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

Section 9 - Emergency Notification and Personnel Responsibilities

This section presents the responsibilities and duties of organizations and individuals charged with responding to emergency situations at CSSA, and the proce­dures and resources that are available at CSSA for use in responding to emergency situations.  Emergency notification procedures and requirements are also described in this section.  General and specific actions in responding to emergency situations at CSSA are described in Section 10.

9.1 - Organizations and Personnel Resources and Responsibilities

The Camp Bullis fire department is responsible for assessing and responding to emergency spills at CSSA.  The resources and roles in a spill response are detailed in the Oil and Hazardous Substances Emergency Contingency Plan, Camp Bullis, Fort Sam Houston, TX, October 1998.  This section will summarize the specific response capabilities that directly relate to CSSA.

9.1.1   Installation On-Scene Coordinator

The installation on-scene coordinator (IOSC) is the official who coordinates and directs the Army control, response, and cleanup efforts at the scene of an emergency situation, including oil or hazardous substance spills from Army activities on or near the installation.  The Camp Bullis Fire Chief is assigned the responsibility of IOSC for CSSA emergency response.  Specifically, the IOSC will:

	Assess the spill, determine the appropriate response, and mobilize the installation response team (IRT) or selected members and equipment;
	Request assistance from other governmental or private sources, if needed;
	Notify the installation commander of all reportable quantity spills;
	Assist the individual first observing/reporting the spill in completing a spill report;
	Notify appropriate local, state, and federal agencies, as required;
	Review the incident log for all spills;
	Assess, in coordination with the Environmental Office at CSSA, all envi­ronmental damage and recommend appropriate restoration measures;
	Prepare and submit reports to higher headquarters, EPA, and other agencies, as appropriate;
	Test effectiveness of this ISCP by conducting annual exercises as required by AR 200-1; and
	Review the material safety data sheets (MSDSs) at the CSSA Safety Office, the Hazardous Materials Pharmacy, and at the point of use, for all chemicals used or stored at CSSA.

The CSSA Safety Officer will perform the duties of emergency coordinator (EC).  The CSSA Environmental Officer is an alternate EC to assist the IOSC in his/her emergency response and notification efforts.  If both CSSA personnel are unavailable to perform the duties of the EC, the IOSC may perform the EC duties or may designate an alternate EC.  The IOSC or the EC on duty has the authority to commit the resources needed to implement the ISCP.

At least one emergency coordinator will be on call or present at CSSA 24 hours a day to respond to any emergency situations that may require the implementation of ISCP.  Upon arrival at the scene of any emergency, the IOSC or the EC on duty will assume control of the contingency operation.

9.1.2   Initial Installation Response Teams

Employees who have received HAZWOPER training will comprise the initial installation response team (IIRT), first responders at an emergency scene.  Each area or building containing fuel storage tanks or hazardous substances will have its own IIRT.  Any person who first discovers an emergency situation will immediately notify the IIRT and the Security desk at extension 911.  The IIRT will take all measures possible to control and contain the spill until the IOSC arrives at the spill site.  The IIRTs will be on duty only during normal work hours.

The Camp Bullis fire department chief shall be designated as the IOSC.  The fire chief will retain incident command until all threats to life and property are eliminated, at which time the fire chief may transfer site control to the EC or backup EC, as available.

9.1.3   Installation Response Team

The Camp Bullis Fire Department is designated as the installation response team (IRT) that performs response functions as directed by the IOSC.  The IRT will perform prevention, containment, response, and cleanup of emergency situations that may arise at CSSA.  The IRT is led by the IOSC, who is responsible for ensuring the IRT is in compliance with all applicable health and safety requirements during a response action.  The training course agenda and class specifications for the IRT are provided in Appendix D. 

9.2 - Off-Post Spill Response Resources

In addition to the on-post organizations and personnel assigned to the response effort, provisions have been made for notifying off-installation organizations when CSSA spill response resources and expertise are insufficient, and when off-installation water, land, or air are potentially affected.  Some of the major off-post spill response resources are discussed in the following paragraphs.  A current listing of telephone numbers for off-post organizations that can be called to respond to emergency situations at CSSA is provided in Table 9.1.

9.2.1  Local Authorities

Upon the IOSC's request, the Bexar County Sheriff's Office and San Antonio Police Department may assist in securing any on-post areas in close proximity to the spill site, disseminating information to the local populace, and evacua­ting personnel.  The San Antonio Fire Department and Bexar County Volunteer Fire Department may also provide personnel and equipment to control fire hazards.  CSSA is in the process of developing mutual aid agreements with local emergency response agencies.  A list of local organizations that are available for emergency response at CSSA is provided in Table 9.1.

