AT_ 11 - Fort Riley SPCCP.pdf

This is an UNCONTROLLED DOCUMENT for reference only. The current copy is on the Fort Riley Intranet https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1

SPILL PREVENTION, CONTROL

AND COUNTERMEASURES

PLAN (SPCCP)

The Department of the Army Headquarters, 1st Infantry Division and Fort Riley, Kansas 66442-5000

September 2018

(amended February 2023) https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 ii Table of Contents September 2018

SPILL PREVENTION, CONTROL, AND

COUNTERMEASURES PLAN (SPCCP)

Table of Contents FORT RILEY EMERGENCY SPILL NOTIFICATION ............................................................... x

EMERGENCY SPILL PROGRAM MANAGER AND ALTERNATES .................................... xi

DEFINITIONS ...................................................................................................................... xv

ACRONYMS and ABBREVIATIONS ............................................................................... xix

EXECUTIVE SUMMARY

1 INTRODUCTION

1.1 Statement of Purpose of the SPCCP

1.2 Applicable Laws and Regulations

1.3 Scope of the SPCCP

1.4 Overview of Fort Riley

1.4.1 Geographic Location

1.4.2 History of the 1st Infantry Division

1.4.3 Mission and Training Activities

1.4.4 Topography and Geology

1.4.5 Climate

1.4.6 Soils

1.4.7 Hydrology

1.4.8 Vegetation

1.5 Spill History

2 GENERAL

2.1 Relationship to Other Plans

2.2 U. S. Army Spill Policy

2.3 Operational Assumptions of the SPCCP

3 CONFORMANCE WITH STATE AND FEDERAL GENERAL REQUIREMENTS

3.1 General Applicability – 40 CFR 112.1

3.2 Exceptions to the General Applicability – 40 CFR 112.1(d)

3.3 Plan Development and Implementation – 40 CFR 112.3

3.4 Amendment and changes – 40 CFR 112.4 and 112.5

3.5 Technical Requirements – 40 CFR 112.7

3.5.1 40 CFR 112.7(a) (1) – https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

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3.5.2 40 CFR 112.7 (a) (2) –

3.5.3 40 CFR 112.7 (a) (3) (i) –

3.5.4 40 CFR 112.7 (a) (3) (ii-iv) –

3.5.5 40 CFR 112.7 (a) (3) (v) –

3.5.6 40 CFR 112.7 (a) (3) (vi) –

3.5.7 40 CFR 112.7 (a) (4) –

3.5.8 40 CFR 112.7 (a) (5) –

3.5.9 40 CFR 112.7 (b, c, e, k) –

3.5.10 40 CFR 112.7 (d) –

3.5.11 40 CFR 112.7 (f) –

3.5.12 40 CFR 112.7 (g) –

3.5.13 40 CFR 112.7 (h) –

3.5.14 40 CFR 112.7 (i) –

3.5.15 40 CFR 112.7 (j) –

4 PREDICTIONS OF POTENTIAL RELEASES – 40 CFR 112.7(b)

Site maps/diagrams

5 RESPONSIBILITIES

5.1 The Installation Commander Will:

5.2 The Directorate of Public Works Will:

5.2.1 The DPW Environmental Division Will:

5.3 The Directorate of Emergency Services Will:

5.4 The Mission and Installation Contracting Command, Fort Riley Will:

5.5 All Installation Organizations Will:

6 SPILL PREVENTION AND CONTAINMENT

6.1 Spill Prevention

6.2 Containment and Diversionary Structures – 40 CFR 112.7(c)

6.2.1 Containment for AST’s:

6.2.2 Containment for Bulk Storage Containers:

6.2.3 Containment for Mobile Tanks/Containers at Construction Sites:

6.2.4 Containment for Mobile Refuelers:

6.2.4.1 Containment for Mobile Refuelers used for storage:

6.2.4.2 Parking Mobile Refuelers:

6.2.5 Containment for Modular Fuel System (TRM/PRM):

6.3 Oil-Filled Operational Equipment – 40 CFR 112.7(k)

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6.4 Facility Tank Truck Loading and Unloading Discharge Prevention and Control – 40 CFR 112.7(h)

7 INSPECTIONS, TESTS and RECORDS – 40 CFR 112.7€

7.1 Inspection Program

7.2 Inspection Criteria

7.3 External/Integrity Testing – 40 CFR 112.8

7.4 Frequency of Inspections

7.5 Brittle Fracture Evaluation Requirements – 40 CFR 112.7

7.6 Inspection Documentation

8 SECURITY – 40 CFR 112.7(g)

8.1 Security Measures

8.2 Installation Access

8.3 Equipment

8.4 Lighting

9 TRAINING AND MEDICAL SURVEILLANCE

9.1 Training – 40 CFR 112.7(f)

9.2 Training Requirements – 40 CFR 112.7(f)(1)

9.3 Training Personnel and Schedule – 40 CFR 112.7(f)(2 &3)

9.4 Training Records

9.5 Medical Surveillance

10 NOTIFICATION OF A SPILL

10.1 Notification of a Discharge of a Hazardous Substance (List of Hazardous Substances)

10.2 Notification of a Suspected Nuclear, Biological or Chemical Incident

11 PLAN DEVELOPMENT, FILING AND MAINTENANCE

11.1 Development

11.2 Maintenance

12 Facility Drainage – 40 CFR 112.8(b)

13 Facility Transfer Operations, Pumping and Facility Process – 40 CFR 112.8(d)

APPENDICES

APPENDIX A – References

APPENDIX B – Fort Riley Spill History, 2019 – 2022

APPENDIX C – Contact Phone Numbers of Organizations with Installation Response Team Members

