J-0200000-13 NSA Souda Bay Spill Prevention and Response Plan.pdf

Naval Facilities Engineering Systems Command Europe, Africa, Central

Final

Spill Prevention and Response Plan

Naval Support Activity Souda Bay Greece

September 2023

Prepared for NAVFAC EURAFCENT by CH2M HILL, Inc.

5701 Cleveland Street, Suite 201 Virginia Beach, Virginia 23462 Contract N62470-19-D-4015

CTO N6247020F5616

230808182756_F1A40E1B iii

Contents Acronyms and Abbreviations ......................................................................................................................... vii

1 Plan Administration ......................................................................................................................... 1-1

1.1 Introduction .................................................................................................................................... 1-1

1.2 Regulatory Background .................................................................................................................. 1-2

1.2.1 Environmental Final Governing Standards – Greece ......................................................... 1-2

1.2.2 Overseas Environmental Baseline Guidance Document – Volume 4, Chapter 7 .............. 1-2

1.2.3 Environmental Readiness Program Manual (OPNAV M-5090.1E) .................................... 1-2

1.3 Plan Updates and Changes ............................................................................................................. 1-4

1.4 Plan Certification ............................................................................................................................ 1-5

2 Spill Prevention ................................................................................................................................ 2-1

2.1 Facility Incident Commander and Alternate ................................................................................... 2-1

2.2 Facility Information ......................................................................................................................... 2-1

2.2.1 General Facility Information .............................................................................................. 2-1

2.2.2 Facility Description ............................................................................................................ 2-1

2.3 Applicable Storage Equipment Inventory ....................................................................................... 2-2

2.3.1 Storage Tank Inventory...................................................................................................... 2-2

2.3.2 Areas of Significant Spill Risk ............................................................................................. 2-3

2.4 Inspections and Testing ................................................................................................................ 2-15

2.5 Facility Prevention, Control, and Countermeasures ..................................................................... 2-15

2.5.1 General Measures ............................................................................................................ 2-15

2.5.2 Sized Secondary Containment ......................................................................................... 2-16

2.5.3 General Secondary Containment .................................................................................... 2-17

2.5.4 Secondary Containment for Piping .................................................................................. 2-19

2.5.5 Feasibility of Secondary Containment ............................................................................. 2-19

2.5.6 Deficiencies ...................................................................................................................... 2-19

2.6 Written Procedures ...................................................................................................................... 2-21

2.6.1 Transfers and Overfill Prevention .................................................................................... 2-21

2.6.2 Storage Locations and Container Management .............................................................. 2-21

2.6.3 Facility Management and Maintenance .......................................................................... 2-22

2.7 Emergency Response Equipment ................................................................................................. 2-23

2.8 Evacuation Plans ........................................................................................................................... 2-23

3 Spill Control ..................................................................................................................................... 3-1

3.1 Response Strategies ........................................................................................................................ 3-1

3.1.1 Response Procedures ........................................................................................................ 3-3

3.1.2 Response Resources .......................................................................................................... 3-3

3.1.3 Aqueous Film-Forming Foam Release Notifications .......................................................... 3-4

3.1.4 Non-Navy Incidents ........................................................................................................... 3-4

3.2 Emergency Response Information .................................................................................................. 3-4

3.2.1 Facility Response Team Personnel Structure .................................................................... 3-5

3.2.2 Qualified Personnel Responsibilities and Duties ............................................................... 3-7

3.2.3 Response Equipment List ................................................................................................. 3-12

3.2.4 Response Procedures ...................................................................................................... 3-12

3.3 Notification Procedures ................................................................................................................ 3-12

3.3.1 Available Communication Systems .................................................................................. 3-12

3.3.2 Public Affairs Involvement ............................................................................................... 3-13

3.3.3 Notification Phone List .................................................................................................... 3-13

SPILL PREVENTION AND RESPONSE PLAN

NAVAL SUPPORT ACTIVITY SOUDA BAY, GREECE

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3.3.4 Arrangements with Emergency Services and External Resources .................................. 3-14

3.4 Discharge Detection Systems ....................................................................................................... 3-14

3.4.1 Inspections ....................................................................................................................... 3-14

3.4.2 Discharge Detection by Personnel ................................................................................... 3-15

3.4.3 Automated Discharge Detection Systems ....................................................................... 3-15

3.5 Sensitive Environments ................................................................................................................ 3-15

3.5.1 Flora and Fauna ............................................................................................................... 3-15

