(DRAFT) TE-X SPILL PREVENTION CONTROL AND.pdf

SPILL PREVENTION, CONTROL AND

COUNTERMEASURE PLAN (SPCCP)

FORT CAVAZOS, TEXAS

Prepared for:

United States Army Fort Cavazos, Texas

By:

Texas Certificate of Authorization – F-17149 www.ebpartners.us

June 2023

Spill Prevention Control and Countermeasure Plan U.S. Army Fort Cavazos, Texas

This page intentionally left blank

June 2023 Page i

TABLE OF CONTENTS

ACRONYMS AND ABBREVIATIONS....................................................................................... v 1 INTRODUCTION ................................................................................................................. 1-1

2 PLAN CERTIFICATION, AVAILABILITY, AMENDMENT, AND DEVIATIONS ......... 2-1

2.1 Command Certification .............................................................................................. 2-1

2.2 Licensed Professional Engineer Certification ........................................................ 2-2

2.3 Availability of SPCCP ................................................................................................ 2-3

2.4 Plan Amendment and Review .................................................................................. 2-3

2.4.1 Administrative Updates ................................................................................ 2-3

2.4.2 Technical Amendments by a Certified PE ................................................ 2-3

2.5 Regulatory Deviations ............................................................................................... 2-5

3 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN AND 40 CFR

112 CROSS-REFERENCE...................................................................................................... 3-6 4 GENERAL DESCRIPTION OF INSTALLATION ............................................................ 4-1 5 LAYOUT OF OIL OPERATIONS ...................................................................................... 5-1

5.1 General ........................................................................................................................ 5-1

5.2 Defense Fuel Supply Point ....................................................................................... 5-1

5.3 Other Installation Oil Storage and Transfer Areas ................................................ 5-2

5.4 Containers Not Covered by this SPCCP ................................................................ 5-2

5.4.1 Exclusions ...................................................................................................... 5-2

5.4.2 Contractors .................................................................................................... 5-3

5.4.3 Underground Storage Tanks....................................................................... 5-3

5.4.4 Permanently Closed Containers................................................................. 5-3

5.4.5 Motive Power Containers ............................................................................ 5-3

5.4.6 Oil/Water Separators Used Exclusively for Treating Wastewater ........ 5-3

5.4.7 Oil Storage Containers Less than 55 Gallons .......................................... 5-4

5.4.8 Grease Bins ................................................................................................... 5-4

5.5 Regulated Containers ................................................................................................ 5-4 6 INSTALLATION DRAINAGE AND DRAINAGE CONTROLS ...................................... 6-1

6.1 General ........................................................................................................................ 6-1

6.2 Dike Drainage Control ............................................................................................... 6-3

6.2.1 General ........................................................................................................... 6-3

6.2.2 Defense Fuel Support Point, Bulk Fuel Storage Facility ........................ 6-3

6.2.3 Defense Fuel Support Point, Robert Gray Army Airfield Alert Tank Farm

......................................................................................................................... 6-3

6.2.4 Defense Fuel Support Point, Yoakum-Defrenn Army Heliport (YDAHP)

Rapid Refuel Facility .................................................................................... 6-4

6.3 Drainage from Undiked Areas .................................................................................. 6-4

6.4 Observation of Effluent Treatment Facilities .......................................................... 6-4

7 BULK STORAGE CONTAINERS ..................................................................................... 7-1

Page ii June 2023

7.1 General ........................................................................................................................ 7-1

7.2 Shop-fabricated Containers ...................................................................................... 7-1

7.2.1 Construction ................................................................................................... 7-1

7.2.2 Aboveground Storage Tank Overfill Protection ....................................... 7-2

7.2.3 Specific Secondary Containment for Storage Containers ...................... 7-2

7.2.4 Specific Secondary Containment for Mobile and Portable Storage

Containers (Excludes Mobile Fuelers) ...................................................... 7-2

7.3 Mobile Refuelers and Other Tank Trucks .............................................................. 7-3

7.3.1 Military MFTs ................................................................................................. 7-3

7.3.2 Contractor MFTs ........................................................................................... 7-3

7.3.3 Installation MFTs ........................................................................................... 7-4

7.3.4 Commercial MFTs ........................................................................................ 7-4

7.3.5 FARP .............................................................................................................. 7-4

7.4 Field-Constructed Aboveground Storage Tanks ................................................... 7-4

7.4.1 Construction ................................................................................................... 7-4

7.4.2 Aboveground Storage Tank Overfill Protection ....................................... 7-5

7.4.3 Specific Secondary Containment for Aboveground Storage Tanks ..... 7-5

7.5 Completely Buried Tanks Regulated by 40 CFR 112 .......................................... 7-6

7.5.1 Construction ................................................................................................... 7-6

7.5.2 Underground Storage Tank Overfill Protection ........................................ 7-6

7.6 Oil Filled Operational Equipment Regulated by 40 CFR 112.............................. 7-6

7.6.1 Elevator Hydraulic Systems ........................................................................ 7-6

7.6.2 Transformers ................................................................................................. 7-6

8 TRANSFER EQUIPMENT AND OPERATIONS ............................................................ 8-1

8.1 General ........................................................................................................................ 8-1

8.2 Fuel Transfer by Pipeline .......................................................................................... 8-1