9.2.2   State of Texas Spill Response Center

The Texas Natural Resources Conservation Commission (TNRCC) has developed an emergency response center to respond to spills occurring within the state boundaries.  The spill response center will, at their discretion, provide technical assistance and consultation, and will assess the health hazard to the population in the local area.  A state representative may be dispatched to the scene to assist in containment, cleanup, or evaluation operations.  The state representative will be briefed by the IOSC and may make available state spill response equipment and contractor personnel to assist the IOSC.  The state spill response center is located in Austin and can be contacted during working hours at 512/463-7727.  During nonworking hours, the local TNRCC District 8 office in San Antonio can be contacted at 210/490-3096.

9.2.3   Regional Response Center

CSSA is under the jurisdiction of the EPA Region VI, in Dallas.  The regional response center is able to provide additional equipment, personnel, expertise, and databases to aid in responding to major spills.  The telephone number for EPA Region VI is 214/665-2222.

9.2.4   Chemical Transportation Emergency Center (CHEMTREC)

The CHEMTREC organization runs a 24-hour hotline that issues warnings and limited guid­ance when a spill product can be identified by either chemical or trade name.  CHEMTREC will also assist in contacting the manufacturer or shipper for addi­tional information.  This service should be used whenever adequate spill response information is not available.  The telephone number for CHEMTREC is (800) 424-9300.

9.2.5   Environmental Technical Information System (ETIS)

ETIS is a computer information system which contains federal and state envi­ronmental regulations and directories of federal and state environmental contacts.  The system manager is the U.S. Army Construction Engineering Research Laboratory.  Additional information on the system and how to access it can be obtained by calling (904) 283-1667.

9.2.6   Oil and Hazardous Materials Technical Assistance Data System (OHMTADS)

The OHMTADS database is a computer information retrieval file on various hazardous substances.  The database contains chemical, biological, toxicological, and response information on more than 1,000 chemicals which can be accessed by either chemical or trade name.  The OHMTADS system should be considered for both spill response plan­ning and as a source of information during a spill response.

9.2.7   Volunteer Civic Organizations

Volunteer groups can be requested to assist in the clean-up of any affected wildlife.  Names and contacts within the various civic organizations can be obtained from the San Antonio Chamber of Commerce at 210/229-2100.

9.3 - Emergency Notification

In the event of an emergency situation, the IOSC, EC on duty, fire department, IIRT, and IRT will be called upon to respond.  Other outside emergency response services such as police, fire station, etc., may also be called upon for assistance (Table 9.1).

In addition to emergency notification, response actions will also be conducted to prevent, mitigate, control, and clean up any releases of oil or hazardous substances.  These response action are presented in Section 10.

Any employee that encounters a potential or an actual emergency situation at CSSA should immediately notify the Security desk (extension 911 if calling from a base line with a 295 prefix; from cell phone or outside line, dial 295-7408).  The dispatcher will initially contact the IOSC or his designate on duty and the IIRT.  The dispatcher will then contact appropriate organizations and personnel at the direction of the IOSC.  General emergency response and notification procedures and flows are outlined in Figure 9.1.

The emergency notification procedures outlined in Figure 9.1 are as follows:

1. The CSSA employee who first discovers an imminent or actual emergency situation will mitigate the situation only if the person is trained to do so and such activity can be accomplished safely and quickly.  The employee will then notify the IIRT and Security desk (extension 911 if calling from a base line with a 295 prefix; from cell phone or outside line, dial 295-7408).

2. Security will immediately report the situation to the IOSC, IRT, and the emergency coordinator on duty.

3. Upon arrival at the scene of incident, the IOSC or his/her designee on duty is responsible for implementing initial emergency procedures and for directing the IIRT in emergency response.  The IOSC is also responsible for alerting other on-post and off-post emergency response organizations, and coordinating the entire response actions.  Section 9.1.1 lists a detailed description of the IOSC's duties and responsibilities.

4. The IOSC will identify the source and character of the incident, and the type and quantity of any hazardous material released.  The IOSC will also assess possible hazards to human health or the environment that may result directly from the situation or during the response action.

5. The need for evacuation of buildings or areas may be deemed necessary at the discretion of the IOSC.  Evacuation will proceed according to the evacuation procedures outlined in Section 10 of this plan.

