ESPO Travis AFB 2nd NOD Additional Memos_18 Jan 2019.pdf

Jared Blumenfeld Secretary for

Environmental Protection

Department of Toxic Substances Control

Meredith Williams, Ph.D.

Acting Director

8800 Cal Center Drive Sacramento, California 95826-3200

MEMORANDUM

TO: Vinke Menardo, Project Manager Permitting Division - Sacramento Hazardous Waste Management Program

VIA: Perry Myers, P.E.

Senior Hazardous Substances Engineer Engineering and Special Projects Office Brownfields and Environmental Restoration Program

FROM Jesus 1. Sotelo, P.E . ...fa,v k'A.w fit, &uf 1.r-'J Hazardous Substances Engi~der / Engineering and Special Projects Office Brownfields and Environmental Restoration Program

Gavin Newsom Governor

SUBJECT: ENGINEERING AND SPECIAL PROJECTS OFFICE (ESPO) REVIE

OF THE TRAVIS AIR FORCE BASE, FAIRFIELD, CA, SEISMIC

EVALUATION OF ABOVEGROUND STORAGE TANKS AND BUILDING

1365, TRAVIS AIR FORCE BASE, SOLANO COUNTY, CA (EPA ID NO.

CA5570024575)

DATE: January 17, 2019

DOCUMENTS REVIEWED

The result of this review is limited to the following document:

1. Seismic Evaluation of Aboveground Storage Tanks, Travis Air Force Base, Solano County, CA, dated November 19, 2018 (Seismic Evaluation Report) prepared for Travis Air Force Base by ECM Consultants, Costa Mesa, California.

2. Building 1365 Seismic Assessment Report, Travis Air Force Base, California, (Seismic Assessment Report) dated 26 July 2006, prepared for Travis Air Force Base by TranSystems Corporation, Oakland. CA

Vinke Menardo Seismic Evaluation of HW AGS Tanks and Building 1365 January 17, 2019

3. Appendix 6, As-Built and Design Drawings of the HWSF, Travis AFB, which presents the following drawings:

A. AW 33-13-14, Sheets 1-8, 1962 As-built drawing of original ammo storage facility (now Building 1365) and record office (now Building 1366).

B. AB-2.1, AB-2.2, AB-2.3, AB-2.4, AB-2.5, AB-3.1, 2007, Building 1365, field prepared as as-built drawings.

C. G-298, Sheets 2, 4, and 5, 1991, AST Farm design drawings.

4. First Notice of Deficiencies (Nod#1) For the RCRA-Equivalent Permit Renewal

Application for Travis Air Force Base Hazardous Waste Facility, 411 Airmen Drive, Fairfield, California 94535, EPA ID No. CA5570024574, DTSC NOD#1 Part 2 Comments/Response Matrix, dated 28 November 2018.

INTRODUCTION

The Engineering and Special Projects Office (ESPO) of the Department of Toxic Substances Control (DTSC) has reviewed the above-referenced report submittal which evaluates the seismic performance of the six (6) Above-Ground Storage Tanks (ASTs) and Building 1365, Container Storage. lf you have any questions, please contact me at

(916) 255-6670 or via email at jesus.sotelo@dtsc.ca.gov.

PROJECT SUMMARY

The following summary was obtained from Envirostor:

Travis Air Force Base in Fairfield, Solano County, CA is owned by the Department of Defense and operated by the United States Air Force. Because it is one of the busiest military air terminals in United States it is a large generator of hazardous waste. This facility stores their hazardous waste in their Hazardous Waste Storage Facility, which consists of two permitted units: Building 1365 and Tank Farm. The first unit, Building 1365, is a container storage unit that stores flammable solvents, contaminated fuels and lubricants, stripping chemicals, waste petroleum products, waste paint, absorbent materials, spilled and outdated materials, and asbestos. The container storage unit holds drums with capacities ranging from 5 - 55 gallons. The second unit, Tank Farm, consists of six above ground 2,500-gallon tanks that store a variety of used oils and used fuels.