8.2.1 Bulk Fuel Pipelines ....................................................................................... 8-1

8.2.2 Buried Piping Installation Protection and Examination ........................... 8-2

8.2.3 Not-in-service and Standby Service Terminal Connections .................. 8-2

8.2.4 Pipe Supports ................................................................................................ 8-2

8.2.5 Aboveground Piping Protection .................................................................. 8-2

8.2.6 General Secondary Containment ............................................................... 8-3

8.3 Tank Car and Truck Loading/Unloading Racks and Transfer Areas ................. 8-4

8.3.1 Tank Truck Transfer Areas ......................................................................... 8-4

8.4 Premature Truck Departure Prevention and Inspection of Drainage Outlets ... 8-6 9 SECURITY ........................................................................................................................... 9-1

9.1 Access Control ............................................................................................................ 9-1

9.2 Flow and Drain Valves Secured .............................................................................. 9-2

9.3 Starter Controls Secured........................................................................................... 9-2

9.4 Pipeline Loading/Unloading Connections Secured .............................................. 9-2

June 2023 Page iii

10 POTENTIAL TYPES OF MAJOR FAILURES AND SPILLS ...................................... 10-1

10.1 General ...................................................................................................................... 10-1

10.2 Bulk Fuel Storage Facility ....................................................................................... 10-1

10.3 Robert Gray Army Airfield Alert Tank Farm and South Ramp .......................... 10-1

10.4 Yoakum-Defrenn Army Heliport Rapid Refuel Facility ....................................... 10-1

10.5 Hydrants..................................................................................................................... 10-2

10.6 Energy Transfer Pipeline......................................................................................... 10-2

11 EQUIPMENT INSPECTIONS, TESTS, AND RECORDS ........................................... 11-1

11.1 General ...................................................................................................................... 11-1

11.2 Correction of Visible Discharges during Inspections .......................................... 11-1

11.3 Inspection and Test Records .................................................................................. 11-2

11.4 Inspection and Tests, Shop-Fabricated Containers ........................................... 11-2

11.5 Inspections and Tests, Bulk Fuel Equipment Including Field Constructed Tanks

..................................................................................................................................... 11-3

11.5.1 Industry Standards ..................................................................................... 11-3

11.5.2 Defense Fuel Support Point Bulk Fuel Storage Tanks and Transfer

Equipment .................................................................................................... 11-4

11.5.3 Brittle Fracture ............................................................................................. 11-7

11.5.4 Inspection of Secondary Containment Drainage ................................... 11-8

12 OIL HANDLING PERSONNEL TRAINING ................................................................... 12-1

12.1 Fort Cavazos Training Procedures ........................................................................ 12-1

12.2 Facility Response Training and Drill/Exercise Plan ............................................ 12-2

12.2.1 Spill Response Training Requirements ................................................... 12-2

12.3 Defense Fuel Support Point ................................................................................... 12-2

12.3.1 DFSP Contract Personnel ......................................................................... 12-3

12.3.2 Fort Cavazos Unit Personnel .................................................................... 12-3

13 FORT CAVAZOS FACILITY RESPONSE PLAN

13.1 Fort Cavazos Facility Response Plan

13.2 Disposal of Recovered Materials

13.3 Facility Response Plan Locations

Page iv June 2023

LIST OF TABLES

Table 1: Regulatory Cross-reference ........................................................................... 3-6 Table 2: Appendix B Container Tables ......................................................................... 5-4 Table 3: Mobile Refueler Types at Fort Cavazos ......................................................... 7-4 Table 4: Truck Loading/Unloading Racks and Transfer Areas ..................................... 8-5 Table 5: API 653 Bottom Plate Thickness Criteria ..................................................... 11-4 Table 6: Defense Fuel Support Point Fort Cavazos Inspections and Tests ............... 11-5

LIST OF APPENDICES

Appencix A: Fort Cavazos Area Drainage Maps Appendix B Tank Inventories Appendix C Inspection Procedures Appendix D Record of Changes Appendix E Secondary Containment Calculations Appendix F Spill Resonse Poster

June 2023 Page v

ACRONYMS AND ABBREVIATIONS

AAF Army Airfield AAFES Army Air Force Exchange Service API American Petroleum Institute AR Army Regulation AST Aboveground Storage Tank ATG Automatic Tank Gauge BFSF Bulk Fuel Storage Facility Bldg(s) Building(s) BLORA Belton Lake Outdoor Recreation Area CAC Common Access Card CFR Code of Federal Regulations CRDM Continuous Release Detection Method CU Classification Unit DA PAM Department of the Army Pamphlet DFSP Defense Fuel Supply Point DoD Department of Defense DPW Directorate of Public Works DLADS Defense Logistics Agency Disposition Services ECA Environmental Compliance Assistant ECO Environmental Compliance Officer EPA United States Environmental Protection Agency FC Fort Cavazos FRP Fiberglass Reinforced Plastic GLO General Land Office YDAHP Yoakum-Defrenn Army Heliport HAZMAT Hazardous Material HEMTT Heavy Expanded Mobility Tank Truck HSMS Hazardous Substance Management System HQ Headquarters IAW In Accordance With IM Interstitial Monitoring IMC Installation Management Command FRP Facility Response Plan F-24 Jet Fuel KMS Key Management Services LLG Liquid Level Gauge LRC Logistics Readiness Center MFT Mobile Fuel Tanker MOGAS Type of Fuel NA Not Applicable NACE National Association of Corrosion Engineers NFC North Fort Cavazos NFPA National Fire Protection Association