3.5.2 Cultural Resources ........................................................................................................... 3-16

3.5.3 Water Resources .............................................................................................................. 3-16

3.6 Response Resources for Spills ...................................................................................................... 3-17

3.6.1 Worst-case Discharge Planning Volume .......................................................................... 3-17

3.6.2 Spill Prevention and Response Methods ......................................................................... 3-19

3.6.3 Disposal Plans .................................................................................................................. 3-19

3.6.4 General Health and Safety Precautions for Spill Response Actions ................................ 3-19

3.6.5 Public Affairs .................................................................................................................... 3-20

3.7 Response Training and Drills/Exercises ........................................................................................ 3-21

3.7.1 Training ............................................................................................................................ 3-21

3.7.2 Drills and Exercises .......................................................................................................... 3-23

4 Reporting and Recordkeeping Requirements .................................................................................... 4-1

4.1 Recordkeeping ................................................................................................................................ 4-1

4.2 Notifications.................................................................................................................................... 4-1

4.2.1 Tier II/III Notifications ........................................................................................................ 4-2

4.2.2 Host Nation Notification .................................................................................................... 4-2

4.2.3 Defense Logistics Agency Notifications ............................................................................. 4-2

4.3 Reporting of Significant Spills ......................................................................................................... 4-2

4.4 Navy Spill Report Messages ............................................................................................................ 4-2

4.5 Incident Review .............................................................................................................................. 4-3

5 References ....................................................................................................................................... 5-1

Appendices

A Cross-Reference Matrix B Site Maps and Figures C Storage Tank Inventory and Accumulation Areas D Site-Specific Standard Operating Procedures E Spill Scenarios and Calculations F Marathi Pier Booming Strategies G Spill Response Equipment and Marathi Pier Resource Guides H Evacuation Maps I Incident Command System Form 201 J NSA Souda Bay Initial Site Safety Plan K Installation Pest Management Plan

Tables

2-1 Spill and Release Prevention Methods ......................................................................................................... 2-15 2-2 Deficiencies ................................................................................................................................................... 2-20 2-3 NSA Souda Bay Approved Pesticides ............................................................................................................ 2-22

3-1 OHS Response Strategies ................................................................................................................................ 3-2 3-2 Core Response Elements and Strategies for POL Spills .................................................................................. 3-2

CONTENTS

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3-3 Greek Spill Response Companies .................................................................................................................... 3-4 3-4 Facility Response Team Members .................................................................................................................. 3-6 3-5 Emergency Dispatch Notification Numbers .................................................................................................. 3-13 3-6 Marathi Pier Ship Fueling Worst Case Discharge ......................................................................................... 3-18 3-7 IRO/IMT Training Requirements ................................................................................................................... 3-22 3-8 Core Test Components of a Response Plan .................................................................................................. 3-23 3-9 Petroleum, Oil, and Lubricants and Hazardous Substances Drills and Exercises ........................................ 3-23

4-1 Officials Approved to Contact Emergency Response Resources .................................................................... 4-2 4-2 "Significant" Spill Thresholds .......................................................................................................................... 4-3

Figures

2-1 USTs CAC-116-01 and CAC-117-01 (Bulk Storage Area) ................................................................................. 2-4 2-2 Tanks AST-014-01 and EMR-014-01 ............................................................................................................... 2-6 2-3 Tank AST-050-01 and EMR-093-01 ................................................................................................................. 2-8 2-4 Tanks AST-C65-01, EMR-C65-01, EMR-C65-02, AST-002-01, and DAY-002-01 ............................................ 2-10 2-5 Tanks UST-078-01, UST-078-02, UST-078-03, Marathi Pier Complex .......................................................... 2-12 2-6 Tank EMR-PTO-01 ......................................................................................................................................... 2-14

3-1 NSA Souda Bay Incident Response Organization ............................................................................................ 3-1 3-2 Initial POL and HS Response Organization...................................................................................................... 3-4 3-3 NSA Souda Bay Petroleum, Oil, and Lubricants and Hazardous Substances Spill Reporting Paths ............. 3-13 https://jacobsengineering-my.sharepoint.com/personal/karen_malley_jacobs_com/Documents/Documents/Work/Graycochea_Kathleen/11_NOVEMBER/November%2028%20-%20Souda%20Bay%20SPRP/NSA_SoudaBay_SPRP_Draft_V2%20Clean.docx#_Toc120628462 https://jacobsengineering-my.sharepoint.com/personal/karen_malley_jacobs_com/Documents/Documents/Work/Graycochea_Kathleen/11_NOVEMBER/November%2028%20-%20Souda%20Bay%20SPRP/NSA_SoudaBay_SPRP_Draft_V2%20Clean.docx#_Toc120628463 https://jacobsengineering-my.sharepoint.com/personal/karen_malley_jacobs_com/Documents/Documents/Work/Graycochea_Kathleen/11_NOVEMBER/November%2028%20-%20Souda%20Bay%20SPRP/NSA_SoudaBay_SPRP_Draft_V2%20Clean.docx#_Toc120628464