APPENDIX D – Emergency Assistance/Notification Telephone Numbers https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

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APPENDIX E – Multi-media Environmental Inspection Report

APPENDIX F – Aboveground Storage Tanks and Underground Storage Tanks

APPENDIX G – Operational Sites Required to Have a Site-Specific Spill Contingency Plan

APPENDIX H – Oil-Filled Operational Equipment Sites

APPENDIX I – Site Surveys and Maps

APPENDIX J – Additional Prediction, Prevention and Countermeasures for Aboveground Storage Tanks, Underground Storage Tanks, and Accumulation Points

APPENDIX K – Personnel Training Requirements

APPENDIX L–Fort Riley Spill Response Equipment Resources

APPENDIX M – Fort Riley Spill Response Procedures

APPENDIX N – Spill Response Procedures for Motor Oil; Antifreeze; and Brake, Hydraulic and Transmission Fluid

APPENDIX O – Spill Response Procedures for Flammable and Combustible Liquids (JP-8, MOGAS, etc.)

APPENDIX P – Spill Response Procedures for Acids

APPENDIX Q – Spill Response Procedures for Caustics

APPENDIX R – Spill Response Procedures for Oxidizers and Organic Peroxides

APPENDIX S – Spill Response Procedures for Pesticides

APPENDIX T – Spill Response Procedures for Polychlorinated Biphenyls

APPENDIX U – Spill Response Procedures for Mercury

APPENDIX V – Spill Response Procedures for Fluorescent Light Bulb Breakage

APPENDIX W – Spill Response Procedures for Aqueous Film Forming Foam (AFFF). . 161

APPENDIX X – Containment Techniques for Spills

APPENDIX Y– Template for the Site-Specific Spill Contingency Plan

APPENDIX Z – Fort Riley Spill Incident Report

APPENDIX AA – Aboveground Storage Tank Inspection Checklists

APPENDIX AB – Secondary Containment Stormwater Release Form https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

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Figures Figure i-1 Fort Riley spill notification chart ................................................................................... x Figure 1-1 Map of Fort Riley Figure 1-2 Map of Fort Riley Waterways

Tables Table 1-1 Emergency spill personnel ............................................................................................ xi Table 1-2 Record of Review ......................................................................................................... xii Table 1-3 Record of changes/amendments .................................................................................. xiii Table 1-4 Amendment Certification ............................................................................................ xiv Table 4-1 Potential Equipment Failures Table 13-1 Training Requirements for oil and hazardous substance handling and spill response https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 vii P.E. Certification September 2018

SEAL

https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 viii P.E. Certification September 2018 https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 ix Approval September 2018

SPILL PREVENTION, CONTROL, AND COUNTERMEASURES PLAN (SPCCP)

APPROVAL

Full approval is extended by the management of this installation at a level with authority to commit the necessary resources to implement the SPCCP.

APPROVED

BY: _________________________ ____________________

HERBERT J. ABEL DATE

Chief, Environmental Division, DPW

APPROVED

BY: _________________________ ____________________

S. STEPHEN SHRADER DATE

COL, IN

Commanding https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 x Spill Notification Chart September 2018

FORT RILEY EMERGENCY SPILL NOTIFICATION

Person Discovering the Spill in

Cantonment Area

Person Discovering the Spill in a Training Area

Or on a Range

Post Emergency Services

DPTMS Range Support Branch

239-4281/4200 or by Radio using assigned

FM Frequency Fort Riley Fire Department 239-4257

Organization Responsible for the Spill

DPW, Environmental Division, Spill Program

Manager 785-210-8866

Fort Riley Operations Center

239-2222

Garrison Commander, 239-2092

Commanding General, 239-3516

Installation Response Team, see App C

KDHE, 785-296-1679

KDEM, 1-800-275-0297

National Response Center, 1-800-424-8802 EPA Region VII, RRT, 913-281-0991

Army Operations Center, 703-695-6828 U.S. Army Corps of Engineers, Kansas City, KS Emergency Management Branch, 816-426-6320

USAEC, 410-436-4714

LEPC, Geary County, 785-238-1290

Riley County, 785-537-2112

FORT RILEY NON-EMERGENCY SPILL NOTIFICATION

Person Discovering the Spill

Organization’s Environmental Team

DPW, Environmental Division, Spill Program Manager 239-8615

Mandatory Notification

As Needed Notification

Figure i-1 Fort Riley spill notification chart https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 xi Responsible Party September 2018

EMERGENCY SPILL PROGRAM MANAGER AND ALTERNATES

As required by 40 CFR 265.52(d)

Table 1-1 Emergency spill personnel

Position Name Address Office Phone Cell Phone

Emergency Coordinator

Jeff Fuller 1418 Candlelight Lane Junction City, KS 66441

785-239-8615 785-223-6161

Alternate # 1 James Doll 2008 Deerfield Square Manhattan, KS 66503

785-239-2305 785-539-4778

Alternate # 2 Shawn LaBonte

664 S. Twelfth St.

Salina, KS 67401

785-239-8436 785-577-4681

Mailing Address Directorate of Public Works Environmental Division ATTN: Spills Program Manager 407 Pershing Court Fort Riley, KS 66442

Fort Riley Longitude/Latitude

Longitude: (degrees, minutes, seconds) 3904’16.51 N

Latitude: (degrees, minutes, seconds) 9646’56.90 W https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 xii Record of Changes and Review September 2018

Table 1-2 Record of Review https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 xiii Record of Changes and Review September 2018

Table 1-3 Record of changes/amendments

RECORD OF CHANGES/AMENDMENTS:

Change/ Amend Number

Date of Change/ Amendment Comments .

