[Home] [Master Table of Contents]
Spill Prevention, Control, and Countermeasures Plan and Installation Spill Contingency Plan
Section 4 - Storage Facilities [40 CFR 112.7(e)(2)]
The potential release sites include storage facilities, transfer facilities, and processes and operations using oil and hazardous substances. Such sites also include used oil management and hazardous waste management areas and units. This section describes such potential spill sites on CSSA that may warrant the implementation of this SPCCP. Also, this section describes various mechanisms available at the installation to respond to and prevent spills of oils and hazardous substances.
4.1 - Potential Sites Where Releases May Occur
The activities at CSSA that may pose a potential for oil and hazardous substance spills and releases include generation, handling, and management of virgin and used oil, diesel, gasoline, hazardous chemicals, and hazardous wastes. The potential spill sites at CSSA are broadly classified into oil management areas, hazardous substance management areas, and miscellaneous operations areas. The potential release sites are further discussed below, and the locations of these sites are shown on Figure 4.1.
The oil management areas at CSSA include receipt, storage, use, and management areas for fuel, virgin oils, and used oils. The fuels managed at CSSA consist of gasoline and diesel, and the oils consist of motor lubricating oils and hydraulic oils. At present, there are no underground storage tanks (USTs) at CSSA. Fuels and oils at the installation are stored only in aboveground tanks. The oil management areas are described below, and the locations of these facilities are shown on Figure 4.1.
4.1.1.1 Aboveground Bulk Storage Tanks [40 CFR 112.7(e)(2)]
At present, a total of five aboveground storage tanks (ASTs) that store fuels and oils, are located at CSSA. A list of these tanks is presented in Table 4.1, including information such as the tank numbers, capacity, type of secondary containment, tank contents, and the general location of the tanks. All aboveground tanks have double-wall construction. The locations of these tanks are shown on Figure 4.1.
4.1.1.1.1 Bulk Storage Tanks - Compatibility of Material [40 CFR 112.7(e)(2)(i)]
All aboveground tanks at CSSA are composed of steel and were specifically designed for storage of petroleum products. The ASTs meet American Petroleum Institute (API) requirements for fuel storage.
4.1.1.1.2 Bulk Storage Tanks - Secondary Containment [40 CFR 112.7(e)(2)(ii)]
All aboveground tanks at CSSA have double-wall construction for secondary containment.
4.1.1.1.3 Bulk Storage Tanks - Drainage from Dikes [40 CFR 112.7(e)(2)(iii)(A-D)]
Not applicable - CSSA does not have dikes around bulk storage tanks.
4.1.1.1.4 Bulk Storage Tanks - Buried Metallic Tanks [40 CFR 112.7(e)(2)(iv)]
Not applicable - CSSA does not have buried metallic bulk storage tanks.
4.1.1.1.5 Bulk Storage Tanks - Partially Buried [40 CFR 112.7(e)(2)(v)]
Not applicable - CSSA does not have partially buried metallic bulk storage tanks.
4.1.1.1.6 Bulk Storage Tanks - Integrity Testing [40 CFR 112.7(e)(2)(vi)]
CSSA conducts regular inspections of all ASTs on the facility. Records of the results of these inspections are kept in the Environmental Office. Example Inspection Records for ASTs are provided in Appendix C. Because the tanks are relatively small, and have double-walled construction, visual inspections are considered to be appropriate. Integrity testing will be performed should visual inspections reveal any signs of deterioration or leaks.
4.1.1.1.7 Bulk Storage Tanks - Internal Heating Coils [40 CFR 112.7(e)(2)(vii)]
Not applicable - ASTs at CSSA do not have internal heating coils.
4.1.1.1.8 Bulk Storage Tanks - Fail-Safe Engineering [40 CFR 112.7(e)(2)(viii)(A-E)]
Audible overflow alarms are installed on the ASTs at Building 201 and Building 46. There is a computerized automatic tank gauge for the tanks at Building 4. Site gauges are used for the remainder of the CSSA ASTs.
4.1.1.1.9 Bulk Storage Tanks - Effluents [40 CFR 112.7(e)(2)(ix)]
Not applicable - the CSSA water treatment system handles domestic wastewater only.
4.1.1.1.10 Bulk Storage Tanks - Oil Leaks [40 CFR 112.7(e)(2)(x)]
Any visible oil leaks observed during periodic tank inspections are corrected promptly.