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Acronyms and Abbreviations AFFF aqueous film-forming foam AGE aerospace ground equipment AST aboveground storage tank ATG automatic tank gauging

BOSC Base Operations Support Contract

CAT Crisis Action Team CCIR Commander’s Critical Information Requirement CDO Command Duty Officer CH2M CH2M HILL, Inc.

CHRIMP Customer Hazardous Materials Reutilization and Inventory Management System CNIC Commander, Naval Installations Command CO Commanding Officer CRMP Cultural Resources Management Plan

DLA Defense Logistics Agency DoD Department of Defense DSA drum storage area

EM Emergency Management EMO Emergency Management Officer EOC Emergency Operations Center EURAFCENT Europe, Africa, Central EVSC Environmental Services Coordinator

FEAD Facilities Engineering and Acquisition Division FES Facility Emergency Services FGS Final Governing Standards FIC Facility Incident Commander FLC Fleet Logistics Center FRT Facility Response Team gpm gallon per minute

HAF Hellenic Air Force HMMP Hazardous Material Management Plan HN host nation HS hazardous substance(s) HW hazardous waste HWAP Hazardous Waste Accumulation Point HWMP Hazardous Waste Management Plan HWSA Hazardous Waste Storage Area

IC Incident Commander ICS Incident Command System ID identification IMT Incident Management Team IPMP Integrated Pest Management Plan IRO Initial Response Organization

LEC lead environmental component viii 230808182756_F1A40E1B

MARAD Maritime Administration Mogas motor gasoline MOU memorandum of understanding MSC Military Sealift Command MWR Morale Welfare Recreation

N/A not applicable NATO North Atlantic Treaty Organization NAVFAC Naval Facilities Engineering Systems Command NAVSUP Naval Supply Systems Command Navy Department of the Navy NOSC Navy On-Scene Coordinator NSA Naval Support Activity

OEBGD Overseas Environmental Baseline Guidance Document OFOE oil-filled operational equipment OHS oil and hazardous substance OPNAV Operational Navy Instruction OSIC On-scene Incident Commander

OWS oil-water separator

PAO Public Affairs Officer PCB polychlorinated biphenyl POL petroleum, oil, and lubricants PPE personal protective equipment PREP Preparedness for Response Exercise Program PWD Public Works Department

QI qualified individual

ROC Regional Operations Center RQ reportable quantity

SDS Safety Data Sheet SITREP situational report SJA Staff Judge Advocate SMT spill management team SO Safety Officer SPRP Spill Prevention and Response Plan STMP Storage Tank Management Plan

TWSA temporary waste storage area

U.S. United States UFC Unified Facilities Criteria UST underground storage tank

WCD worst-case discharge

XO Executive Officer

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1 Plan Administration In the event of a spill, initiate response actions described in the NSA Souda Bay Red Plan.

1.1 Introduction

This Spill Prevention and Response Plan (SPRP) has been prepared by Jacobs, for Naval Facilities Engineering Systems Command (NAVFAC) Europe Africa Central (EURAFCENT), under NAVFAC Atlantic's Multimedia Program, Contract No. N62470-19-D-4015, Task Order N6247020F5616. This SPRP meets the requirements for spill prevention and response planning as required by Volume 4, Section 7 of the 2020 Department of Defense (DoD) Manual 4715.05, Overseas Environmental Baseline Guidance Document (OEBGD) (DoD, 2020) and Chapter 18 of the Final Governing Standards (FGS) for Greece (DoD, 2014). Remediation of affected areas is not within the scope of this document and instead will be conducted pursuant to DoD Instruction 4715.08 Remediation of Environmental Contamination Outside the United States (DoD, 2018).