Page vi June 2023

NHWAP Non-Hazardous Waste Accumulation Point OFOE Oil-filled Operational Equipment OSHA Occupational Safety and Health Administration OWS Oil/Water Separator PCB Polychlorinated Biphenyl P.E. Professional Engineer POL Petroleum, Oils, and Lubricants PREP Preparedness for Response Exercise Program PST Petroleum Storage Tank PSTR Petroleum Storage Tank Remediation PWS Public Work Service RA Regional Administrator RCRA Resource Conservation and Recovery Act RGAAF Robert Gray Army Airfield RFP Reinforced Fiberglass Plastic RRC Railroad Commission of Texas RRF Rapid Refuel Facility SSA Supply Support Activity SCU Secondary Containment Unit SOP Standard Operating Procedure SPCCP Spill Prevention Control and Countermeasure Plan STI Steel Tank Institute SWPPP Stormwater Pollution Prevention Plan SWRO Southwest Regional Office TAC Texas Administrative Code TCEQ Texas Commission on Environmental Quality TNRCC Texas National Resource Conservation Commission TPDES Texas Pollution Discharge Elimination System UFC Unified Facilities Criteria UL Underwriters Laboratory UPRP Used Product Reclamation Point USACE U.S. Army Corps of Engineers UST Underground Storage Tank WFC West Fort Cavazos

June 2023 Page 1-1

1 INTRODUCTION

This SPCCP addresses the storage and management of oil products found within the operational areas of Fort Cavazos, Texas. The SPCCP describes practices, procedures, structures, and equipment used to prevent spills and eliminate or reduce harmful effects to human health and the environment.

This SPCCP fulfills the requirements for an SPCCP as mandated by 40 Code of Federal Regulations (CFR) §112, Oil Pollution Prevention, Army Regulation 200-1, and Texas Administrative Code (TAC) 30 Chapters 327 and 334.

The State of Texas has adopted USEPA regulations specific to SPCCPs and regulations governing USTs equivalent to federal regulations. As such, this plan has been developed in a manner that is compliant with the regulatory requirements of the State of Texas.

The purpose of the Fort Cavazos SPCCP is to identify and implement measures to prevent oil and other hazardous substances spills. Oil is defined in 40 CFR 112 as “...oil of any kind or in any form, including, but not limited to: fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and, other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil.”

In the event of a spill, the Fort Cavazos Facility Response Plan (FRP) establishes countermeasures to respond to, cleanup, and dispose of the spill. Fort Cavazos maintains the FRP to conform to the facility response plan requirements of 40 CFR 112.20 and the spill countermeasure requirements of the SPCC regulations. The facility response planning in the FRP incorporates the spill risk and various spill prevention information in the SPCCP. Consequently, the SPCCP and the FRP are companion documents that are integral parts of the overall program designed to prevent environmental pollution, eliminate and mitigate hazards, and effectively manage the storage and use of oil and hazardous materials at Fort Cavazos.

Page 1-2 June 2023

This page intentionally left blank

2 PLAN CERTIFICATION, AVAILABILITY, AMENDMENT, AND DEVIATIONS

2.1 Command Certification

The responsibility for oil release control within the boundaries of Fort Cavazos has been assigned as identified below.

Fort Cavazos is committed to providing the manpower, equipment, facilities, and materials required to establish precautionary measures and to expeditiously control and remove any harmful quantity of oil or hazardous substances discharged from the operational area identified within the five (5) cantonment areas and associated trailing lands located within the boundaries of Fort Cavazos.

By signature, I certify that I have reviewed and approved this SPOOF and agree to implement the necessary changes outlined in the Facility Upgrade Schedule.

APPROVED:

COL Lakicia Stokes Commanding Fort Cavazos

23t4AJ 25/ Date

June 2023 Page 2-1

Page 2-2 June 2023

2.2 Licensed Professional Engineer Certification

I hereby certify that during the week of January 3, 2022, I visited and examined petroleum storage and handling facilities at Fort Cavazos and being familiar with the provisions of 40 Code of Federal Regulations (CFR) 112, I attest that the Spill Prevention, Control and Countermeasure Plan aspects of this SPCCP conform to the requirements of 40 CFR 112 and have been prepared IAW good engineering practice, including consideration of applicable industry standards. Procedures for required inspections and testing have been established and the plan is adequate for the facility.

June 2023 Page 2-3

2.3 Availability of SPCCP

The SPCC is published in KMS and available electronically to any CAC Card holder. The DFSP Fire Department, and DPW Environmental Office maintain hardcopies.

2.4 Plan Amendment and Review

This plan shall be revised as specified in this section. There are two types of revisions:

Administrative Updates and Technical Amendments by a Certified Professional Engineer

(PE).

2.4.1 Administrative Updates

Administrative updates are non-structural- and non-process-related changes to the plan.

Administrative updates to the plan do not require a PE signature but must be made immediately upon knowledge of the change.

Examples of administrative updates include:

a. Changes in the assignment or phone numbers of key personnel

b. Changes in phone numbers of local emergency response agencies

c. Reflections of Department of Defense or Army policy changes

To record administrative updates to this plan, use the form located in Appendix D of this plan.

2.4.2 Technical Amendments by a Certified PE

The SPCCP must be amended per 40 CFR §112.5(a-c) when there is a change in facility design, construction, operation, or maintenance that materially affects the facility’s potential for the discharge of oil as described in 40 CFR §112.1(b)0F

1. The SPCCP must also be reviewed at least once every five years. If no technical amendments are required upon such a review, it is not necessary to have the plan recertified by a PE. You must document your completion of the review and evaluation and must sign a statement as to whether you will amend the Plan, either at the beginning or end of the Plan or in a log or an appendix to the Plan. The following words will suffice, “I have completed review and evaluation of the SPCCP for (name of facility) on (date) and will (will not) amend the Plan as a result.” All technical amendments to the plan must be implemented as soon as possible, but not later than six months after the change occurs. All technical amendments must be certified by a PE.

a. The plan must be amended and certified by a PE within six months after the 5-year review to include more effective prevention and control technology if:

• such technology will significantly reduce the likelihood of a spill event from the facility; and

• Such technology has been field-proven at the time of the review.