Posted By (Printed Name)

PE Recertification (Y/N) (If Y, Name)

1 1/31/2023 Updated phone numbers, organization name(s), throughout

Jeff Fuller N

2 1/31/2023 Updated Emergency Spill Personnel contact information, pg x

Jeff Fuller N

3 2/8/2023 Revised definition of reportable spill, pg xvii

Jeff Fuller N

4 2/8/2023 Updated Table 4-1 to include Milford and KS River Bridging Activities

Jeff Fuller N

5 1/31/2023 Updated historical spill report tables to 2019-2022 in Appendix B

Jeff Fuller N

6 1/31/2023 Updated Appendix E with current inspection checklist

Jeff Fuller N

7 1/31/2023 Added Appendix W for DoD AFFF Response

Jeff Fuller Y, Kyle Kirchner

8 2/8/2023 Updated information and records of Oil-Filled Equipment in Appendix H

Jeff Fuller N https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 xiv Record of Amendments September 2018

Table 1-4 Amendment Certification https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 xv Definitions September 2018

DEFINITIONS

Accumulation Point: A location where a generator collects hazardous waste or unwanted hazardous materials in containers or other means while awaiting transport to a consolidation point (less than 90 days) or a treatment, storage, or disposal (TSD) facility.

Bulk Storage Container: Any container, 55 gallons and larger in which a material is stored, transported, treated, disposed of, or otherwise handled.

Chemtrec: An agency that provides a 24-hour emergency hotline for information on hazardous materials. Phone: (800) 424-9300.

Combustible Liquid (DOT) : A liquid with a flash point above 140F and below 200F.

Contractor Owned, Contractor Operated: The facility and operations conducted there are the responsibility of the Contractor, (e.g. Intercontinental Hotels Group, Corvias).

Controlled Materials: Materials that do not meet the EPA’s definition of hazardous waste, but if disposed of improperly, may be a hazardous waste, violate the Clean Water Act, or trigger a cleanup.

Discharge: Includes, but is not limited to spilling, leaking, pumping, pouring, emitting, emptying, or dumping of oil or other hazardous substance, or action that violates applicable water quality standards, causes a film or sheen or discoloration of the surface of the water, causes sludge or emulsion to be deposited beneath the surface of the water, or affects the quality of the ground water.

Emergency Situation: When human health or the environment is threatened because of a fire, explosion, or release of oil or hazardous substances, any of which cannot be contained using organization resources.

Emergency Spill: See definition for Emergency Spill in Section 10 of this plan.

Environmental Team: The organization’s personnel responsible for spill prevention and response.

Flammable Liquid (DOT): A liquid having a flash point of not more than 140F or any material in a liquid phase with a flash point at or above 100F that is intentionally heated and either offered for transportation or transported at or above its flash point in a bulk packaging.

Fuel Tank: A tank other than a cargo tank, used to transport flammable or combustible liquid or compressed gas for the purpose of supplying fuel for propulsion of the transport vehicle to which it is attached, or for the operation of other equipment on the transport vehicle.

Hazardous Substance: An element or compound, other than oil, which, when spilled in any quantity into or upon navigable waters of the United States or their tributaries, presents an imminent or substantial threat to the public health or welfare.

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Incompatible: A hazardous substance, material, or waste, which is unsuitable for the following:

Placement in a particular device or facility, because it may cause corrosion or decay of containment materials such as container inner liners or tank walls.

Combining with another waste or material under uncontrolled conditions, because the combination might produce heat or pressure, fire or explosion, violent reaction, and/or toxic flammable fumes or gases.

Installation Response Team (IRT): Properly trained personnel at Fort Riley who respond to spills of oil or hazardous substances.

Local Emergency Planning Committee (LEPC): The LEPC’s primary objective is to develop an emergency response plan and to review it at least annually. This plan evaluates potential hazards and available resources for preparing for and responding to a potential chemical accident. The LEPC is appointed by the state commission and includes, at a minimum, elected state and local officials; police, fire, civil defense, and public health professionals; and environmental, hospital, and transportation officials.

Modular Fuel System (MFS) Tank/Pump Rack Module: The Modular Fuel System (MFS) provides the ability to rapidly establish fuel distribution and storage capability without a bag farm or engineer support by using the Tank Rack Module (TRM) and/or Pump Rack Module (PRM). They provide mobile fuel storage and issuing capability for the Brigade Combat Team (BCT). Both systems hold approximately 2,500 gallons of fuel and can be transported by multiple vehicles over all types of terrain.

Mobile Refueler: Means a bulk storage container onboard a vehicle or towed, that is designed or used solely to store and transport fuel for transfer into or from an aircraft, motor vehicle, locomotive, vessel, ground service equipment, or other oil storage container.

National Contingency Plan (NCP) or the National Oil and Hazardous Substances Pollution Contingency Plan: Describes procedures to be followed by agencies and assigns duties and responsibilities for the agencies if oil or hazardous substances are released.

National Response Center (NRC): National reporting center for releases of oil, hazardous substance, or hazardous waste spills. The NRC is staffed by the U. S. Coast Guard, and will forward spill information to the appropriate EPA region.

