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Spill Prevention, Control, and Countermeasures (SPCC) Plan

Section 2 - General Requirements [40 CFR §112.7]

2.1 - Introduction

This SPCC Plan for CSSA has been prepared to comply with federal requirements under 40 CFR §112, Final Rule and Interim Final Rule, July 17, 2002 and January 9, 2003, hereafter referred to as 40 CFR §112. The purpose of the SPCC Plan is to prevent any petroleum products from entering the environment and navigable waterways of the United States. Therefore the SPCC Plan focuses on the potential release of petroleum, oils and lubricants and hazardous substances to (1) storm sewers or other overland routes that flow into surface water or groundwater and (2) industrial or sanitary sewers carrying materials that are incompatible with that system. The SPCC Plan provides the following:

	Identification of potential spill areas at CSSA;
	Measures to be taken at those sites to contain potential spills; and
	Work practices such as daily monitoring of potential spill areas to prevent spills.

Material presented in the SPCC Plan has been generally arranged in accordance with the requirements of 40 CFR §112. The format of this document is designed to serve as a tool for management and employees to implement, maintain, and document spill prevention control measures and responses. A cross reference of requirements promulgated by 40 CFR §112.7 and their location in this SPCC Plan is presented as Table 2-1.

2.1.1   Conformance 40 CFR §112.7(a)(1)

CSSA is in conformance with the requirements listed in the SPCC regulations effective on August 16, 2002.

CSSA will conduct a review and evaluation of this document at least once every five years. Following this evaluation, amendment to the SPCC Plan will be made as soon as possible, but no later than six months of the review. Amendments will be implemented within six months of the revision. Amendments to the SPCC Plan will be documented in Plan Updates and Plan Review summaries (page xii). Technical amendments must be certified by a Professional Engineer, on the SPCC Certification page in the preface of this report.

Additionally, CSSA will amend the facility SPCC Plan within six months of a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge. Such a change may include: construction or demolition of secondary containment structures, commissioning or decommissioning of bulk oil storage containers or equipment, changes in product use, or revision of maintenance procedures.

Table 2.1 - CSSA 40 CFR §112, Final Rule SPCC Plan Cross Reference

2.1.2   Alternate Conformance 40 CFR §112.7 (a)(2)

Site Security. CSSA is a limited access facility. Security personnel maintain control of access at various entry points 24-hours per day. . The installation is frequently patrolled by security personnel. All oil and hazardous substance activities and areas are under the control of authorized personnel. Bulk fuel delivery vehicles are supervised by CSSA escorts at all times.

Secondary Containment. Where it is not practical that secondary containment structures be constructed, periodic integrity testing of bulk oil storage tanks and periodic integrity and leak testing of valves and piping must be performed. No secondary containment structure is provided for the bulk oil tanks. Where no secondary containment structures are provided, periodic integrity and leak testing of associated transfer valves and piping will be performed. An oil spill contingency plan following the requirements of 40 CFR §109 has been included in this SPCC Plan (Section 2.4)

2.1.3   Physical Layout 40 CFR §112.7 (a)(3)

Figure 2.1 shows the location of the storage tanks and general arrangements of the facility. Also provided on this diagram are flow (slope) directions of rain water (and spilled oil paths). As required under this section, this facility diagram indicates the location and contents of each container. Also listed are the hazardous material storage locations (otherwise exempted).

Table 2-2 contains an inventory of the bulk storage tanks at CSSA including materials stored and secondary containment.

Table 2.2 - Aboveground Storage Tanks

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. Table 2-3 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 a major fire or an explosion with a potential for water pollution.
	Internal explosion of an AST resulting in an explosion and fire with the potential for water pollution.

Table 2.3 - Summary of potential Spill Scenarios and Flow Direction

	Rupture of piping releasing gasoline or diesel fuel which could lead to water pollution with a potential for a 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 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 petroleum naptha vat.
	A small release of a hazardous substance at satellite storage areas.

2.2.2   Spill Flow Direction

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, the location of tanks and the large spill area, it is unlikely that a spill would migrate offsite.

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.