1 40 CFR §112.1(b) – “discharge oil in quantities that may be harmful…into or upon the navigable waters of the U.S. or adjoining shorelines, or into or upon the waters of the contiguous zone, or in connection with activities under the Outer Continental Shelf Lands Act or the Deepwater Port Act of 1974, or that may affect natural resources belonging to, appertaining to, or under the exclusive management authority of the U.S.”

Page 2-4 June 2023

b. Examples of the types of changes requiring an amendment to the plan include the following:

• Commissioning or decommissioning of ASTs or USTs

• Replacement, reconstruction, or movement of ASTs or USTs

• Reconstruction, replacement, or installation of piping systems

• Construction or demolition that might alter secondary containment structures

• Revision of standard operation or maintenance procedures

• Addition of new hazardous material (Hazardous Material) or POL storage buildings

• Fueling activity changes (addition of fixed on-site fueling systems, or cessation of fixed on-site fueling systems. Does not include mobile/portable fueling operations)

• Installation of new storage tanks

• Significant changes to federal or State of Texas regulations affecting the applicability and effectiveness of this SPCCP or those regarding reportable spill quantities

• When the SPCCP fails or proves to be ineffective in preventing or responding to a spill

• At the request of the EPA or TCEQ

• After pertinent national, regional, or state contingency plans are modified

• After any changes in adjacent land or water use that would affect spill prevention and response.

c. In the event of certain discharges, specific facility and discharge information must be submitted to the EPA Region 6 Administrator and the state agency in charge of controlling oil pollution. Fort Cavazos is subject to this reporting requirement specified in 40 CFR 112.4 if either of the following occurs:

• The facility discharges more than 1,000 gallons of oil in a single discharge, as described in Part 112.1(b), or;

• The facility has discharged more than 42 gallons of oil, as described in Part 112.1(b), in each of two discharges, within any 12-month period.

d. Fort Cavazos must submit the required information to the EPA Region 6 Administrator and the state agency within 60 days of the occurrence of the spill event subjecting Fort Cavazos to the requirement. Part 112.4 requires submission of the following information:

• Name of the facility

• Name of the individual submitting the information

June 2023 Page 2-5

• Location of the facility

• Maximum storage or handling capacity of the facility and normal daily throughput

• The corrective actions and/or countermeasures taken, including adequate description of equipment repair and/or replacement

• An adequate description of the facility, including maps, flow diagrams, and topographical maps

• The cause(s) of such a discharge as described in Part 112.1(b), including a failure analysis of the system or subsystem in which the failure occurred

• Additional preventive measures that have been taken or contemplated to minimize the possibility of recurrence; and,

• Other information as the Regional Administrator (RA) may reasonably require pertinent to the Plan or discharge.

e. The EPA may require amendments to this plan after reviewing submitted information or an on-site review of the plan. If the plan requires modifications, Fort Cavazos must do so within 30 days after receiving notice from EPA. Also, Fort Cavazos must implement any required plan amendment no later than six months after revising the plan.

2.5 Regulatory Deviations

Because of the significant size and scale of Fort Cavazos Installation, deviations specific to the content and layout of site diagrams that are maintained in Appendix A of this SPCCP have been approved by the Certifying Professional Engineer. As an Environmental Equivalent the Phantom Warrior WebMap, managed by the DPW, provides an extensive archive of diagrams that provide details that meet the requirements of §112.7(a)(3) and that are available for review by DPW Environmental Staff as needed.

Additional details regarding overhead piping systems common to Maintenance Facilities for the transfer of used oils and antifreeze to aboveground storage tanks located at the Maintenance Facility are maintained by the DPW and are available to the DPW Environmental Staff for review as required.

Page 3-6 June 2023

3 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN AND 40 CFR

112 CROSS-REFERENCE

This SPCCP does not follow the sequence of the regulatory requirements as specified in 40 CFR 112.7. Consequently, as required, this plan provides a cross-reference of the applicable provisions in this SPCCP that conform to the general plan requirements in Part

112.7 and the plan requirements for onshore facilities in Part 112.8. Plan requirements for onshore oil production facilities in Part 112.9, for onshore oil drilling and workover facilities in Part 112.10, for offshore oil drilling, production, or workover facilities in Part 112.11, and for non-petroleum oil facilities in Part 112.12 are not applicable for this

SPCCP.

Given that this SPCCP and the FRP are companion documents some requirements of applicable to SPCCP are addressed in the FRP.

Table 1: Regulatory Cross-reference

40 CFR 112 Topic SPCCP Section 112.3(d) Licensed Professional Engineer SPCCP Certification 2.2 112.3(e)(1) and (2)

SPCCP Maintained at Facility and Available for EPA RA’s Review 2.3

112.4(a) Submittal of Information to EPA RA for Specified Spills 2.4.2 112.4(c) Submittal of Information to Appropriate State Agency for Specified

Spills 2.4.2

112.5(a) Required SPCCP Amendments Dues to Facility Design, Construction, Operation, or Maintenance

2.4.2

112.5(d) 5-Year SPCCP Plan Review, Evaluation, and Amendment 2.4.2 112.5(c) Licensed Professional Engineer Certification of Technical

Amendments 2.4.2

112.7 Management Approval and Regulatory Cross Reference 2.1 & 3 112.7(a)(1) SPCCP Conformance to Regulatory Requirements Cross Reference

Cited Plan Sections

112.7(a)(2) SPCCP Deviations and Equivalent Environmental Protection of Alternate Measures

