[Home]
[SPCC Table of Contents] [Next Section]
Spill Prevention, Control, and Countermeasures (SPCC) Plan
Section 4 - 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 conditionally exempt 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 - 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. CSSA receiving/transportation 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 WWTP, 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 RQ 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.
4.2 - Waste Generation and Accumulation
Various hazardous and nonhazardous wastes are generated at CSSA from primary mission activities and other post 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.
4.3 - 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 transported off-post for disposal. 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 conditionally exempt 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.
4.5 - Miscellaneous Operations Areas
In addition to the oil and hazardous substance management areas described above 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.
4.5.1 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, generally 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.
General refuse consists of office wastes, food wastes, plastics, waste cardboard, wood and metal wastes, residential 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 Resource Conservation and Recovery Act (RCRA) empty and classified as nonhazardous Class 1 or Class 2 industrial solid wastes and are managed at offsite facilities.
4.5.4 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.