4.1.1.1.11 Bulk Storage Tanks - Portable Storage Tanks [40 CFR 112.7(e)(2)(xi)]
Not applicable - there are no portable storage tanks at CSSA.
4.1.2 Used Oil Management Areas
CSSA does not maintain a fleet of cars and trucks. All vehicles are leased from the General Services Administration (GSA), which is responsible for all maintenance. Therefore, the motor pool branch has reduced operations, which has resulted in a great deal of waste reduction. Used oils generated at CSSA are from servicing tractors, heavy equipment and other light machinery used at the facility.
The used oils generated at CSSA are accumulated at the motor pool building in 55-gallon barrels. Separate barrels are assigned for collection of hydraulic oil, engine oil, filters, and antifreeze. Barrels are placed on spill containment pallets. These used oils are classified as nonhazardous class 1 and class 2 industrial solid wastes in accordance with the TNRCC waste classification rules (30 TAC §335.501-334.515). All used oils are transported offsite for recycling.
4.1.3 Oil Receipt/Transfer Operations [40 CFR 112.7(e)(3)]
CSSA periodically receives shipments of oils including fuels, motor oils, hydraulic oils, and greases. Fuels are received in bulk, while oils and grease are generally received in 5-gallon or smaller containers. The bulk shipments are received in tanker trucks, and products are directly pumped from the tanker truck to ASTs. A CSSA escort is provided for all tanker trucks to ensure that fuels are properly and safely transferred to CSSA ASTs. Also, two people will be within visual and vocal contact at all times during bulk loading/unloading or transfer of petroleum products and hazardous substances. CSSA transfer operations are conducted in accordance with federal regulations as summarized below.
4.1.3.1 Transfer Operations - Buried Piping [40 CFR 112.7(e)(3)(i)]
AST piping at Building 46 runs beneath the road way before it reaches the boiler. This piping is double walled for secondary containment. There is no other buried piping for transport of oil or hazardous substances at the facility.
4.1.3.2 Transfer Operations - Out-of-Service Pipelines [40 CFR 112.7(e)(3)(ii)]
Not applicable - CSSA does not have out-of-service pipelines for transport of oil or hazardous substances.
4.1.3.3 Transfer Operations - Pipe Supports [40 CFR 112.7(e)(3)(iii)]
Pipe supports for aboveground piping have been designed to minimize abrasion and corrosion and allow for expansion and contraction.
4.1.3.4 Transfer Operations - Aboveground Piping Inspections [40 CFR 112.7(e)(3)(iv)]
Aboveground piping and valves are regularly inspected in conjunction with inspections of ASTs. Example inspection logs are provided in Appendix C.
4.1.3.5 Transfer Operations - Vehicular Traffic Control [40 CFR 112.7(e)(3)(v)]
All deliveries to CSSA ASTs are accompanied by a CSSA escort. The CSSA escort will ensure that the delivery vehicle does not endanger aboveground piping.
4.1.4 Facility Loading/Unloading Operations [40 CFR 112.7(e)(4)]
CSSA receives oils, including fuels, motor oils, hydraulic oils, and grease; fuels are received in bulk, while oils and grease are generally received in 5-gallon or smaller containers. The bulk shipments are received in tanker trucks, and products are directly pumped from the tanker truck to ASTs.
4.1.4.1 Loading/Unloading Operations - DOT Requirements [40 CFR 112.7(e)(4)(i)]
DOT requirements are followed and enforced during fuel loading and unloading operations. CSSA has developed AST filling procedures to minimize the likelihood of accidental releases during fuel loading operations. These procedures are summarized in Table 4.2.
4.1.4.2 Loading/Unloading Operations - Containment System [40 CFR 112.7(e)(4)(ii)]
As described in Table 4.2, CSSA will provide an overfill/spill containment pad and boom to be placed below the refueling connections prior to initiating refueling.
4.1.4.3 Loading/Unloading Operations - Warning System [40 CFR 112.7(e)(4)(iii)]
During fuel loading operations, the CSSA escort is responsible for preventing the delivery vehicle from departing before complete disconnect of flexible or fixed transfer lines. CSSA will also post warning signs at the four AST sites to help prevent the possibility of a fuel truck leaving the AST site before properly disconnecting the fueling apparatus.
