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Spill Prevention, Control, and Countermeasures (SPCC) Plan
Section 3 - SPCC Requirements for OnShore Facilities [40 CFR §112.8]
3.1 - General Requirements [40 CFR §112.8(a)]
40 CFR §112.8 contains requirements for owners and operators of facilities that manages petroleum and non-petroleum oils. Such facilities are required to meet all the general requirements. CSSA meets all the general requirements specified in 40 CFR §112.7.
3.2 - Facility Drainage [40 CFR §112.8(b)]
CSSA does not employ diked areas as secondary containment. Therefore, drain and discharge requirements are not applicable at this facility. Drainage from specific areas where tanks are located and ponds are illustrated in Figure 2.1.
CSSA does not use lagoons or catchment basins. CSSA does not have a centralized ditch drainage system. In the event of an uncontrolled discharge, given the relatively small size of the storage and the porous nature of surface materials, it is unlikely the spill would reach the facility boundary in surface water pathways.
3.3 - Bulk Storage Containers [40 CFR §112.8(c)]
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.
At present, a total of five ASTs that store fuels, are located at CSSA. A list of these tanks is presented in Table 3.1, 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.
CSSA does not have buried metallic bulk storage tanks. CSSA does not have partially buried metallic bulk storage tanks.
CSSA conducts regular inspections of all ASTs on the facility. Records of the results of these inspections are kept in the Motor Pool. Example Inspection Records for ASTs are provided in Appendix C. Integrity testing will be performed should visual inspections reveal any signs of deterioration or leaks.
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. A site gauge is used for the emergency generator tank at Building 99.
3.4 - Used Oil Management Areas
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 TCEQ waste classification rules (30 TAC §335.501-334.515). All used oils are transported offsite for recycling.
3.5 - Facility Transfer Operations [40 CFR §112.8(d)]
AST piping at Building 46 runs beneath the roadway 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.
CSSA does not have out-of-service pipelines for transport of oil or hazardous substances.
Pipe supports for aboveground piping have been designed to minimize abrasion and corrosion and allow for expansion and contraction.
Aboveground piping and valves are regularly inspected in conjunction with inspections of ASTs. Example inspection logs are provided in Appendix C.
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.