2.5

112.7(a)(3) Description of Facility Physical Layout and Diagram of the Containers, Storage Areas, Transfer Stations, and Connecting Pipes

4, 5, 6. 7.1, & Appendix A

112.7(a)(3)(i) Contents and Capacities of Containers Appendices A & B 112.7(a)(3)(ii) Discharge Prevention Measures and Routine Oil Handling Procedures 6, 7, 8, &

Appendices A, D 112.7(a)(3)(iii) Discharge or Drainage Controls 6, 7.3, 7.4, 8.2.6, & 8.3 112.7(a)(3)(iv) Discharge Discovery, Response, and Cleanup Section 5.1 of

FRP

112.7(a)(3)(v) Methods of Disposal of Recovered Materials Sections 5.3.3 &

6.0 of FRP

112.7(a)(3)(vi) Discharge Emergency Response Contact List and Telephone Numbers

Section 1.2.3 of

FRP

112.7(a)(4) Discharge Reporting Sections 1.2 & 1.3 of FRP

112.7(a)(5) Emergency Response Procedures Section 5.0 of

FRP

June 2023 Page 3-7

Table 1: Regulatory Cross-reference

40 CFR 112 Topic SPCCP Section 112.7(b) Prediction of Potential Spill Direction, Flow Rate, and Total Volume for

Each Type of Major Equipment Failure With a Reasonable Potential of Occurrence

10, Appendix A, & Section 4.0 of

FRP

112.7(c) Appropriate Containment and/or Diversionary Structures or Equipment

6, 7, 8, & Appendix B

112.7(d) Requirements for Determination of Impracticability of Specified Containment Structures and Equipment.

2.5

112.7(e) Inspection and Test Procedures and Records 11, Appendix C 112.7(f)(1) Oil-Handling Personnel Spill Prevention Equipment Operation and

Maintenance Training

112.7(f)(2) Designated Person Accountable for Spill Prevention Section 1,1 of

FRP

112.7(f)(3) At Least Annual Oil-Handling Personnel Spill Prevention Briefings 12 112.7(g) Security and Access Control of Oil Handling, Processing, and Storage

Areas 9 & Appendix A

112.7(h)(1) Tank Truck and Car Loading/Unloading Rack Containment 8.3 & Appendix A

112.7(h)(2) Warning or Equipment to Prevent Premature Departure of Vehicles From the Loading and/or Unloading Rack Area 8.4

112.7(h)(3) Inspection of Tank Truck or Tank Car Lowermost Drains and Outlets Before Filling and Departure 8.4

112.7(i) Evaluation and Mitigation of Field-Constructed Aboveground Tank Discharge Risk Due to Brittle Fracture or Other Catastrophe 11.5.3

112.7(j) Discussion of Conformance to Other Applicable Parts and More Stringent State Rules, Regulations, and Guidelines 1 & 3

112.7(k) Alternative to General Secondary Containment for Qualified Oil-filled Operational Equipment 7.6

112.8(b)(1) Control of Drainage From Diked Storage Areas 6.2

112.8(b)(2) Diked Area Drainage Valve Type and Inspection Requirement for Draining Diked Area

6.2, 11.6, & Appendix C

112.8(b)(3) Facility Drainage Systems from Undiked Areas With Potential for a Discharge 6.3

112.8(b)(4) Diversion System for Final Drainage Discharges From All Facility Ditches If Facility Drainage Systems Are Not Engineered According to 112.8(b)(3)

6.3

112.8(b)(5) Requirements for Treating Drainage Water With More Than One Continuous Treatment Unit Using Pumps For Transfers 6.4

112.8(c)(1) Container Material and Construction Compatibility With Stored Material and Storage Conditions

7.3, 7.4 & Appendix B

112.8(c)(2) Sized and Sufficiently Impermeable Containment for Bulk Storage Tanks

7.1, 7.3, 7.4, & Appendix B

112.8(c)(3) Requirements for the Drainage of Uncontaminated Rainwater From Diked Area

6.2, 11.6, & Appendix C

112.8(c)(4) Corrosion Protection and Regular Leak Test of Completely Buried Metallic Storage Tanks Installed On or After January 10, 1974 11

112.8(c)(5) Corrosion Protection of Partially Buried or Bunkered Metallic Tanks 7.2

112.8(c)(6) Aboveground Container Inspection and Integrity Testing on a Regular Schedule, Dike Area Inspections, Personnel Qualifications, and Records

11 & Appendix C

112.8(c)(7) Control of Leakage through Container Internal Heating Coils 7.2 112.8(c)(8) Good Engineering Practice for Container Including at least One Listed 7.3.2, 7.4.2, 7.5.2, Page 3-8 June 2023

Table 1: Regulatory Cross-reference

40 CFR 112 Topic SPCCP Section Measure for Preventing Overfills and Regular Testing of Liquid Level Sensing Devices

11 & Appendix B

112.8(c)(9) Observation of Effluent Treatment Facilities to Prevent Oil Discharges 6.4

112.8(c)(10) Prompt Correction of Visible Discharges From Containers and Removal of Oil Accumulations in Diked Areas 6.2 & 11.2

112.8(c)(11) Positioning Mobile or Portable Oil Storage Containers to Prevent Discharges and Providing Sized and Sufficiently Impermeable Containment for These Containers

7.4

112.8(d)(1) Wrapping and Coating, with Cathodic Protection of Buried Piping Installed or Replaced On or After August 16, 2002 and Inspection of Exposed Piping

8.2.2

112.8(d)(2) Requirements for Not-In-Service and Standby Service Piping Terminal Connections 8.2.3

112.8(d)(3) Pipe Supports Design 8.2.4

112.8(d)(4) Regular Inspection of Aboveground Valves, Piping, and Appurtenances and Leak and Integrity Tests of Buried piping 11

112.8(d)(5) Warning Vehicles of Aboveground Piping and Transfer Operations 8.2.5 Appendix C Substantial Harm Criteria Certification Page iv of FRP

June 2023 Page 4-1

4 GENERAL DESCRIPTION OF INSTALLATION

Fort Cavazos is the Army’s premier installation for training and deploying heavy forces.