ASTs at Buildings 46 and 201 are equipped with overfill alarms. The Building 4 ASTs have computerized automatic tank gauging.
4.1.4.4 Loading/Unloading Operations - Inspection of Drains and Outlets [40 CFR 112.7(e)(4)(iv)]
As described in Table 4.2, prior to filling and departure of the fuel delivery vehicle, drains and outlets on the vehicle will be examined for leakage and adjusted or repaired, if necessary.
CSSA also receives shipments of motor lubricating oils, hydraulic fluids, and grease. These containers are generally less than or equal to five gallons in size and are received at Building 93. All loading and unloading activities occur in the presence of CSSA personnel and, except when necessary during an emergency, during daylight. Any spills will be responded to immediately as described in this plan.
4.1.4.5 Oil Production, Drilling and Workover Facilities [40 CFR 112.7(e)(5) through (7)
CSSA does not operate any oil production, oil drilling or workover facilities. Therefore, the provisions of 40 CFR 112.7 (e)(5): Oil Production Facilities, 40 CFR 112.7 (e)(6): Oil Drilling and Workover Facilities, and 40 CFR 112.7 (e)(7): Oil Drilling, Production, and Workover Facilities are not applicable to this SPCCP.
4.1.5 Hazardous Substance Management Areas
Hazardous substance management areas at CSSA include receipt, storage, usage, and management areas for hazardous chemicals and wastes containing hazardous constituents. Hazardous chemicals used at the installation include solvents, caustic solutions, paints, and paint thinners. The three main areas hazardous materials are used/stored at CSSA are Buildings 4/5 (Motor Pool), Building 86 (less than 90 day storage area), and Building 90 (Rehab).
CSSA is a small quantity hazardous waste generator (EPA Identification Number TX22100120739). The installation generates hazardous and nonhazardous wastes from various activities involved in performing the primary missions at the installation detailed in Section 1.4.2.
In addition to the wastes generated directly from the primary mission activities, some waste streams are generated from miscellaneous installation support activities. The specific activities involved in managing hazardous and nonhazardous wastes and their locations on the installation are discussed below.
4.1.5.1 Hazardous Substance Receipt, Transfer, and Storage Activities
Hazardous chemicals are received at CSSA generally in 55-gallon or smaller containers. Containers are received at the Building 93 receiving docks. The receiving docks are covered and thus protected from precipitation. All loading and unloading activities occur only in the presence of CSSA personnel and during daylight. Any spills or releases that may occur will be responded to immediately. Chemicals are stored and controlled by the hazardous materials pharmacy at Building 93. The pharmacy is responsible for material inventory, and issuance of appropriate quantities to requestors.
Chlorine gas used for water treatment is stored in cylinders at Building 54, water well 1, the wastewater treatment plant, and chlorine tablets and gas cylinders are stored at the swimming pool. Chlorine tanks are received at the Building 293A and Building 54 where they are used for treatment of drinking water. This gas has a reportable quantity of 10 pounds under 40 CFR 302.4 (Appendix A).
It is the responsibility of the hazardous materials pharmacy to maintain an inventory of all hazardous chemicals at CSSA and ensure that MSDSs are provided in the building for each chemical. Each building or site that uses hazardous chemicals will also maintain an inventory list of the chemicals and appropriate MSDSs. It is the responsibility of the building or site supervisor to insure MSDS sheets are available and that the user reads and understands the products' content prior to use.
4.1.5.2 Waste Generation and Accumulation
Various hazardous and nonhazardous wastes are generated at CSSA from primary mission activities and other base support activities. Hazardous wastes generated at CSSA are accumulated at the point of waste generation in up to 55-gallon containers that are maintained in good condition and are compatible with the material being accumulated.
All waste accumulation activities are under the control of the operator of the process generating the waste. The containers accumulating hazardous wastes are labeled and routinely inspected. Hazardous wastes accumulated at the initial generation points are transferred to the less-than-90-day waste storage facility located at Building 86.
4.1.5.3 Onsite Waste Transfer and Storage
Hazardous wastes accumulated at the initial generation points will be transferred to the storage facility at CSSA for further storage until waste transportation. The less-than-90-day hazardous waste container storage area at CSSA is located at Building 86. This area is managed in accordance with 40 CFR 262.34 and 30 TAC. However, because CSSA is a small quantity generator, the maximum storage time can be extended to 180 days. Pesticides are stored in Building 30. Both Building 86 and Building 30 are prefabricated metal safety storage buildings specifically designed for storage of hazardous materials.
