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Spill Prevention, Control, and Countermeasures (SPCC) Plan
Section 1 - Introduction
This Spill Prevention, Control, and Countermeasures (SPCC) Plan (Sections 1 through 5 of this document) along with the Installation Spill Contingency Plan (ISCP) (Sections 6 through 8 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 SPCC Plan 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 SPCC Plan under federal, state, and Army regulations (ARs). In the event that circumstances warrant implementation of the plan, this plan will be used in conjunction with the ISCP. This SPCC Plan 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.
SPCC plans for facilities are prepared and implemented as required by the Environmental Protection Agency (EPA) Regulation contained in Title 40, Code of Federal Regulations (CFR), Part 112, (40 CFR §112). A non-transportation related facility is subject to SPCC regulations if: the aggregate aboveground capacity of the facility exceeds 1,320 gallons (excluding those tanks and oil filled equipment below 55 gallons in capacity) and if, due to its location, the facility could reasonably be expected to discharge oil into or upon the navigable waters or adjoining shorelines of the United States.
This plan is applicable to:
CSSA;
All active and semi-active military and Army Reserve units located on or utilizing the facilities at CSSA;
Contractors and lessees located on or utilizing CSSA; and
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 SPCC Plan 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 Figures 2.2 and 2.3 of this plan.
In accordance with AR 200-1, this SPCC Plan 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.
An SPCC plan is not required to be filed with the EPA, but a copy must be available for on-site review by the Regional Administrator (RA) during normal working hours. The SPCC plan must be submitted to the EPA Region 6 RA and the state agency along with the other information specified in Section 112.4 (a) if either of the following occurs:
The facility discharges more than 1,000 gallons of oil into or upon the navigable waters of the United States or adjoining shorelines in a single spill event; or
The facility discharges oil in quantities greater than 42 gallons in each of two spill events within any twelve month period.
The following spill information must be submitted to the RA within 60 days if either of the above thresholds is reached. This report is to contain the following information [40CFR§112.4 (a)]:
Name of the facility.
Name of the individual submitting the information.
Location of the facility.
Maximum storage or handling capacity of the facility and normal daily throughput.
The corrective actions and/or countermeasures taken, including adequate description of equipment repairs and/or replacements.
Description of the facility including maps, flow diagrams, and topographical map.
The cause(s) of such spill(s), including a failure analysis of system or subsystem in which failure occurred.
Additional preventive measures taken or contemplated to minimize the possibility of recurrence.
9. Such other information as the Regional Administrator may reasonably require that is pertinent to the plan or spill event(s).
The SPCC plan must be amended within 6 months of a change in facility design, construction, operation, or maintenance that materially affects the facility’s spill potential. The SPCC plan must be reviewed at least once every 5 years and amended to include more effective prevention and control technology, if such technology will significantly reduce the likelihood of a spill event and has been proven in the field. All such amendments must be re-certified by a registered professional engineer (PE).
1.2.2 Definition of Discharge or Spill
A discharge or spill is defined by the State of Texas Oil and Hazardous Substances Spill Contingency Plan (Texas Spill Plan), 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 was 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 (RQ), or in a harmful quantity for that substance, the release should be reported to the appropriate authorities listed in the front of this document. During working hours, releases should be reported to the Environmental Office (210) 698-5208/(210) 336-1266/(210) 861-5217. The Environmental Office will notify the necessary agencies.
Title 30 of the Texas Administrative Code (TAC), further stipulates (in 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 Texas Spill Plan defines the RQ for oil spills as 5 or more barrels (210 gallons) or any quantity of oil spilled in waters of the State. For this plan, 25 gallons should be used as the RQ 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.
For hazardous substances besides oil, 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.
1.3 - 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 (RRAD).
The title and address of the operator of the installation are:
Installation Manager
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 Office
Camp Stanley Storage Activity
Phone: 210/698-5208
Cell Phone: 210/861-5217 or 210/336-1266
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.
1.3.2 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 non-hazardous materials which result in solid wastes that are hazardous and non-hazardous. CSSA is a conditionally exempt 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 frequency.
1.3.3 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 northeast to southwest trending faults and 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.
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 dry most of the year at CSSA except after large rain events. A Leon Creek tributary receives discharge from the on-post wastewater treatment plant (WWTP). A tributary of Salado Creek receives discharge from the on-post granular activated carbon (GAC) system that is used to treat investigation derived waste (IDW). Intermittent flow may be found in these creeks after periods of rain.