cleanup; |
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Regulatory notification process: name and telephone numbers of persons contacted, respective agencies, and time of contact; |
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Final disposition of the spill: a written record of all events reflecting final disposition of the spill, including plans for preventing recurrence. |
Two spill events have occurred at CSSA since the SPCCP/ISCP was originally issued in 1996, and are summarized below:
February 3, 1999: A hydraulic hose on a tractor broke and released approximately 50 gallons of hydraulic fluid along approximately 1.3 miles of asphalt roadway between Buildings 91 and 5. Sand was spread along the roadway to absorb the fluid. The sand was then swept up, stockpiled and covered with plastic tarps. Laboratory analyses of the stockpiled sand found low levels of TPH. The sand was disposed of as Class 2 waste. TNRCC was notified of the release.
August 2, 1999: Battery corrosion at igloo C-146 caused a release of a small amount of battery acid and caustic gas. The corroded batteries were placed in an overpack container and disposed of by the Kelly AFB DRMS. This release did not leave the igloo and because it did not exceed reportable requirements, was not reported to TNRCC.
2.2 - Spill Prediction [40 CFR 112.7(b)]
40 CFR 112.7(b) requires a prediction of direction, rate of flow, and total quantity of oil which could result from a release due to failure of storage facilities. Appendix F provides a summary for each site at CSSA, which shows direction of flow, and describes potential rates of flow and quantities for each site. Table 2.1 summarizes spill prediction information for potential release scenarios. Potential scenarios are listed in Section 2.2.1.
2.2.1 Potential Release Scenarios
The potential hazards posed by the products and wastes stored at CSSA, if released, could occur during the following scenarios below:
Catastrophic failure of an AST releasing gasoline or diesel fuel which could lead to water pollution with a high potential for a major fire or an explosion.
Internal explosion of an AST resulting in an explosion and fire with the potential for water pollution.
Rupture of piping releasing gasoline or diesel fuel which could lead to water pollution with a high potential for a major fire or an explosion.
Release of gasoline or diesel fuel at the loading areas which could lead to water pollution with the potential for a major fire or an explosion.
Tank trailer accident (such as a collision with a private vehicle at the facility entrance) with the release of gasoline or diesel fuel; the potential for ignition of any released gasoline products is high.
A container storage area with leaking drums, such as punctured by a forklift.
Rupture or leak of tank or other equipment associated with caustic or solvent operations.
Catastrophic failure of fuel tanker truck during AST refueling.
A leak or rupture of a Building 90 bluing or petroleum naphtha vat.
A small release of a hazardous substance at satellite storage areas.
See Figure 2.1 for drainage patterns at CSSA which shows the direction of overland flow in the event of a large release. Flow from a tank rupture or spill from the AST at Building 99 would be to the south, overland, and then to an unnamed tributary of Leon Creek. A release from the two ASTs at the Building 4 refueling station would flow south into natural drainage overland which ultimately drains to Leon Creek. At the Building 46 AST, a spill would flow east to Salado Creek. A spill at the AST at Building 201 would flow southeast to Salado Creek. Considering the relatively small volumes of stored products and wastes, and the permeable nature of CSSA drainage ways and creek beds, a spill would be most unlikely to migrate offsite. See Appendix F for figures of each individual site at CSSA.
Because of relatively shallow soil and extensive areas of fractured limestone substrate, it is likely that there would be a significant vertical component of contamination flow at CSSA. The potential for vertical flow and possible impact to site groundwater would need to be evaluated on a site by site basis.
Flow direction maps were not developed for the container storage (Building 86), satellite accumulation, or the chlorine storage areas. Building 86 is a self-contained hazardous waste storage building. A release in Building 86 would be confined to the building and not enter any drainage. The satellite accumulation areas are located within buildings and contain only small volumes of hazardous materials which are located on containment pallets. A release from an accumulation area would not exit the building or enter any drainage ways. A release of chlorine gas would become airborne and would not impact site drainage ways.
The ASTs are all double-walled and relatively new, therefore, a catastrophic failure of both inner and outer tanks would be unlikely. A more probable scenario would be a leak from failure of a seam or weld, or from piping leading from the AST to boilers or emergency power generation equipment. The rate of flow is dependent on mode and location of failure. Other than a catastrophic failure, the contents would drain through a rupture in approximately 1/2 to 1 hour’s time. It is more likely that this type of leakage would occur over several days’ time and be detected during routine inspections.
The largest quantity of oil or hazardous substance that might be released as a result of a major failure would be 10,000 gallons of gasoline at the Building 4 refueling station. If released, the gasoline would enter a nearby drainage ditch and potentially into an open field, where it would be absorbed in the soil or fractured rock. There are no creeks, streams, or stormwater systems in the immediate area that would be affected by a spill.
2.3 - Secondary Containment [40 CFR 112.7(c)]
As discussed in 40 CFR 112.7(c), containment and/or diversionary structures are recommended to prevent a release of oil from reaching navigable waters. Containment employed at CSSA includes double-walls on all fuel storage tanks, and containment pallets for satellite accumulation storage areas. Building 86, the less-than-90-day storage area, has four storage cells separated with secondary containment. Fuel lines associated with the Building 46 AST/boiler system have secondary containment. Where secondary containment structures do not exist (e.g., piping), these areas have been identified by CSSA for evaluation and scheduling of mitigative actions if necessary. For example, secondary containment for the Building 201 AST system is planned for FY 2001. Tanker truck escort will be equipped with spill pads and booms to be used in the event of a release during refueling operations.
2.4 - Contingency Plan [40 CFR 112.7(d)]
The SPCCP and the ISCP comprise CSSA's contingency plan for response to release of oil or hazardous substances into the environment.