The onsite waste transfer activities include pickup of waste containers from the initial generation points and delivery to the designated waste storage or treatment units. The onsite waste transfers are accomplished using a flat-bed truck.
Hazardous wastes are primarily stored in 55-gallon drums or smaller containers. A 55-gallon waste container may be overpacked in an 85-gallon overpack drum if the primary container is leaking, shows signs of eminent leaks, or is damaged while being handled. There are no hazardous waste storage tanks, vats, or similar bulk storage facilities or units at CSSA. The waste storage activities at CSSA include ensuring integrity of waste containers, storage facility operation and maintenance procedures, inspections, and record keeping.
Offsite waste transfer and disposal may be initiated from initial waste generation points or the waste storage area. The offsite waste disposal facilities may include offsite incineration and landfilling facilities. All offsite transfers from CSSA will be initiated and conducted by CSSA through the Defense Reutilization and Marketing Service (DRMS) or a contractor. This plan describes only the waste management activities that occur on the installation.
4.1.6 Miscellaneous Operations Areas
In addition to the oil and hazardous substance management areas described above (Section 4.1.1 and Section 4.1.5), various operations at CSSA manage solid and hazardous wastes. The specific activities involved in miscellaneous operations and their locations on the installation are discussed below.
4.1.6.1 Solvent/Bluing Operations
Building 90 contains solvent tanks used for cleaning parts. Solvent tanks are located over containment tanks. The building also has a satellite accumulation area for used solvents, which are accumulated in barrels on containment pallets. Building 90-1, the Bluing Shop, contains caustic tanks and a single barrel (on a containment pallet) which is used to accumulate impurities skimmed from the caustic tank. Building 90-2 is used for machinery storage and equipment for tumbling or cleaning parts using steel shot, glass beads or other abrasives. Building 90 contains 4 spill response kits, and Building 90-2 also has an oil spill response kit.
A solvent recovery machine is located outside Building 90-1 in a covered area. This machine is used to recover solvents through a distilling–type process. The entire apparatus is located inside of a metal secondary containment structure. The solvent recovery machine is currently not operational. CSSA has contracted with an outside company with a mobile, self-contained recycling unit that is brought to CSSA and operated.
General refuse consists of office wastes, food wastes, plastics, waste cardboard, wood and metal wastes, residential trash, and construction trash. These are classified as general installation refuse and are disposed of in an offsite municipal landfill.
Empty containers result from emptying the wastes or materials contained in the original containers. Some empty material containers are used to place compatible wastes of similar composition (e.g., empty solvent containers for spent solvents). The empty containers intended for discard are classified as nonhazardous Class 1 or Class 2 industrial solid wastes and are managed at offsite facilities.
4.1.6.4 Investigation-Derived Wastes
Various environmental investigations have been and will be conducted at CSSA. These investigation activities result in wastes such as soil boring cuttings, well development and purge water, general investigation trash, and decontamination wastes. Cuttings and development/purge water are normally stored on-site while awaiting analytical results, then disposed of on-site or off-site depending on the results of the laboratory analyses. General investigation trash (such as used personal protective equipment (PPE), disposable bailers, etc., are placed in plastic bags and disposed of as municipal solid waste. Decontamination fluids are drummed and either taken off-site for disposal or decontaminated using the CSSA granular activated carbon filter (GAC) system.
4.2 - Spill Prevention Measures
Spill prevention, control, and countermeasures procedures, methods, and equipment have been developed and implemented for the installation oil and hazardous substance management areas. Spill prevention measures include specific structures, equipment, procedures, and policies to ensure that the potential for spills is minimized. In addition, spill response measures will be undertaken once a spill occurs (Section 4.3).
An integral part of the spill prevention measures includes preventive maintenance and monitoring activities such as routine inspections, monitoring, operational procedures, etc. The inspection and preventive maintenance program is discussed in Section 5.
4.2.1 Spill Response Equipment
The installation has spill response kits in Buildings 4, 5, 30, 38, 86, 90, 90-2, and 93 for small spills. The spill response kits include absorbent pads and pillows, and acid and base neutralizers, and are stored in a barrel which may be used as an overpack or for disposal of clean-up materials. CSSA also has heavy equipment that could be utilized in the event of an emergency release situation. This equipment includes two backhoes, one water truck, one front end loader, one bulldozer, and one dump truck.