Navigable Waters: Waters of the United States (as defined in section 502(7) of the Federal Water Pollution Control Act (FWPCA)), and includes:

1) All navigable waters of the United States, as defined in judicial decisions prior to passage of the 1972 Amendments to the FWPCA (Pub. L. 92-500) and tributaries of such waters;

2) Interstate waters;

3) Intrastate lakes, rivers, and streams which are utilized by interstate travelers for recreational or other purposes; and

4) Intrastate lakes, rivers, and streams from which fish or shellfish are taken and sold in interstate commerce.

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On-scene Coordinator (OSC): The official, pre-designated by the Installation Commander to coordinate and direct Installation responses under the National Oil and Hazardous Substances Pollution Contingency Plan. During the emergency response phase of Emergency Spill responses, the OSC is the senior Directorate of Emergency Services (DES) Fire Department official who responds to the spill. During non-emergency response phases and non-emergency Spill responses, the Public Works, Environmental Division’s Spill Program Manager or his/her designated alternate is responsible.

Oil: Oil of any kind or in any form, including, but not limited to petroleum products, fuel oil, sludge, oil refuse, and oil mixed with wastes. The terms oil and POL (Petroleum, Oil, and Lubricants) are used interchangeably.

Organic Peroxide: Any organic compound containing oxygen (O) in the bivalent -O-O-structure and which may be considered a derivative of hydrogen peroxide, where one or more of the hydrogen atoms have been replaced by organic radicals.

Oxidizer: A material that may, generally by yielding oxygen, cause or enhance the combustion of other materials.

Post Emergency Services: Consists of the Military Police, Fort Riley Police and the Fort Riley Fire Department

Potential Spill: Any incident or other circumstance that threatens to result in the discharge of oil or a hazardous substance.

Potential Spill Site: Any site that transfers, handles, and/or stores one or more controlled or hazardous substances in quantities that would threaten human health or the environment if released.

Public Health or Welfare: All factors affecting the health and welfare of humans including, but not limited to human health, the natural environment, fish, shellfish, wildlife, and public and private property, shorelines, and beaches.

Regional Response Team (RRT): Program representatives of enforcement, operations, and when appropriate, research and development agencies that provide support to respond to major spills that could endanger human health and the environment.

Reportable Spill: According to Fort Riley and AR 200-1, oil and hazardous substance spills must be reported by the individual or organization that discovered the spill if they:

a. Are greater than 5 gallons.

b. Enter any storm drain, stream, or waterway.

c. Are hazardous to human health, or detrimental to aquatic or terrestrial species of plants or animals.

d. Are a threat to, or result in, contamination of underground or surface water.

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e. Cause a film or sheen upon, or discoloration of the surface of the water or adjoining shoreline, or cause a sludge or emulsion to be deposited beneath the surface of the water or upon the adjoining shorelines.

Remedial: Those actions consistent with permanent remedy taken instead of, or in addition to, removal action in the event of a release or threatened release of a hazardous substance or oil into the environment

Reportable Quantity: Means quantities that may be harmful as set forth in 40 CFR Table 117.3, the discharge of which is a violation of section 311(b)(3) of the Clean Water Act and requires notice as set forth in 40 CFR 117.21.

Secondary Containment: A structure or system designed to prevent the accidental release of oil or hazardous substance from entering the environment.

Site File: A file maintained by Fort Riley organizations that are required to maintain a Site- Specific Spill Contingency Plan (SSSCP). The file contains a copy of the organization SSSCP, release prevention procedures, site inspection procedures, spill reports for the past three years, and facility inspection reports for the past three years.

https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 xix Acronyms and Abbreviations September 2018

ACRONYMS and ABBREVIATIONS

AEC Army Environmental Center AP Accumulation Point for Hazardous Waste, Universal Waste and Controlled Material BSC Bulk Storage Container AR Army Regulation AST Aboveground Storage Tank CERCLA Comprehensive Environmental Response, Compensation, and Liability

Act CFR Code of Federal Regulation CHEMTREC Chemical Transportation Emergency Center CHRIS Chemical Hazards Response Information System CM Controlled Material COCO Contractor Owned, Contractor Operated CVWF Central Vehicle Wash Facility CWA Clean Water Act DA Department of the Army DES Directorate of Emergency Services DFMWR Directorate of Family Morale, Welfare and Recreation DOD Department of Defense DOL Directorate of Logistics DOT Department of Transportation DLA Defense Logistics Agency DPTMS Directorate of Plans, Training, Mobilization & Security DPW Directorate of Public Works EMP Environmental Management Plan EPA Environmental Protection Agency EPCRA Emergency Planning and Community Right-To-Know Act ERG Emergency Response Guide ET Environmental Team ETL Environmental Team Leader ETT Environmental Team Training ETT-R Environmental Team Training Refresher EWMC Environmental Waste Management Center FROC Fort Riley Operations Center FWPCA Federal Water Pollution Control Act GPM Gallons Per Minute HW Hazardous Waste HWPS Hazardous Waste Profile Sheet https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 xx

HWSF Hazardous Waste Storage Facility IAW In Accordance With IC Installation Commander IMCOM Installation Management Command IRT Installation Response Team KAR Kansas Administrative Regulation KDHE Kansas Department of Health and Environment KDEM Kansas Emergency Management LEPC Local Emergency Planning Committee MASCAL Mass Casualty MEDDAC (U.S. Army) Medical Department Activity MFS Modular Fuel System MICC Mission and Installation Contracting Command SDS Material Safety Data Sheet NCP National Oil and Hazardous Substances Pollution Contingency Plan NFPA National Fire Protection Association NIOSH National Institute of Occupational Safety and Health NRC National Response Center NRT National Response Team OSC On-Scene Coordinator OSHA Occupational Safety and Health Administration OWS Oil Water Separator PAO Public Affairs Office PCBs Polychlorinated Biphenyls PE Professional Engineer PEL Permissible Exposure Limit POC Point of Contact POL Petroleum, Oil, and Lubricants POV Privately Owned Vehicle PPE Personal Protection Equipment ppm Parts Per Million PRM Pump Rack Module RCRA Resource Conservation and Recovery Act RRC Regional Response Center RRT Regional Response Team RQ Reportable Quantity SAP Satellite Accumulation Point SARA Superfund Amendments and Reauthorization Act SERC State Emergency Response Commission SERO Senior Emergency Response Officer https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 xxi