2.2.3   Rate of Flow

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 required to prevent a release of oil from reaching navigable waters, unless determined to be not practicable (40 CFR §112.7(d)). Containment employed at CSSA includes double-walls on all fuel storage tanks, and containment pallets for satellite accumulation storage areas. Where it is not practical that secondary containment structures be constructed, periodic integrity testing of bulk oil storage tanks and periodic integrity and leak testing of valves and piping must be performed. No secondary containment structures are provided for the loading areas of the bulk oil tanks. Where no secondary containment structures are provided, periodic integrity and leak testing of associated transfer valves and piping will be performed. Sorbant materials [40 CFR§112.7(c)(vii)] are emplaced during filling procedures in the event of a spill.

Building 86, the less-than-90-day storage area, has four separate storage cells that include secondary containment. Fuel lines associated with the Building 46 AST/boiler system have secondary containment.

2.4 - Contingency Plan [40 CFR §112.7(d)]

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

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 2.5.

2.4.1   Spill Response Equipment

A complete list of available spill equipment can be found in Table 2-4. Absorbent pad, dikes, and pillows are carried in the escort vehicle during transfer operations. 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 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.

The fire fighting and installation response teams that respond to CSSA are located at Camp Bullis, adjacent to CSSA. 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 backhoes, 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 (FSH) 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. 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. The fire-fighting equipment is maintained by the Camp Bullis fire department.

2.4.2   Firefighting Equipment

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 600,000 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.

2.4.3   Spill Contingency and Response Actions

2.4.3.1   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, or a catastrophic failure of the gasoline tank. 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 a diesel 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.

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 Initial Installation Response Team (IIRT) will evaluate if they can contain the spill safely, including reviewing appropriate material safety data sheet (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.

2.4.3.2   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 post 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 2.2. Figure 2.3 diagrams response actions for oil spills. Section 7 of the ISCP also has details regarding reporting criteria and notification procedures.

Each work area that handles hazardous materials should develop an 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 should 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 2.4 summarizes personnel trained to respond to spills and their qualifications/ training. Detailed information on response duties of personnel is contained in the ISCP, Section 7.

Table 2.4 - Summary of Personnel Duties, Qualifications and Training

2.4.3.3   Evacuation Plan

CSSA has developed an evacuation plan for the installation, including a map in electronic form. Evacuation procedures are discussed in the ISCP (Section 8.2).

2.4.3.4   Intraservice Support

CSSA has established an Intraservice Support Agreement with FSH to provide emergency services in the event of a fire or spill.

2.4.3.5   Spill Reporting

The complete listing of tables containing RQs as designated in the Clean Water Act (CWA), Section 311 or Section 307a, and the Superfund Amendments Reauthorization Act is presented in Appendix A. If a spill of a hazardous substance occurs which does not have an RQ specifically designated by the CWA or Superfund Amendment and Reauthorization Act (SARA), the reportable spill quantity is 1 pound. Flyleaf page ii contains information and contact numbers on agencies to be notified should a release of a RQ occur.

2.5 - Inspections Tests and Records [40 CFR §112.7(e)]

2.5.1   Inspection Program

As required by 40 CFR §112.7(e), the organizations responsible for operation of aboveground storage tanks (ASTs) needs to document that inspections are performed on the tanks and ancillary equipment. Tank inspection checklist and sample tank inspection forms are provided in Appendix C. Completed tank inspection forms, signed by the supervisor or inspector, will be maintained in Appendix C of this plan for a minimum period of 3 years.

2.5.1.1   Aboveground Storage Tanks

All CSSA fuel storage tanks are double-walled for secondary containment. Data gathered from equipment inspections are reviewed to ensure that the tank system is being operated according to design. The ground area surrounding the tank and the area immediately surrounding the externally accessible portion of the tank system is inspected to detect erosion or signs of releases of fuel oil (e.g., wet spots, stains). According to tank inspection guidelines of the American Petroleum Institute, at a minimum ASTs are visually inspected weekly during normal operation.

2.5.1.2   Waste Accumulation Areas

Waste accumulation activities are monitored and inspected by the autho­rized personnel (waste generator) to ensure that the potential spills or release of hazardous constituents are minimized. Personnel inspect and ensure the following items on a regular basis:

	Containers are kept closed except when necessary to add or remove waste.
	Containers are handled or stored in such a manner as to avoid ruptures or releases.
	Containers are inspected weekly for leaks and deterioration, and the information recorded on a log form.
	Incompatible or reactive wastes and materials are not placed in the same container. Containers with incompatible wastes located within the accumulation area are separated by the maximum possible distance.