This SPRP is applicable to all petroleum, oils, and lubricants (POL) and hazardous substances (HS), including pesticides and polychlorinated biphenyl (PCB)-containing equipment, located within NSA Souda Bay. This SPRP also serves as the installation Hazardous Waste (HW) Contingency Plan, consistent with requirements set out in Chapter 6.3.6.1 of the Greece FGS (DoD, 2014). Copies of this plan will be submitted to the NSA Souda Bay police, fire department, Emergency Management, Port Operations, and first responders.

This SPRP is applicable to the following locations:

• NSA Souda Bay – Topside

• NSA Souda Bay – Bulk Storage Area

• NSA Souda Bay – Marathi Pier Complex

• NSA Souda Bay - Malaxa

The Public Works Department (PWD) Environmental Division is proactive with respect to training and ensures NSA Souda Bay meets requirements outlined in the Greece FGS (DoD, 2014). Appropriate NSA Souda Bay personnel have been identified and trained for spill prevention and response, and written procedures guide personnel performing inspections and monitoring regulated activities. Because NSA Souda Bay is dynamic by nature, it is important to continue the practices of training and monthly inspections for spill prevention as equipment degrades and personnel rotate through the facility.

The PWD Environmental Division is responsible for ensuring environmental compliance by conducting required environmental inspections, identifying training requirements, and recordkeeping for NSA Souda Bay. Tenant commands and contractors operating at NSA Souda Bay are responsible for oil storage and/or transfer operations at their respective facilities or complexes.

The SPRP is organized to function with the Red Plan (Jacobs, 2023b), which provides the user with the necessary information in the initial emergency response to a spill incident. In addition, NSA Souda Bay maintains a Storage Tank Management Plan (STMP) (Jacobs, 2023a) and Hazardous Waste Management Plan (HWMP) (Navy, 2018b) to provide guidance on proper operation and maintenance of storage tank systems to prevent spills and disposal of HWs generated by POL-related activities.

NSA Souda Bay is presently in substantial conformance with Greece FGS requirements. However, several deficiencies exist and should be addressed immediately to return to full compliance. Refer to Table 2-2 for the list of regulatory deficiencies identified during the site visit and best engineering practice recommendations for resolution. The NSA Souda Bay PWD Environmental Division maintains current inspection reports and corrective action status.

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1.2 Regulatory Background

1.2.1 Environmental Final Governing Standards – Greece

The Greece FGS provides environmental compliance criteria at United States (U.S.) DoD installations in Greece.

The Greek FGS implements the DoD Instruction 4715.05, Overseas Environmental Baseline Guidance Document (OEBGD) (DoD), 2020). This SPRP will address the following sections of the Greek FGS:

• Chapter 9 Petroleum, Oil, and Lubricants (POL), includes criteria to control and abate pollution resulting from the storage, transport, and distribution of petroleum products.

• Chapter 18 of the Greece FGS (DoD, 2014), requires all DoD installations in the country to prepare, maintain, and implement a SPRP that provides for the prevention, control, response, and reporting of POL and HS spills.

• The requirements in Chapter 19 of the Greece FGS, for underground storage tanks (USTs), apply to NSA Souda Bay. Refer to the NSA Souda Bay STMP (Jacobs, 2023a) for the requirements for the management of USTs.

This SPRP covers the prevention and response requirements for spills that occur from the transfer of fuel to and from the USTs.

1.2.2 Overseas Environmental Baseline Guidance Document – Volume 4, Chapter 7 The OEBGD identifies baseline standards for installations to ensure the protection and management of historical and cultural resources and the conservation of natural resources and species at risk (DoD, 2020) using the following methods:

• Implements policy, assigns responsibilities, and provides standards to protect human health and the environment on enduring installations under DoD control outside the U.S..

• Considers and, where relevant, incorporates generally accepted federal environmental standards applicable to DoD installations, facilities, and actions in the U.S., and incorporates requirements of U.S. law that have extraterritorial application to the DoD.

• Is used by DoD lead environmental components (LECs) to establish and update FGSs.

• Establishes baseline environmental standards for installations in countries for which an FGS is not required or has not been developed.

Section 3.1 of the OEBGD (DoD, 2020) states the following:

Compliance with the standards of this volume is achieved by complying with the current FGSs, since the standards of this volume are reflected in the FGSs. In cases where updates or revisions to this volume have not yet been considered and incorporated into an FGS, installations must comply with the more protective standard, whether it is found in this volume or the FGS.