SJA Staff Judge Advocate SPCCP Spill Prevention, Control, and Countermeasures Plan SSSCP Site Specific Spill Contingency Plan TEMF Tactical Equipment Maintenance Facility TRM Tank Rack Module USAEC U.S. Army Environmental Command UST Underground Storage Tank https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 1 Introduction September 2018

EXECUTIVE SUMMARY

The purpose of the Fort Riley Spill Prevention, Control, and Countermeasures Plan (SPCCP) is to minimize the effect of spills of oil and hazardous substances at this installation. Federal regulations require spill prevention plans be maintained by Army installations that could reasonably expect spills of oil or hazardous substances in quantities harmful to human health and the environment. This plan requires all Fort Riley personnel, including temporarily assigned personnel, to report all spills. Depending on the location, quantity, and hazardous nature of the material spilled, the following organizations will be notified: the Directorate of Emergency Services (DES) Police and Fire Departments, the Directorate of Public Works (DPW) Environmental Division Spill Program Manager, or the Directorate of Plans, Training, Mobilization & Security (DPTMS) Range Support Branch (Figure i-1 Fort Riley spill notification chart).

This SPCCP identifies all known operational sites where oil and hazardous substances are used, stored, or transferred. Each site designated by the Hazardous Waste Program Manager is required to maintain a site file that identifies and describes secondary containment, the physical barriers to prevent spill migration to the environment, deficiencies at each site, and procedures to preclude spills of oil and hazardous substances. A spill into the environment will trigger a response under this Plan. The site file also identifies the Environmental Team Leader as the Organization’s Spill Program Manager.

This plan is required by 40 CFR 112. The SPCCP contains information about the Fort Riley oil and hazardous substance spill/release prevention program. The SPCCP’s contents include roles and responsibilities, duties, required equipment, procedures, resources, required reporting, and countermeasures to prevent the release of oil and hazardous substances to the environment.

Training to support this plan is listed in APPENDIX K – Personnel Training Requirements of this plan and consists of requirements as stated in the Federal Regulations. The intent of the training is to minimize threats to human health or the environment from oil and/or hazardous materials.

Federal regulations require that the SPCCP be reviewed at least once every five years (40 CFR 112.5(b)). The regulation also requires that the plan be reviewed and amended, when necessary, if there is a change in facility design, construction, operation or maintenance that affects the potential for spills of oil and hazardous substances (40 CFR 112.5(a)).

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P2-SPCCP, Version 1.1 1

1 INTRODUCTION

1.1 Statement of Purpose of the SPCCP

This SPCCP was developed for the 1st Infantry Division and Fort Riley Kansas to protect human health and the environment. This SPCCP establishes procedures and guidelines to prevent, detect, and report oil and hazardous substance spills on or off Fort Riley that are caused by Department of the Army (DA) activities, including activities of Fort Riley’s tenants and contractors. This plan identifies potential spill sites, prevention, response procedures, maintenance programs, and required training of personnel.

1.2 Applicable Laws and Regulations

This SPCCP has been prepared in accordance with (IAW) the regulations and standards listed in Appendix A.

1.3 Scope of the SPCCP

This SPCCP implements U.S. Environmental Protection Agency (EPA) regulations for the Clean Water Act to ensure that Fort Riley has procedures to prevent and control spills of oil and hazardous substances that could adversely affect human health or the environment. This SPCCP serves as the standard for all personnel, units, activities, organizations, and contractors involved in the handling, transfer, removal, or storage of oil and hazardous substances on or off Fort Riley. In addition, this plan establishes requirements for training activities, record documentation, and inspections of operational sites.

1.4 Overview of Fort Riley

The following narrative presents a general overview of Fort Riley, describing the installation’s geographic location, history, mission and training activities, topography and geology, climatology, soils, hydrology, and vegetation.

1.4.1 Geographic Location

Fort Riley is located in north-central Kansas, just north of Interstate 70, approximately 65 miles west of Topeka, Kansas. The installation encompasses over 100,000 acres located in Riley, Geary, and Clay Counties and is bordered by the Kansas and Republican Rivers on the south.

Fort Riley is divided into six cantonment areas: Camp Whitside, Camp Forsyth, Custer Hill, Camp Funston, Main Post, and Marshall Army Airfield. These areas are identified on the Fort Riley Military Installation Map in Figure 1-1.

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Figure 1-1 Map of Fort Riley https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 3

1.4.2 History of the 1st Infantry Division

Initial surveys for the Fort Riley site were conducted in the late fall of 1852 at the confluence of the Smoky Hill and Republican Rivers. Because the installation was believed to be near the geographic center of North America, it was initially called Camp Center. The 6th Infantry whose mission was to protect westward-moving pioneers on the Santa Fe Trail, garrisoned Camp Center. In 1853, Congress appropriated funds to construct a new post on the site that was designated Fort Riley, in honor of Major General Bennett Riley. During the late 1800s, Fort Riley became the center of military training for cavalry and light artillery.