2.5.1.3   Waste Storage Area

CSSA has one less-than-90-day hazardous waste storage facility, a container storage area (Building 86). This area stores wastes in a variety of containers, which are typically 55 gallons or less in size.

At a minimum, the container storage area is inspected weekly. Any deterioration or malfunction of equipment or structures noted during an inspection will be remedied. If the problem poses an imminent hazard to human health or the environment, remedial action will be taken immediately. The inspec­tion program shall ensure the following:

	Container is labeled on the outside with words "HAZARDOUS WASTE," and container surface is free of leaks, spills, or any apparent contamination.
	Containers are stored properly according to their waste compatibility.
	No more than three 55-gallon waste containers are stored on each pallet, and the pallets are stacked with waste containers no more than two rows high. At no time, is the maximum waste storage capacity of the area (2,500 gallons) exceeded.
	Sufficient aisle space (3 ft., when possible) is maintained for inspections and spill or emergency response activities.
	All monitoring equipment, safety and emergency equipment, and security devices are operational.
	Drums are free of any indications of leaks, corrosion, deterioration, bulging, or damage.
	Proper storage conditions such as aisle space, stack height, and bungs and covers in place.
	Any actual or imminent spills and leaks.
	Condition of the secondary containment structure.

An example inspection form is included in Appendix C. Any spills or leaks found during the inspections must be immediately responded to as described in Figure 2.2 and the ISCP. Any deficiencies and corrective actions taken should be noted in the inspection form.

2.5.2   Preventive Maintenance

Preventive maintenance, as a part of the spill prevention program, involves the periodic lubrication, adjustment, and replacement of worn parts in all equipment where failure could result in a spill of oils or hazardous substances, or could impede response efforts. This includes implementation of all standard operating procedures and recurring maintenance programs for the specific areas. In addition to preventive maintenance, repairs are made as appropriate where determined necessary through the inspection program discussed in Section 5.

2.6 - Personnel, Training, and Discharge Prevention Procedures 40 CFR§112.7(f)

2.6.1   Training Program [40 CFR §112.7(f)(1)]

Personnel training is provided for all CSSA employees involved in activities that may expose them to hazardous substances or health and safety hazards. The training program includes initial training and site-specific training, including on-the-job training. Personnel that deal with POL/hazardous materials receive training and periodic briefings on the SPCC Plan and their responsibilities in the event of a release. Selected members of CSSA staff have also received Emergency Response training and Hazard Communication training.

The following is a brief description of different types of personnel training programs in place at CSSA based on the job duties and responsibilities of the worker.

2.6.1.1   Initial Training

A 40-hour introductory HAZWOPER training is given to all CSSA employees who work or oversee hazardous waste facility operations and to all employees who are involved with the handling of hazardous waste. In the past, continuing training consisting of 8 hours of classroom training has been conducted by the U.S. Army or by other certified training program(s).

The purpose of the introductory and continuing training program is to educate the employees, who are responsible for hazardous waste handling activities and facilities. The training programs are designed to reduce the potential for occurrence of situations which may threaten human health or the environment and to thoroughly familiarize personnel with their duties and responsibilities. The program will make known to the employees the following:

	Safety and emergency response actions and procedures. Procedures delineated in the ISCP are in effect at CSSA and include information on key contact personnel, after hours point of contact, evacuation routes, and location of equipment and absorbents for containment/cleanup of spills.
	Rationale for why certain tasks must be performed in a prescribed manner.
	Hazards of wastes generated, treated, or stored at CSSA.
	State, federal, and ARs for hazardous waste activities.
	Emergency and monitoring equipment (use, inspection, repair, and replacement).
	Automatic cut off systems (key parameters).
	Communication/alarm systems.
	Fire or explosion response.
	Procedures for shut down of operations.
	Response to release of hazardous waste to the environment.

In addition to formal training, on-the-job training is an ongoing process in all operational areas where employees are involved in the management of oil and hazardous substances. This training includes familiarizing personnel with emergency procedures, emergency equipment inspection, location evacuation routes, response to emergencies, and their job duties and responsibilities.