6. If the IOSC determines that the installation has had a spill of a harmful quantity of oil or a release of hazardous constituents which could threaten human health or the environment, the IOSC will immediately make a telephone report to the TNRCC district office or Texas Emergency Response Center.  This telephone report will provide the following information:

	Date, time, and duration of the incident;
	Type and characteristics of material(s) spilled;
	Estimate of the quantity of material;
	Exact location of the spill, including the environmental media (e.g., water, soil, air) affected;
	Source of the spill;
	Name, address, and telephone number of the party in charge of or responsible for the installation or activity associated with the spill;
	Extent of actual and potential water pollution;
	Name and telephone number of the party at the spill site who is in charge of operations at the site;
	Steps being taken or proposed to contain and clean up the spilled material and any precautions (e.g., evacuation) taken to minimize impacts of the spill;
	The extent of injuries, if any;
	Known or anticipated human health risks and, where appropriate, advice regarding medical attention necessary for exposed individuals;
	Possible hazards to the environment (air, soil, water, wildlife, etc.); and
	Identity of governmental and/or private sector representatives responding on-scene.
	In accordance with 30 Texas Administrative Code (TAC) Section 335.153, if the IOSC's assessment of the situation indicates that evacuation of local areas would be advisable, then the IOSC must immediately notify the appropriate local authorities such as fire and police departments, sheriff's office, and local hospitals.  The IOSC must also be available to help appropriate local officials decide whether local areas should be evacuated.

7. In addition, the IOSC will immediately notify the National Response Center and the Texas Emergency Response Center within a 24‑hour period if a reportable quantity of a hazardous substance has been released into the environment.  This notice is required by the CERCLA, SARA Title III, and Chapter 26, Subchapter G, of the Texas Water Code.

	The IOSC will notify the Chief Environmental Division at Red River Army Depot for a significant release of any substance.
	The term hazardous substance under CERCLA Section 103(a) refers to a list of specific substances defined under the act.  Hazardous substances, per CERCLA, do not include petroleum products.  However, the State of Texas defines RQ for oil as a release to the environment exceeding 25 gallons or causes a sheen on nearby surface water.  RQs for hazardous substances are listed in Appendix A.

8. The IOSC will follow up all verbal reports with written notification as required by the applicable federal, state, and Army regulations.

9. The installation commander or his/her designee has the responsibility for releasing information regarding spill events to the public.  Public affairs guidance is provided in Appendix E.

10. Following any incident of a release of 1,000 gallons of oil in a single spill, a significant or harmful quantity of oil spill, or two reportable spills within any 12 month period, the installation is required to submit the SPCCP and this plan for review by the EPA Regional Administrator (Region VI) within 60 days.  CSSA must also submit a written report along with the plan to the Regional Administrator.  The report must include the following information:

	Name and location of the installation;
	Date and year of initial installation operation;
	Name, title, and phone number of person making the report;
	Name, address, and phone number of the owner or operator of the installation;
	Date, time, and type of incident(s);
	Maximum oil storage or handling capacity and normal daily usage rate;
	Description of the installation including maps, flow diagrams, and topographical maps;
	Nature and causes of the spill or release, and analysis of causes of failure in the system or subsystems where the failure occurred;
	Corrective actions and countermeasures taken to respond to the release;
	Additional preventive measures planned or implemented to prevent the incident recurrence; and
	Any other information related to the plans or the spill event that the Regional Administrator may reasonably require.

11. Within 15 days of each incident involving fire, explosion, or release of hazardous wastes or constituents to the environment requiring the implementation of this plan, CSSA must also file a written report to the EPA regional administrator (40 CFR 262.34[d]).  This report must include information listed below:

	Name, address, and EPA identification number of the generator
	Date, time, and type of incident(s)
	Nature of the incident including name and quantity of material(s) involved
	The extent of injuries, if any
	Estimated quantity and disposition of recovered material from the incident.

9.4 - Spill Response Equipment

The Camp Bullis Fire Department has access to a variety of spill response equipment; representative examples are listed in Table 9.2.  Spill control materials and equipment are stored at CSSA, Camp Bullis, and Fort Sam Houston (FSH) for use by the IIRT and IRT.

Spill response kits at CSSA are located at various hazardous substance/waste generation or storage areas:  Buildings 4, 5, 30, 38, 86, 90, 90-2, and 93 have spill response kits.  The locations of these buildings are shown on Figure 4.1. These kits include absorbents, pads and pillows, acid and base neutralizers, personal protective equipment (PPE), etc. 

Spill response equipment available to the Camp Bullis Fire Department include several portable, centrifugal and positive displacement pumps, for responding to spill emergencies.  These pumps are rated for pumping rates varying from a few gallons per minute (gpm) to several hundred gpm.  The pumps are decontaminated after each emergency response use and stored.  Furthermore, CSSA also has various heavy equipment such as back-hoes, drag line, dump trucks, grade-all, etc., which may be used in responding to emergency situations.

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.

9.5 - Personal Protective Equipment

All personnel on the IIRT, IRT, and decontamination unit must have access to appropriate PPE (Table 9.3).  Spill kits in each area include PPE which is appropriate for minor releases.  Protective equipment provides the minimum level of protection for initial site entries until the hazards have been further identified and defined by monitoring, sampling, and other reliable methods of analysis.  Depending on the results of the initial hazard analy­sis, the level of protection may be adjusted by the IOSC.  The equipment will be stored at the Camp Bullis Fire Department for IRT use.

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