Fort Cavazos is home to the HQ Command III Corps, 1st Cavalry Division, 1st Army Division West, 3rd Armored Calvary Regiment, 3rd Air Support Operations Group, 13th Sustainment Command (Expeditionary), six brigade combat teams, and five other brigade-size formations. The installation’s primary mission is to train its assigned units, as a mobilization station for Army Reserve and National Guard units and as a strategic power projection platform. The installation also supports other assigned and tenant organizations including the Army Reserve, the National Guard, the Reserve Officer Training Corps, and reservists from other military services.

Encompassing 218,823 acres or 342 square miles of Bell and Coryell Counties, Fort Cavazos is the largest, most capable armored military training installation in the country.

Over 35,000 military and 5,000 civilian employees are assigned to Fort Cavazos. The installation supports a diverse community of over 382,300 soldiers, civilians, contractors, family members, and retirees. The installation includes approximately 136,094 acres of maneuver training area, 64,000 acres as a live fire impact area, and 22,026 acres for the installation’s cantonment areas, which includes 50 live fire ranges, more than 2,500 tanks and other tracked vehicles, 193 helicopters, and 10,126 vehicles, and over 100 motor pools to service the vehicles and tanks. Fort Cavazos maintains about 5,900 installation buildings and 5,912 sets of privatized family quarters encompassing approximately 37 million square feet.

Currently, the only significant source of water for the installation is the Belton Lake reservoir, which is fed by the Leon River and Cowhouse Creek. The main aquifer system underlying Fort Cavazos is the Travis Peak formation, which occurs at approximately 1,000 feet below ground surface. This aquifer was used previously as a source of water supply for the installation. However, its use has ceased due to excessive drawdown.

Other shallow formations, such as the Glen Rose, Paluxy, and Edwards aquifers, constitute alternative groundwater sources.

The Bell County Water Control and Improvement District Number 1 treats sewage collected from the main cantonment and West Fort Cavazos (WFC) cantonment areas.

City of Gatesville treats sewage collected at North Fort Cavazos (NFC). A privatized utility contractor, American Water, treats Belton Lake Outdoor Recreational Area (BLORA) sewage.

Topographic features on the installation include valleys, buttes, and mesas. The terrain consists of partly dissected plains that rise from remnants of old plateaus. Geologic formations are rock layers consisting of thin- to medium-bedded, hard, continuous limestone strata. The soil cover in the area is generally shallow to moderately deep, clay-rich, and underlain by limestone bedrock. Elevations range from 590 feet to 1,200 feet with most below 850 feet. Most slopes are in the 2 to 5 percent range, although some slopes exceeding 45 percent occur as bluffs along the side of mesas and hills. The average annual precipitation is approximately 30 inches. The mean annual temperature is 67.1 degrees Fahrenheit, with an average range of 38 to 94 degrees Fahrenheit.

June 2023 Page 5-1

5 LAYOUT OF OIL OPERATIONS

5.1 General

Fort Cavazos conducts bulk fuel storage and transfer operations for operating military aircraft, ground vehicles, power generators, and other military end-use fuel-driven equipment. Military motor pools, aircraft and various other equipment maintenance facilities also store and use petroleum, oils, and lubricants (POL) for vehicle and equipment maintenance operations and collect and store used POL, including reclaimed fuels. Military dining facilities store used cooking oil and kitchen grease. Other sites that store and transfer POL and non-petroleum oil and grease are the automobile service stations and restaurants operated by the Army Air Force Exchange Service (AAFES) for authorized customers at Fort Cavazos.

5.2 Defense Fuel Supply Point

The Defense Fuel Supply Point (DFSP) at Fort Cavazos is a government-owned contractor-operated facility that stores and supplies bulk fuel to military units at Fort Cavazos. Oil storage capacity at the DFSP includes approximately 3,156,000 gallons in field-constructed aboveground storage tanks (ASTs) and 33,000 gallons in tank trucks.

There are no oil storage underground storage tanks (USTs) at the DFSP facilities, only spill containment USTs. The DFSP consists of four separate fuel storage and transfer sites within the confines of the military installation: Bulk Fuel Storage Facility (BFSF);

Robert Gray Army Airfield (RGAAF), which includes the Alert Tank Farm and the South Ramp Hydrant at the RGAAF; and Yoakum-Defrenn Army Heliport (YDAHP) RRF

5.2.1 Bulk Fuel Storage Facilities

These storage and transfer sites primarily supply jet fuel (F-24) and gasoline (MOGAS) for the operating units stationed at or training at Fort Cavazos. The DFSP facility contractor operates under a Defense Logistics Agency Energy (DLA Energy) contract.