2.6.1.2   Refresher Training

All employees who received initial training also receive annual refresher training as long as they continue to perform hazardous substance related functions. The refresher training will focus on maintaining proficiency, learning new techniques and procedures, and reinforcing safety and quality consciousness. This training also includes any changes or updates in the regulatory requirements. Any critique of incidents that have occurred in the past year that can serve as training examples and other related topics may also be included in refresher training.

2.6.1.3   Record Keeping

Training records are maintained for each employee by the Post Personnel Officer. These records include the name of each employee, the job description of all positions held by the employee, the dates of employment for each position, and a description of the type and amount of training received by each employee.

All personnel who have received and successfully completed the training at CSSA are given a certification of completion by their instructor, head instructor, or trained supervisor. Formal training received by installation employees is annotated on the employee's permanent record. Training records on current personnel are kept on file by the Post Personnel Officer until closure of the facility. Training records on former employees will be maintained for 3 years after the employee last worked at the facility. The records include information such as the dates, type, and amount of introductory and continuing training; training technique; and schedule to be followed by the instructor. After each training session, the training received is annotated on the employee's personnel file.

2.6.2   Designated Person For Spill Prevention

The CSSA Installation Manager has designated the Environmental Officer accountable for discharge prevention at CSSA.

The CSSA Installation Manager has appointed the Camp Bullis Fire Department as the designated response team for spills at CSSA. The Camp Bullis Fire Department is under the direction of the Camp Bullis Fire Chief who will report to CSSA management per 40 CFR §112.7 (e)(10)(ii).

Training for the Camp Bullis Fire Department is discussed in the Oil and Hazardous Substances Emergency Contingency Plan, Camp Bullis, FSH, TX, October 1998.

2.6.3   Spill Prevention Briefings

As required by 40 CFR §112.7(f)(3), periodic spill prevention briefings are conducted for all personnel involved in activities that may expose them to oil, hazardous substances or health and safety hazards. Annual spill response exercises are also conducted, as required by AR 200-1, Chapter 3.

2.7 - Security 40 CFR §112.7(g)

2.7.1   Fencing and Access [40 CFR §112.7(g)(1)]

The entire CSSA installation is bounded by a chain link fence and barbed wire. Entry and access to the installation are controlled at all times by security personnel. The installation is frequently patrolled by security personnel. All oil and hazardous substance activities and areas are under the control of authorized personnel. Bulk fuel delivery vehicles are supervised by CSSA escorts at all times.

2.7.2   Locking of Tanks [40 CFR §112.7(g)(2)]

Motor fuel tanks at Building 4 are locked out at the pump. The boiler and emergency power tanks are plumbed directly to their appliances and are not locked out.

2.7.3   Starter Control on Pumps [40 CFR §112.7(g)(3)]

Starter controls on fuel pumps are locked in the "off" position when pumps are not in use. Pumps may only be accessed by authorized personnel.

2.7.4   Out-of-Service Oil Pipelines [40 CFR §112.7(g)(4)]

Loading/unloading connections of oil pipelines are securely capped when not in service or when on standby service for an extended time.

2.7.5   Facility Lighting [40 CFR §112.7(g)(5)]

Fixed lighting at fuel oil storage areas is very limited and is probably not adequate to allow cleanup of spills or leaks after dark. However, portable lighting is available and receipt and transfer of fuels occurs during working hours only, there is sufficient natural light to initiate containment and cleanup actions for a spill during transfer. Hazardous materials use and storage occurs inside buildings at CSSA. All of these buildings have ample lighting to allow inspection, containment and clean-up to take place at any time of day.

2.8 - Facility Tank Car and Tank Truck Loading/Unloading Rack [40CFR§112(h)]

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.

2.8.1   Facility Transfer Operations, Pumping and Facility Process

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.

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 2.5.

Table 2.5 - CSSA AST Filling Procedures

2.8.2   Containment System [40 CFR §112.7(h)(1)]

As described in Table 2.5, CSSA will provide an overfill/spill containment pad and boom to be placed below the refueling connections prior to initiating refueling.

2.8.3   Warning System [40 CFR §112.7(h)(2)]

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.

2.8.4   Inspection of Drains and Outlets [40 CFR §112.7(h)(3)]

As described in Table 2.5, 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.

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