The current OEBGD was effective June 29, 2020, while the Greece FGS (DoD, 2014) was effective September 7, 2012, and revised in 2014. At the time of the development of this plan, the FGS had not been updated to incorporate the updates made to the 2020 OEBGD. Therefore, the requirement listed in Section 3.1 of the OEBGD has been followed in the development of this SPRP. Cross-reference matrixes of Chapter 18 of the Greece FGS and OEBGD Volume 4, Section 7 requirements are provided in Appendix A.

1.2.3 Environmental Readiness Program Manual (OPNAV M-5090.1E) The Environmental Readiness Program Manual - Operational Navy Instruction (OPNAV) M-5090.1E is the governing document for environmental compliance within the Department of the Navy (Navy). The manual itself does not outline compliance rules, but instead requires all Navy shore activities to meet the requirements of the FGS and OEBGD in addition to applicable host country rules and regulations.

1—PLAN ADMINISTRATION

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This SPRP will primarily address spill response and prevention guidance provided in the following relevant chapters of the OPNAV M-5090.1E (Navy, 2021a):

• Chapter 34 – Overseas Environmental Compliance Ashore

• Chapter 39 – Oil and Hazardous Substance Spill Preparedness and Response

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1.3 Plan Updates and Changes

In accordance with Greece FGS Chapter 18.3.1 (DoD, 2014) and OEBGD Volume 4, Section 7.2.a (DoD, 2020), the SPRP must be updated every 5 years or as follows:

• Within 6 months of any significant changes to operations

• When there have been two significant spills to waters of the host nation (HN) in any 12-month period

• When there has been a spill of 3,785 liters [1,000 gallons] or greater

Change Number Page(s) Affected Abstract/Description Date Initial

1 All 5-year update; format change;

Incorporate requirements of 2020 OEBGD August 2022

1—PLAN ADMINISTRATION

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1.4 Plan Certification

This SPRP for NSA Souda Bay has been prepared in accordance with good engineering practice, the information provided by the facilities (which is assumed correct), industry standards for spill prevention and environmental protection, and information obtained during the site visit conducted in April 2022. It was prepared in accordance with the requirements of the OEBGD approved June 2020 and the requirements of Chapter 18 (Spill Prevention and Response Planning) Greece FGS approved September 7, 2012, revised May 2014. This SPRP is adequate for each facility included.

This certification in no way relieves the owner or operator of the facility of his or her duty to prepare and fully implement this SPRP in accordance with the requirements of FGS. This SPRP is valid only to the extent that the facility owner or operator maintains, tests, and inspects equipment, containment, and other devices as prescribed in this plan.

Signature: __________________________________________ Date: _____________________

Michael Wirtz, PE Registered Professional Engineer Idaho Registration No. 13330

9/20/2023

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2 Spill Prevention

2.1 Facility Incident Commander and Alternate

The Commanding Officer (CO) of NSA Souda Bay is the Facility Incident Commander (FIC). Per the OPNAV 5090.1E Chapter 39-3.1(c), the title of FIC cannot be delegated. The CO has designated the following Incident Commanders (ICs) during a spill response for each location unless otherwise directed by the CO:

• Fire and Emergency Services as the IC for all spills at all sites except at the Marathi Pier Complex.

• Port Operations as the IC the Marathi Pier Complex.

The IC will conduct first responder actions, including source control, containment, site stabilization, and safety and security coordination. Additional resources from the local fire department can be called in by Emergency Dispatch if needed.

2.2 Facility Information

2.2.1 General Facility Information

Facility Owner/Operator: CO/NSA Souda Bay

Address: U.S. Navy Support Activity Souda Bay PSC 814 Box 11

FPO AE 09266

Telephone: +011-30-2821-021000

Greek Address:

Αμερικάνικη Ευκολία Αεροπορικής Βάσης Σουδας Μουζουράς Ακρωτηρίου, Χανιά, Κρήτη

2.2.2 Facility Description

NSA Souda Bay is a tenant activity on the Hellenic (Greek) Air Force Base by the village of Mouzouras, 17 kilometers (approximately 10 miles) east of the city of Chania. NSA Souda Bay occupies an area of approximately 110 acres on the north side of the Base, which is the home of the Hellenic Air Force's 115th Combat Wing. The airfield also serves as the civilian airport for the Chania region of Crete. The civilian terminal is located at the opposite end of the runway and is not within walking distance. The activity is located on the Akrotiri Peninsula, which forms the northern face of the Souda Bay harbor. A Hellenic Naval Base occupies a large portion of both the north and south coast of the Souda Bay harbor along with the port village of Souda.