Under the contract, the DFSP contractor is responsible for the operations, routine inspections, and maintenance of the DFSP.

a. The BFSF is the main bulk fuel storage and distribution facility for F-24, MOGAS, E-85 MOGAS, and diesel/biodiesel fuels at Fort Cavazos. Commercial tank trucks deliver fuels to this facility at the facility’s load racks and load areas. The BFSF distributes fuel in bulk to other installation fuel use sites and users by tank trucks or military refuelers, and Mobile Fuel Tankers (MFTs) using unloading areas. The BFSF also supplies fuel by pipelines to the DFSP retail fuel dispensing facility servicing military vehicles, which is on the same site.

b. The Alert Tank Farm stores and supplies F-24 to a hydrant for refueling aircraft at the South Ramp at the RGAAF. The hydrant refuels fixed wing aircrafts and loads Army MFTs. This site also includes a parking area for parking the DFSP tank trucks and hydrant hose trucks. Commercial and DFSP tank trucks deliver F-24 to the Alert Tank Farm at the facility’s load areas. The Alert Tank Farm distributes fuel in bulk to other installation fuel use sites and users by MFTs using unloading areas.

c. The YDAHP RRF also consists of a bulk F-24 tank farm that supplies F-24 to a hydrant at the YDAHP. The hydrant refuels rotary wing aircrafts and loads MFTs.

Page 5-2 June 2023

Commercial and DFSP tank trucks deliver F-24 to the tank farm at the facility’s unload area.

5.3 Other Installation Oil Storage and Transfer Areas

Other fuel transfer operations at Fort Cavazos entail using commercial tank trucks, MFTs, and military fuel pods to deliver fuel to the end-users’ storage containers and retail fuel dispensing operations. Tank trucks or MFTs also deliver fuel to North Fort Cavazos, which includes the contractor operated fuel point and the military operated hot refuel point; DPW Maintenance fuel point; BLORA, which has a recreational boat refueling dock; certain motor pools; Rail Operations Center, which has a diesel train engine refuel site; and automobile retail service stations. Military units store their MFTs and fuel pods in their motor pools. Most containers that store reclaimed fuel, used oil, cooking grease, or hazardous material have only fill-ports and no connected pipelines, so personnel manually transfer oil into these containers for storage and disposal.

Fort Cavazos also uses completely buried tanks for collecting spills from containment systems or structures or as collection tanks for oily water or recovered oil from oil/water separation equipment. Fort Cavazos uses oil/water separators (OWS) as components of secondary containment systems at the main bulk fuel farm and at the South Ramp Hydrant fueling location at the RGAAF.

5.4 Containers Not Covered by this SPCCP

This SPCCP does not address the oil storage and use at the Texas Army National Guard Mobilization and Training Equipment Site, a tenant unit located in NFC. It also does not address oil storage containers owned by American Water, the drinking water privatization contractor on post, or the electrical transformers now owned by Dominion Electric, the utilities privatization contractor, who own all equipment and storage containers at their facilities. The Texas Army National Guard, American Water, and Dominion Electric are responsible for developing and maintaining a SPCCP and response plan for their facility as required by 40 CFR 112, Fort Cavazos (FC) Regulation 200-1, and this SPCCP.

Additionally, grease bins that serve military dining facilities and restaurants operated by the Army Air Force Exchange Service (AAFES) at Fort Cavazos are owned and operated by contractors. Given the nature of this contract DPW Environmental does not have operational control of the grease bins. As such, they have been excluded from this plan.

5.4.1 Exclusions

This plan also does not cover the following:

a. Containers owned and operated by contractors temporarily working at the installation

b. USTs subject to the technical requirements of 40 CFR 280 or to a state program approved under 40 CFR 281

c. Permanently closed containers

d. Motive power containers

June 2023 Page 5-3

e. Oil/water separators (OWS) used exclusively for the purpose of treating wastewater where there are no external oil storage containers associated with the OWS System

f. Oil storage containers that are less than 55 gallons

5.4.2 Contractors

Oil storage containers owned and operated by contractors temporarily working on Fort Cavazos property are not covered by this plan and may include fuel tanker trucks, temporary ASTs, and 55-gallon drums. Each contractor is responsible for determining SPCC applicability and developing a site-specific SPCCP, if required. The contractor must provide a copy of their SPCCP to the Water Program Manager. The Water Program Manager will notify the contracting organization of the requirements. The Contracting Officer Representative (COR) would in-turn notify the contractor of the requirements. The environmental specifications that go into all DPW and Corps of Engineers contracts state that temporary construction containers must be equipped with secondary containment.

5.4.3 Underground Storage Tanks

Underground storage tanks subject to the technical requirements of 40 CFR 280 or to a state program approved under 40 CFR 281 are exempt from SPCC requirements and do not count toward the overall storage capacity of the installation; however, they must be shown on the installation diagram. This installation has 14 USTs subject to a state program approved under 40 CFR 281 (TAC Chapter 334). Table B-1, Appendix B, lists these USTs; the locations of the USTs are illustrated on the Site Diagrams provided in Appendix A and on the Phantom Warrior Webmap.

5.4.4 Permanently Closed Containers

In accordance with the SPCC requirements, permanently closed tanks and any connecting piping are to be empty of liquid and sludge with all associated piping disconnected and the tank clearly labeled as permanently closed.

5.4.5 Motive Power Containers

40 CFR 112.1(d)(2)(ii) excludes motive power containers from regulation under the SPCC Rule and the capacities of the containers do not count toward the overall oil storage capacity for Fort Cavazos. Motive power containers are onboard bulk storage containers used primarily to power the movement of a motor vehicle, or ancillary onboard oil-filled operational equipment (e.g., vehicle or equipment gas tanks).

5.4.6 Oil/Water Separators Used Exclusively for Treating Wastewater 40 CFR 112.1(d)(6) exempts any facility or part thereof if used exclusively for wastewater treatment and not used to meet any other requirement of 40 CFR 112. However, note that the OWS that serves as secondary containment system at the main bulk fuel farm for the transfer areas are not exempt from regulation under 40 CFR 112.