This facility is currently operating under the 2008 RCRA Hazardous Waste Permit, which will expire on January 19, 2018. DTSC received a Permit Renewal Application from the facility in July 2017. On August 18, 2017, DTSC issued an administrative completeness determination and began the technical review of the permit in September 2017.

January 17, 2019 Page3of4

ESPO focused its review and evaluation of the documents with respect to compliance with the CCR, Title 22, Article 10, Tank Systems and comparison to the response to our comment memo dated February 26, 2018.

ESPO has the following comments.

COMMENTS AND RECOMMENDATIONS

1. Seismic Evaluation 2,500 Gallon AST Anchor. The equations for Fp listed in ASCE 7 -16, Chapter 13 section 13.6.1 through 13.3.3 is valid for calculating the seismic demands on nonstructural components and not appropriate for the tank(s). ASCE 7- 16, Chapter 15.7 should be used to evaluate the forces applicable to the tanks seismic response.

2. The Engineer of Record (ECM Consultants) assumed that the tank is a rigid structure. Based upon the c;lata presented by USGS Design Maps Detail Report, plot of Spectral Response Acceleration Sa (g) versus Period, T (in seconds) for ASCE 7-10 Standard (38.262°N, 121.943°W), To is greater than 0.06 which would indicate the structure should not be considered rigid. The period of the tank should be evaluated using one of the methods listed in ASCE 7-16 chapter 12. or chapter 15, and if the period of the tank is greater than 0.06 seconds, the equations listed in ASCE 7-16 15.7.6 should be used to evaluate the overturning moment.

3. ESPO notes that the response to the NOD did not address comment no. 2 and 2(d) of our February 26, 2018 memo. The following deficiencies in regard to section

66264.192 were found in the Seismic Evaluation Report: ·

a. 66264.192(b); According to ASCE 7-16, Section 15.7.6.1.2, sloshing of the stored liquid should be taken into account in the seismic design/evaluation. The equations of this section should be utilized to demonstrate that the tank has adequate freeboard. If adequate freeboard cannot be demonstrated, an analysis of the roof loads should be conducted to verify that the roof can withstand the effect of the sloshing wave. No determination of minimum freeboard for each tank was provided. No evaluation was performed regarding any possible limitation placed on maximum elevation of liquids placed in each tank as may be required to prevent tank failure due to seismic wave sloshing.

b. No description of the type or the degree of external corrosion protection, as required per sub-section (3)(8) and section 66264.192(g), was provided.

4. The Seismic Evaluation Report is deficient with sections 66264.192(e) and 66264.192(1) as tank tightness testing has still not been performed since October 2003.

January 17, 2019

5. ESPO notes that the response to the NOD did not address comment no. 5 of our February 26, 2018 memo. ESPO noted that the Seismic Assessment Report outlines a radius of only 50 miles for determining the length of the significant fault when it should be based upon a significant fault within a radius of 100 kilometers (62 miles). The Seismic Assessment Report is outdated and should be updated to reflect analysis using the latest geologic hazards knowledge and seismic industry practice, knowledge, ground motion prediction models (Next Generation Attenuation [NGA], more specifically NGA West-2) and analyses methods. ESPO notes the current tectonic framework for California is based on the 2015 Uniform California Earthquake Rupture Forecast (UCERF3). The seismic analysis should be expanded to include a full seismic hazards evaluation for all permitted units using the current/latest Industry practice methods including hazards such as liquefaction, lateral spreading and subsidence/settlement that may affect the facility. ESPO recommends use of either ASCE 7-16 or ASCE 41-17 Seismic Evaluation and Retrofit of Existing Buildings.

DISCLAIMER

The Engineering Services review was based solely on the information supplied by the DTSC Project Manager at the time the review was performed and does not constitute a guarantee of the completeness of the information or accuracy of the assumptions used by the responsible party.

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