At Marathi Pier, the fuel facility is owned by the Command Navy Installation Command (CNIC), and the fuel is owned by Defense Logistics Agency (DLA). Vertex is under contract to the DLA as the DLA fuels contractor at the NSA Souda Bay Bulk Storage Area, which receives fuel from the Marathi Pier via an underground pipeline. In the event of a POL release, the Navy Port Operations personnel are in position to lead and support containment, recovery, and coordination of off-spec oil disposal of spills from U.S.-owned or -contracted vessels. There are storage tanks under the responsibility of NSA Souda Bay located within the Marathi Pier Complex. The complex is located on the northern face of Souda Bay harbor, approximately 2 miles south of the Hellenic Airforce Base.

Detailed site figures, including the stormwater drainage system, for each facility are provided in Appendix B.

The four locations included in this SPRP that have POL, HS, and HW storage are as follows:

• Topside

• Bulk Storage Area

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• Malaxa

• Marathi Pier Complex

The Bulk Storage Area is located on the eastern side of NSA Souda Bay (refer to Figure B-2 found in Appendix B).

JP-5 coming from the North Atlantic Treaty Organization (NATO) POL facility at the Marathi Pier Complex enters NSA Souda Bay from the east and is pumped to one of two 500,000-gallon underground fuel storage tanks (CAC-116-01 and CAC-117-01). From there, the JP-5 can be pumped to 15 fueling hydrants along the flightline and a bulk storage fill stand, or to the four active day tanks (UST-081-01, UST-081-02, UST-081-03, and UST-081-04), and to fill the five mobile refuelers at Bulk Storage Area 81. The Bulk Storage Area is managed by the DLA fuels contractor.

Malaxa is a hilltop communications site south of NSA Souda Bay and across the bay (refer to Figures B-1 and B-3 found in Appendix B). The approximately 0.17 acre site is surrounding by a perimeter security fence and consists of towers, and support equipment. The site is unmanned but routinely checked.

The Marathi Pier Complex (refer to Figures B-1 and B-3 found in Appendix B) is a pier that the Navy jointly operates with the Hellenic Navy under a Memorandum of Agreement dated May 30, 1990 (Appendix D). The Navy uses the area of land between the POL and Ammunition Depots at Souda Bay primarily for ship support including repairs, offloading, and resupply. The Marathi Pier Complex remains under the command of the Hellenic Republic; however, the Navy retains command and control over U.S. personnel, equipment and operations while using the facility. The Navy Port Operations are the lead support for containment, recovery, and coordination of response actions from spills from U.S. vessels or U.S.-contracted vessels. An underground pipeline between the NATO POL facility at the Marathi Pier Complex and NSA Souda Bay is maintained by the Hellenic Republic. If a spill involving the pipeline were to occur, the Hellenic Navy would respond and potentially request aid of the Navy.

2.3 Applicable Storage Equipment Inventory

NSA Souda Bay stores a variety of POL and HS for use in fueling, ground vehicle operation, and facility maintenance. Fuels are stored in aboveground storage tanks (ASTs) and USTs. Off-spec fuels and nonfuel POL products such as used cooking oil, lubricating oils, and hydraulic fluids are stored in smaller, 55-gallon (208-liter) drums or 275-gallon (1,041-liter) portable plastic totes.

POL transfers are conducted by mobile refuelers. Smaller transfers such as generator tank fueling are completed by a Navy or DLA fuels contractor refueler trucks ranging in size from 1,200 gallons (4,542 liters) to 5,000 gallons (18,927 liters). Defueling operations utilize three mobile bowsers, two of which are 500 gallons (1,893 liters) and one is 600 gallons (2,271 liters).

Jet fuel is supplied via a 6-inch underground pipeline maintained by Greece that transfers fuel from where it is off-loaded at the Marathi Pier Complex to NSA Souda Bay Topside. Once the fuel arrives at NSA Souda Bay Topside, it is stored in one of two bunkered 500,000-gallon USTs (CAC-116-01 and CAC-117-01)

Detailed specifications for all assets classified as oil storage containers can be found in the NSA Souda Bay STMP (Jacobs, 2023a). The locations of all assets are shown in Appendix B.

2.3.1 Storage Tank Inventory

The storage tank inventory is provided in Appendix C and includes the following tables:

Table C-1 lists the storage, handling, and transfer areas of POLs located at NSA Souda Bay. It also includes information on typical spill scenarios from each asset.

Table C-2 lists oil-filled operational equipment at NSA Souda Bay.

Table C-3 lists potential mobile refueling locations at NSA Souda Bay and identifies the fuels at each.