Page 5-4 June 2023

5.4.7 Oil Storage Containers Less than 55 Gallons

Installation personnel store fuel and/or oil in 5-gallon fuel cans, equipment/machinery, and other oil storage containers with a storage capacity of less than 55 gallons. Oil storage containers with a capacity of less than 55 gallons are not subject to the requirements contained in the SPCC Rule and are therefore not discussed in the plan.

5.4.8 Grease Bins

Grease bins that serve military dining facilities and restaurants operated by the Army Air Force Exchange Service (AAFES) at Fort Cavazos are owned and maintained by a 3rd party contractor. Due to the nature of this contract DPW Environmental lacks the authority to manage or control these storage containers. Given that the grease bins are less than 250-gallons and that they operate at geographically separate locations that are not considered the same facility, they have been excluded from the Fort Cavazos SPCC Plan.

5.5 Regulated Containers

The SPCC rule regulates oil containers having a capacity of 55-gallons or more.

Aggregate oil storage capacity includes approximately 3.8 million gallons in ASTs and 187,000 gallons in USTs. Fort Cavazos also maintains variable amounts of MFTs and associated fuel pods; and variable amounts of 55-gallon drums. SPCCP Tables B-1 to B-9, Appendix B, identify each regulated container, along with its available spill control and prevention measures. Container information in Appendix B includes the location, container type and capacity, substance stored, secondary containment, and the year the tank was installed or upgraded, where available.

Table 2: Appendix B Container Tables

Oil Storage Container List Container SPCCP Table B-1, Fort Cavazos USTs Underground Storage Tanks (including those exempt from the SPCC Rule) SPCCP Table B-2, Fort Cavazos Generator & Pumps Belly & Day Fuel Tanks SPCCP Table B-3, Fort Cavazos ASTs Aboveground Storage Tanks – Shop

Fabricated Tanks SPCCP Table B-4, Fort Cavazos Drums and Portable Containers. POL Storage areas

55-Gallon Drums and Other Portable Containers

SPCCP Table B-5, Non-Haz Waste Storage 55-Gallon Drums and Other Portable Containers

SPCCP Table B-6, Capitalized Fuels Aboveground Storage Tanks – Field Erected SPCCP Table B-7, American Water Generator Belly Tanks SPCCP Table B-8, Texas Army National Guard

MATES

Aboveground Storage Tanks and 55-gallon Drums

SPCC Table B-9, Fort Cavazos Elevator Hydraulic Systems

Hydraulic Reservoirs

June 2023 Page 6-1

6 INSTALLATION DRAINAGE AND DRAINAGE CONTROLS

6.1 General

Moving surface water, that flows through or are in proximity to the installation, include:

Leon River, Clear Creek, Owl Creek, Cowhouse Creek, and Reese Creek. All water courses flow into Belton Lake, except Lampasas River and Reese Creek. Reese Creek discharges into the Lampasas River. In turn, the Lampasas River flows into Stillhouse Hollow Lake. Belton Lake is along the southeastern border of Fort Cavazos and is operated by the U.S. Army Corps of Engineers (USACE) for flood control, resource conservation, water storage, and recreation. A major part of Fort Cavazos is in the Cowhouse Creek and Owl Creek watersheds draining into Belton Lake. Both Belton and Stillhouse Hollow Lakes are federal reservoirs. A portion of the cantonment area is in the Nolan Creek sub-watershed that drains into the Leon River below Belton Lake. NFC drains into the Leon River above Belton Lake and a portion of WFC drains into the tributaries of the Lampasas River. Fort Cavazos encompasses 250 acres of lakes and ponds, 35 springs, 55 miles of rivers and permanent streams, intermittent waterways, and 161 small impoundments, manmade water bodies that provide flood control, sedimentation detention, wildlife and livestock water, and fish habitat.

The major oil storage facilities at Fort Cavazos are generally widely separated. Fort Cavazos is divided into five general geographic areas as illustrated in Figure 1, located on page 6-2. These are: the Main Cantonment, WFC, BLORA, NFC and the Fort Cavazos Training Area. Most of the storm water at the installation drains to existing storm drainage ditches and/or intermittent waterways, which ultimately drain to Belton Lake. Storm water in the RGAAF Alert Tank Farm drains to water courses that are tributaries to Stillhouse Hollow Lake. Storm water in the the YDAHP RRF ultimately drains to the Leon River to the south of Belton Lake and then into the Little River, which is a part of the Brazos River Basin.

Appendix A contains a site survey and figure for each of the sites identified as a potential oil and hazardous material spill source. These site survey figures show potential pathways on-site for spills that are not contained.

Page 6-2 June 2023

Figure 1: Fort Cavazos Stormwater drainage Diagram

North Fort Cavazos

West Fort

Cavazos

Fort Cavazos Training Area

BLORA

Cowhouse Creek

Henson Creek

Stillhouse Lake Lampassas River

Main Cantonment

June 2023 Page 6-3

6.2 Dike Drainage Control

6.2.1 General

Where Fort Cavazos equips oil storage containment dikes with drain valves, the valves are installed outside the dikes and are manual open-and-closed type valves (Parts 112.8[b][1] and [2]). Flapper-type drain valves are not permitted for use for secondary containment dikes or structures at Fort Cavazos. Standard procedure is to keep the dike valves closed except when draining uncontaminated storm water from the dikes. Sections

6.2.2 to 6.2.4 review the specific dike drainage controls at the DFSP. Many aboveground tanks have a concrete berm with a drain valve around them.