The fire fighting team and installation response team that responds to CSSA is located at Camp Bullis, adjacent to CSSA. The heavy equipment needed for spill response is also located at Camp Bullis and is under the responsibility of the Department of Public Works. Available heavy equipment includes back-hoes, drag line, dump trucks, and grade-alls, which may be used in responding to emergency situations. The Camp Bullis fire fighting team also has spill response equipment including absorbent materials, an explosion-proof pump, and wetting agent for gasoline spills. In addition, Fort Sam Houston fire station maintains a spill response van that may be used for spill incidents. Response equipment is discussed in detail in the ISCP.
Emergency supplies consumed in an emergency situation will be replenished as soon as possible. Spill kits are monitored on a monthly basis. During the month, it is the general responsibility of area workers to maintain the spill kits and notify the Environmental Office of any deficiencies of supplies. The spill response supplies at Buildings 4, 5, 30, 38, 86, 90, 90-2, and 93 are inspected by CSSA personnel. The fire-fighting equipment is maintained by the Camp Bullis fire department.
Adjacent to CSSA, Camp Bullis maintains a full-time fire department equipped with firefighting trucks and pumper trucks. These trucks are maintained with sufficient water for initial fire fighting activities. If additional water is needed, these trucks can be refilled from the CSSA water distribution system. The system contains a water reservoir that can hold approximately 603,000 gallons of water.
Various types of fire extinguishers and automatic sprinkler systems are located throughout the installation. CSSA also owns and maintains a 750-gallon water truck which is available for use in emergency situations.
4.3 - Spill Contingency and Response Actions
4.3.1 Potential Spill Scenarios
CSSA has identified worst case, medium case and small case potential spill scenarios. Analysis of these scenarios is used to develop response plans for each scenario type.
Worst Case. The worst case scenario at CSSA would be a fuel tanker truck releasing its entire load during refueling operations. As shown in Table 2.1, this scenario has the potential to release up to 9,000 gallons of fuel.
Medium Case. An example medium case scenario at CSSA would be the failure of an AST, releasing some or all of its contents. As Table 2.1 shows, such a scenario would result in the release of up to 2,000 gallons of diesel or up to 10,000 gallons of gasoline.
Small Case. An example of a small spill would be a leak in a solvent or nickel penetrate vat in Building 90. Such a spill would not be expected to leave the building. After notifying security, the IIRT will evaluate if they can contain the spill safely, including reviewing appropriate MSDS if necessary. If feasible, the IIRT will contain the spill using spill pads and/or absorbent material from the Building 90 spill kit. The spilled substance and absorbent will be picked up and placed in a drum for proper disposal.
4.3.2 Response Actions - Personnel Duties and Qualifications
In the event of a spill or release of oil or hazardous substances, the person that discovers the event will 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. A flow diagram of the response actions to emergency situations is provided for quick reference purposes in Figure 4.2. Figure 4.3 diagrams response actions for oil spills. Section 9 of the ISCP also has details regarding reporting criteria and notification procedures.
Each work area that handles hazardous materials will develop an Initial Installation Response Team (IIRT). Each IIRT will be made up of personnel from that area that are familiar with the materials used, the physical layout of their work area, and the locations, contents, and limitations of their areas' spill kit(s). The IIRT will be responsible for containment of releases in their area when they have necessary equipment. Also, they shall not place themselves or others in jeopardy by their response.
Table 4.3 summarizes personnel trained to respond to spills and their qualifications/ training. Detailed information on response duties of personnel is contained in the ISCP, Section 9.
CSSA has developed an evacuation plan for the installation, including a map in electronic form. Evacuation procedures are discussed in the ISCP (Section 10.2).
CSSA has established an Intraservice Support Agreement (ISA No. W45NQP-00275-143) with Fort Sam Houston to provide emergency services in the event of a fire or spill.
The complete listing of tables containing RQs as designated in the Clean Water Act, Section 311 or Section 307a, and the Superfund Amendments Reauthorization Act is presented in Appendix A. If a spill occurs of a hazardous substance which does not have an RQ specifically designated by the CWA or SARA, the reportable spill quantity is 1 pound. Section 9.3 (ISCP) contains information and contact numbers on agencies to be notified should a release of a RQ occur.