Table C-4 lists the HW accumulation points and temporary waste storage areas (TWSAs) at NSA Souda Bay.

2—SPILL PREVENTION

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Table C-5 lists the drum storage areas (DSAs) (both POL and HS) at NSA Souda Bay. All DSAs are located inside buildings and not exposed to stormwater.

2.3.2 Areas of Significant Spill Risk

The OEBGD (DoD, 2020) defines a significant spill as the following:

“For hazardous wastes or hazardous substances identified as a result of inclusion in Table 6 of Appendix 5A of Volume 5, any quantity in excess of the reportable quantity listed in that table;

• For POL or liquid or semiliquid hazardous material, hazardous waste, or hazardous substances in excess of 416 liters [110 gallons];

• For other solid hazardous material in excess of 225 kilograms [500 pounds]; or

• For combinations of POL and liquid, semiliquid, and solid hazardous materials, hazardous waste, or hazardous substance in excess of 340 kilograms [750 pounds].

If a spill is contained inside an impervious berm, on a nonporous surface, or inside a building and is not volatilized and is cleaned up, the spill is considered a contained release and is not considered a significant spill.”

Areas with inadequate secondary containment measures, high fuel throughput, fuel transfer operations within 25 feet (8 meters) of a storm drain, fuel operations including the storage and transfer of aircraft fuel, and over the water pipeline fueling were considered high risk areas for a significant spill.

2.3.2.1 Top Side

USTs CAC-116-01 and CAC-117-01 (Bulk Storage Area)

Tanks CAC-116-01 and CAC-117-01 are 500,000-gallon (1,782,705-liter) bulk storage USTs within the Bulk Storage Area on the east end of the runway. Each tank is double- walled with an earthen cover. The tanks receive JP-5 from the Marathi Pier Complex via a 6-inch underground pipeline that can transfer up to 620 gallons per minute.

Each tank is equipped with pump auto shut off, high level alarm, and monitored double bottom. During transfers from Marathi Pier Complex, personnel are at each end of the pipeline with handheld radios and in constant communication. The pipeline is equipped with a pressure alarm.

The fuel passes through a fuel filter prior to entering USTs CAC-116-01 and CAC-117-01. Fuel from the bulk storage tanks transfers to 15 hydrant fuel pits, as well as a mobile refueler fuel stand. The fuels system is monitored by Navy Supply Systems Command (NAVSUP) DLA fuels contractor. The DLA fuels contractor also maintains and operates the five NAVSUPNIC-owned mobile refuelers (TRK-245 through TRK-249) to refuel aircraft on the flightline.

Fuel transfers to the 15 hydrants along the flightline is pumped at 600 gallons per minute (gpm) under normal conditions and up to 1,200 gpm when fueling two aircraft (when a second pump is used).

Flow rate of transfers from the bulk storage tanks to the refuelers is estimated at 500 gpm. The transfer to the refuelers is completed within a covered structure with secondary containment that drains into an OWS.

Spills from USTs CAC-116-01 and CAC-117-01 and would be a result of fuel transfers both from the Marathi Pier Complex and to the pumps and hydrants. The surge tank valve can isolate the bulk storage tanks from the underground pipeline and remains closed unless active filling is occurring. An estimated 3-minute response time is estimated to shut down flow since flow is controlled by the Greek at the Marathi Pier Complex.

Spills within the CAC-116-01 and CAC-117-01 tanks would collect inside the double tank. Hatches on top of the tank system help keep stormwater out of the double tank containment.

Figure 2-1 presents the most likely spill flow direction for a spill at USTs CAC-116-01 and CAC-117-01.

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Figure 2-1. USTs CAC-116-01 and CAC-117-01 (Bulk Storage Area)

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Tanks AST-014-01 and EMR-014-01

The 396-gallon (1,499-liter) AST-014-01 provides diesel for emergency backup generator EMR-014-01, which has a 70-gallon (265 liter) belly tank for the Potable Water Pump House. Both the AST and the emergency generator are located within 25 feet (8 meters) of a storm drain to the west and north. AST-014-01 is a double-walled tank which provides fuel directly to EMR-014-01. The fuel line running from AST-014-01 to the emergency generator is double walled. The belly tank associated with EMR-014-01 is a single-walled tank but not in use; EMR-014-01 will remain in this inventory.