1st Infantry Division’s history begins in 1917 when General John “Blackjack” Pershing arrived in France with the First American Expeditionary Force. From 1955 to 1995, Fort Riley was the center of operations of the 1st Infantry Division (Mechanized).

During World War II, the 1st Infantry Division was the first to reach England, the first to fight the enemy in North Africa and Sicily, the first on the beaches of Normandy on D-Day and the first to capture a major German City – Aachen. The 1st Infantry Division remained in Germany until 1955, first as occupation troops, then as partners with the new Germany in NATO, the North Atlantic Treaty Organization.

In 1955, the Big Red One redeployed to Fort Riley, Kansas. In the summer of 1965, the Big Red One was the first division called to fight in Vietnam. In April 1970, the colors of the 1st Infantry Division returned to Fort Riley. Home again, the Big Red One became a dual based division with its 3rd Brigade in West Germany.

Another first was credited to the Division when it embarked on the beginning of a long series of REFORGER (Return of Forces to Germany) exercises. These exercises demonstrated our nation's determination and capability to defend Western Europe with our NATO allies.

On November 8, 1990, the 1st Infantry Division was alerted and over the next two months, deployed more than 12,000 soldiers and 7,000 pieces of equipment to Saudi Arabia in support of Operations Desert Shield/Storm. Another first, the Big Red One led the charge into Iraq.

On April 10, 1996, the colors of the 1st Infantry Division moved to the German city of Würzburg.

Shortly after their arrival, the Big Red One soldiers assumed peace enforcement responsibilities in Bosnia-Herzegovina in support of Operations Joint Endeavor/Guard. The Division deployed to the Balkans twice in 1999, first as part of Task Force Sabre in Macedonia, then in Kosovo with NATO’s Task Force Falcon on 10 June.

In January 2003, the division primed itself for Operation Iraqi Freedom. The 1st Brigade Combat Team deployed to support Operation Iraqi Freedom in the fall of 2003 and returned to Fort Riley in September 2004.

As part of the Base Realignment and Closure (BRAC) changes, the Division cased its colors in Germany July 7, 2006. The 1st Infantry Division conducted a transfer of authority to the 24th Infantry Division on August 1, 2006, assuming command and control of Fort Riley.

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The 2nd Brigade Combat Team deployed from Germany in support of Operation Iraqi Freedom in 2006.

Due to changes in the war strategy, 1st Brigade assumed two new missions for the Army in 2006.

Mission 1: The 1st Brigade is charged with supporting the Army's Transition Team training mission where Brigade Soldiers train thousands of service members from across the Army, Air Force and Navy to become Iraqi and Afghan military advisors.

Mission 2: The 1st Brigade provided a deployable security force elements allowing them to move anywhere the Army requires. Approximately 2,000 Soldiers from the brigade deployed in the fall of 2006 as Security Forces (SECFOR) companies.

The 4th Infantry Brigade Combat Team from Fort Riley deployed to Iraq in early 2007 and returned in April 2008. During its 15-month deployment to Iraq, 74 Soldiers from assigned and attached units gave their lives. While in Iraq, the 4th IBCT Soldiers conducted combat operations that resulted in the capture of more than 200 high-profile targets and reduced 20 enemy cells down to five. The 4th IBCT Soldiers also completed more than 200 civil projects, including repairing sewer, water, medical and educational facilities. Working with the Iraqi Government in Rashid, the 4th IBCT increased water accessibility by 90 percent.

The 3rd Brigade Combat Team deployed to eastern Afghanistan in June 2008, where the 'Dukes' would record more than 1,000 firefights, 1,000 enemy KIAs, 500 bombs dropped, 26,000 rounds of artillery fired, and 400 purple hearts awarded.

In October 2008, the 2nd Heavy Brigade Combat team deployed to Iraq again, this time to Northwest Baghdad, where the Dagger Brigade would oversee the moving of American Forces out of the city and restricted to post, in accordance with the new Status of Forces Agreement with the Iraqi Government.

The Division Headquarters and Headquarters Battalion (DHHB), the first of its kind in the new modular division headquarters structure, deployed to United States Division – South to assume control of the ongoing United States Operations in the southern part of Iraq. The DHHB unit replaced the 34th Infantry Division 'Red Bulls', and was relieved by the 36th Infantry Division 'Arrowhead'.

In April of 2010, the 1st Infantry Division Combat Aviation Brigade returned to Iraq, assuming the role of Enhanced Combat Aviation Brigade (CAB), taking responsibility for the air control over all of Iraq in August.

The 1st Brigade of the 1st Division reformed as a combat team again and deployed in support of Operation New Dawn in November 2010.

The Division Headquarters and Headquarters Battalion, assembled as Task Force Defender, deployed to Combined Joint Task Force (CJTF-1), Regional Command East to assume control of https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 5 the ongoing United States Operations in the eastern part of Afghanistan. The DHHB's activities were chronicled at http://www.rc-east.com.

The Division Headquarters and Headquarters Battalion uncased its colors back home at Fort Riley, March, 2013.

1.4.3 Mission and Training Activities

1st Infantry Division and Fort Riley build and maintain combat ready forces. These forces deploy, as ordered, in an expeditious manner to conduct Decisive Action to fight and win in complex environments as members of a Joint, Inter-organizational, and Multinational (JIM) team.

Fort Riley supports the following activities:

Military maneuvers and training activities.

Military aircraft operations.

Facility-related industrial operations.

Natural and cultural resource management activities.

Military Construction, Army (MCA) activities.

1.4.4 Topography and Geology

Fort Riley is located in the Osage Plains section of the Central Lowlands physiographic province, where elevations range from 1,025 to 1,365 feet above sea level. Fort Riley is composed of three types of geological-topographical areas: high upland, tallgrass prairies in the northern and western portions of Fort Riley; alluvial, bottomland flood plains along the Republican and Kansas Rivers; and broken, hilly transition zones in the eastern portion of Fort Riley.

Two types of alluvial bottomlands exist at Fort Riley: wide meandering floodplains of major rivers, with associated terraces, and areas created by smaller creeks and streams that cut the uplands. Local relief in bottomland areas range from 23 to 60 feet. The transitional areas, extending from the uplands down to the valley floors, are broken, sloping to steep country composed of alternating limestones and shales. The upland areas are mostly covered with the residuals of various shale units that overlie the escarpment-forming limestones. The cutting action of the streams on the thick shale units has sculpted much of the area into a rolling plateau.

Local relief ranges from 164 to 240 feet.

Fort Riley is located within a Zone II seismic area that includes the entire Flint Hills, stretching from Oklahoma to Nebraska through east central Kansas. The only identified geologic hazard is a fault located northeast of Fort Riley. Earthquakes producing moderate structural damage are possible within the Fort Riley area.

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1.4.5 Climate

The climate in central Kansas is categorized as temperate continental, with hot humid summers and cool dry winters. Precipitation averages 31 inches per year at Fort Riley, with a pronounced peak in rainfall in late spring and the first half of the summer. Snowfall averages 22 inches during a typical year in central Kansas, with eight inches as the norm for a single storm.

Precipitation is the major limiting factor to plant growth at Fort Riley. Normally, spring rains are adequate to recharge soil moisture before the summer months when evapotranspiration rates normally exceed precipitation rates, especially in the latter half of the summer. In years when rainfall is below average, soil moisture in the upper soil levels is depleted, causing stress on particular grain and forage crops, as well as shallow-rooted landscape plants.

The prevailing winds at Fort Riley are south to southwesterly during most of the year except during February and March when prevailing winds are from the north. Mean wind speeds range between 4 and 12 miles per hour.

1.4.6 Soils

Fort Riley is part of the Great Plains Winter Wheat and Rangeland Soil Resource Region. Most soils are friable, silt loam 6 to 12 inches thick, overlying nearly impervious clays. Soils in Fort Riley developed residually from parent materials carried by water or deposited by wind at the installation. Post soils vary from excessively drained sandy lowland soils with high permeability to tight clays with very low permeability. The bedrock depths under these soils vary from less than 1 foot to greater than 10 feet. There are 36 soil series mapped on Fort Riley, categorized into six broad soil associations: the Eudora-Haynie-Sarpy, Reading-Kennebec-Ivan, Smolan- Geary, Wymore-Irwin, Clime-Sogn, and Benfield.

1.4.7 Hydrology

Fort Riley is located in the Kansas River Basin. The basin consists of ponds, lakes, rivers, and streams, some of which are perennial and some intermittent. Surface waters in the southern part of Fort Riley drain to the south to either the Republican or Kansas Rivers. The Kansas River forms by the confluence of the Republican and Smoky Hill Rivers. The western portion of Fort Riley drains toward the southwest via tributaries to Milford Lake on the Republican River. The northeastern portion of Fort Riley drains to the northeast to Wildcat Creek, a tributary of the Kansas River. Fort Riley contains 14 creeks, all of which are intermittent streams, except for Wildcat, Seven Mile and Madison Creeks. The larger rivers and streams have a nearly stable grade and well-developed floodplains. The smaller streams and intermittent drainages have steeper gradients and narrower channeled floodplains, or none at all if in the younger stages of stream development. These waterways are identified on the hydrology map shown in Figure 1-2.

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Figure 1-2 Map of Fort Riley Waterways

Levees constructed around Fort Riley protect certain areas from flooding (these areas are beyond the 100-year flood plain of the Republican and Kansas Rivers). However, the southern periphery https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 8 of the Main Post is just inside the 100-year floodplain boundary. The construction of Milford Dam provides added protection to Fort Riley from flooding by the Republican and Kansas Rivers.

Ground water aquifers in the Fort Riley area occur primarily in three areas: alluvial deposits of major streams and rivers, porous surface deposits, and near-surface limestone fissures of upland areas. The three common types of aquifers from which groundwater is derived are confined, semi-confined, and unconfined. The principal aquifers are unconfined and are composed of alluvial valley fill, colluvial material, or jointed, solutioned limestones (in the upland areas). The alluvial aquifers are recharged from rain infiltration, leaching from limestones and shales, or adjacent streams and rivers at high flow stages. Groundwater flows toward the rivers and streams except during flooding. The valley-filled, alluvial sediments discharge water into streams and rivers as base flow. The limestones have water in the solution channels and joints within the rock.

1.4.8 Vegetation

Fort Riley is located in the Bluestem Prairie section of the Tall Grass Prairie biotic province.

This area is characterized by rolling plains dissected by stream valleys. These plains are dominated by tall grasses such as big bluestem, Indian grass, switchgrass, and mid-grasses such as little bluestem and sideoats grama. This system evolved to maintain itself by wildfires and herbivore grazing.

Forest lands, which occur mainly in stream valleys, are dominated by bur and chinquapin oaks, American elm and red mulberry on the upper slopes, and black walnut, green ash, and honey locust on the lower slopes. Flood plains along the Kansas and Republican Rivers are dominated by cottonwood, sycamore, box elder, and hackberry.

Much of the bottomlands and uplands in this region, including Fort Riley, have been cultivated for crop production, although, areas once cultivated have largely reverted back to grasses since being acquired by the Army.

1.5 Spill History

A summary of the reported spills at Fort Riley for the past four calendar years is contained in the Fort Riley Spill History, 2019-2022 (See APPENDIX B).

A database of each reportable quantity spill and a complete list of all known spills are maintained by the Environmental Division, DPW. Each report contains information on the cause(s), corrective action(s) taken, and plan(s) for preventing future recurrence.

This is an UNCONTROLLED DOCUMENT for reference only. The current copy is on the Fort Riley Intranet at https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

P2-SPCCP, Version 1.1 9 Conformance Requirements September 2018

2 GENERAL

2.1 Relationship to Other Plans

This SPCCP is developed to meet the requirements of local, county, state, and federal prevention and response plans.

This SPCCP meets the requirements of the Hazardous Waste Management Program for releases regulated by the Emergency Planning and Community Right-to-Know Act Sections 301(a), 303(d)(1), and 304.

This SPCCP meets the requirements of the Resource Conservation and Recovery Act, Part A and B Permits for guidance for releases of regulated hazardous waste from permitted hazardous waste storage facilities.

2.2 U. S. Army Spill Policy

The Army policy is to prevent spills of oil and hazardous substances and to maintain readiness to rapidly respond to spills. A spill is defined as the unpermitted release to the environment of oil or a hazardous substance (AR 200-1).

2.3 Operational Assumptions of the SPCCP

This SPCCP is sufficient so long as its assumptions are true. Any changes in these assumptions will require review of this plan pursuant to the conditions stated in Section 5.2.1 of this plan.

The plan assumes the following:

This SPCCP is in effect and is continuously implemented.

This SPCCP applies to all military, civilian, and contract personnel involved in activities at Fort Riley.

Modifications at Fort Riley (including additions, removals, and relocation of structures and equipment, supplies, vehicles, and activities) are evaluated in terms of their effect on this SPCCP.

Fort Riley personnel continue to evaluate, recommend, develop, maintain, or otherwise improve secondary containment for any oil and hazardous substance within their respective work areas with the appropriate approval.

Fort Riley personnel routinely clean up all oil and hazardous substances spills.

This is an UNCONTROLLED DOCUMENT for reference only. The current copy is on the Fort Riley Intranet at https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

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3 CONFORMANCE WITH STATE AND FEDERAL GENERAL

REQUIREMENTS

3.1 General Applicability – 40 CFR 112.1

The United States Environmental Protection Agency’s (USEPA’s) Spill Prevention, Control & Countermeasures (SPCC) regulations apply to non-transportation-related onshore or offshore facilities engaged in drilling, producing gathering, storing, processing, refining, transferring, distributing, using, or consuming oil and oil products.

US Army Garrison Fort Riley in Fort Riley, Kansas is a non-transportation-related facility that stores and uses oil and oil products, and meets the requirements referenced in 40 CFR 112.1(d)(2).

Furthermore, facilities are regulated if, due to their location, the facility could reasonably be expected to discharge oil into navigable waters of the United States or adjoining shorelines. Fort Riley is located within portions of Riley, Geary and Clay counties and is hydraulically connected to the Republican and Kansas Rivers via a number of smaller watersheds.

As such, the following Subparts of 40 Code of Federal Regulations (CFR) 112 apply to the development of this SPCC Plan:

40 CFR 112.7 General Requirements for SPCC Plans 40 CFR 112.8 SPCC Plan Requirements for On-Shore Facilities

Additionally, Fort Riley does not meet the substantial harm criteria as defined under 40

CFR 112.20.

3.2 Exceptions to the General Applicability – 40 CFR 112.1(d) Fort Riley utilizes various containers of oil with a storage capacity of less than 55 gallons. As per 40 CFR 112.1(d)(5) these containers are not specifically addressed in this SPCC Plan.

Additionally, Fort Riley owns and/or operates oil-water separators (OWS) for stormwater treatment. As per 40 CFR 112.1(d)(6), oil separation process equipment associated with treatment operations are not required to be covered in the facility SPCC Plan. Although these units have integral oil storage capacity, they have not been included herein as under normal operation they will contain oil or fuel material in quantities substantially less than the 55 gallons threshold.

There are underground storage tanks (USTs) at Fort Riley that are subject to the technical requirements of 40 CFR 280 and the Kansas Storage Tank Act (K.A.R. 28-44), which outlines the requirements for UST’s storing petroleum and hazardous substances; these tanks are exempt from the requirements of 40 CFR 112 however their locations are marked on the facility diagram (Appendix I) as required by 40 CFR 112.7(a)(3).APPENDIX I

This is an UNCONTROLLED DOCUMENT for reference only. The current copy is on the Fort Riley Intranet at https://armyeitaas.sharepoint-mil.us/teams/EnvironmentalComplianceInspectors/SitePages/EventPlanHome.aspx

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3.3 Plan Development and Implementation – 40 CFR 112.3

As required as part of Section 112.3, the owner/operator must create, implement and maintain a copy of a SPCCP in accordance with Section 112.7. The SPCCP must be available to personnel at sites in operation at least four hours per day or at the nearest field office if it is not operating for at least four hours per day.

3.4 Amendment and changes – 40 CFR 112.4 and 112.5

As required in Section 112.4, a report must be submitted to the EPA Regional Representative and to the KDHE Representative in charge of oil pollution control activities within…