The most likely discharge scenario is a release of fuel from fuel transfers through piping associated with filling AST-014-01. A storm drain is located 9 feet (3 meters) to the west of AST-014-01. Response should focus on containment and prevention by diverting spill and securing the storm drain. During use, spill kits with storm drain blockers must be maintained at the site and storm drain blockers used during fueling operations.

Figure 2-2 presents the most likely spill flow direction for a spill at AST-014-01.

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Figure 2-2. Tanks AST-014-01 and EMR-014-01

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Tank AST-050-01 and EMR-093-01

AST-050-01 is a Convault ® concrete split tank with 1,000-gallon (3,785 liter) diesel tank and a 1,00-gallon (3,785 liter) JP-5 tank and is used for vehicle and ground support equipment fueling by the U.S. Air Force and Air Operations.

The most likely discharge scenario is a release of fuel from fuel transfers into the tank during vehicle fueling operation. A concrete lined stormwater ditch is located 23 feet (7 meters) to the east of AST-050-01. Response should focus on containment and prevention by diverting spill and securing the stormwater ditch. Spill kits with containment boom must be maintained at the site and absorbent boom used during fueling operations. Currently, if a spill reaches the ditch, it would flow to an underground stormwater pipe that discharges into the stormwater pond at the west end of the airfield. NSA Souda Bay plans to construct an earthen berm within the stormwater pond downstream of the discharge to contain any releases. Moving the AST away from the stormwater ditch would reduce the risks associated with tank filling and fuel transfers.

EMR-093-01 is a 95-gallon (360-liter) diesel belly tank associated with an emergency generator that provides emergency backup power for the fire department. The AST is located within 25 feet (8 meters) of a stormwater ditch to the south. The generator is located within a sufficiently sized secondary) containment. The most likely discharge scenario is a release of fuel from fuel transfers filling the belly tank associated with the generator. A concrete lined stormwater ditch is located 17 feet (5 meters) to the south.

Responses should focus on containment and prevention by diverting spill and securing the stormwater ditch.

When in use, spill kits with stormwater ditch blockers must be maintained at the site and stormwater ditch blockers used during fueling operations.

Figure 2-3 presents the most likely spill flow direction for a spill at AST-050-01 and EMR-093-01.

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Figure 2-3. Tank AST-050-01 and EMR-093-01

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Tank AST-C65-01

The 2,000-gallon (7,570-liter), double-walled AST-C65-001 provides diesel fuel for two emergency generators (EMR-C65-01 and EMR-C65-02) at the facility.

The most likely discharge scenario is a release of fuel from fuel transfers through tank filling. A storm drain is located 29 feet (9 meters) to the east of AST-C65-01. Even though the tank is greater than 25 feet from the nearest storm drain, this area is considered high risk due to the capacity of the tank and volume of fuel transfers to the two emergency generators. Response should focus on containment and prevention by diverting spill and securing the storm drain. During use, spill kits with storm drain blockers must be maintained at the site and storm drain blockers used during fueling operations.

Figure 2-4 presents the most likely spill flow direction for a spill at AST-C65-01.

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Figure 2-4. Tanks AST-C65-01, EMR-C65-01, EMR-C65-02, AST-002-01, and DAY-002-01

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Tanks UST-078-01, UST-078-02, and UST-078-03

The Souda Bay Filling Station consists of three USTs (UST-078-01, UST-078-02, and UST-078-03) that supply fuel to dispenser pumps located directly to the north of the tanks. Tanks UST-078-01 and UST-078-02 provide Mogas (gasoline) while tank UST-078-03 provides diesel. Spills from this area would be a result of fuel transfers into vehicles by untrained personnel and during fuel transfer operations of the USTs. Fuel is delivered to the USTs via commercial fuel trucks operated by a HN contractor.

Fuel is transferred from the HN contractor truck to the USTs by gravity. In case of an emergency, the HN contractor who is standing by the truck’s outlet valve, will shut it off.

Fuel is transferred from USTs to vehicles using dispensers. The dispensers are equipped with a shear valve that will automatically stop the fuel flowing from the dispenser hoses in the event the valve is broken for any reason. A spill kit is permanently staged at the Filling Station between the dispensers and all fuel trucks are equipped with a spill kit.

A spill from the Filling Station would flow south along paved asphalt to a concrete lined stormwater trench with metal grating over the top and discharge to an oil/water separator under the parking lot on the northwestern side of Building 95. UST-078-02 (23 feet [7 meters]) and UST-078-03 (11 feet [4 meters]) are both within 25 feet of the concrete lined stormwater trench. Due to the proximity of the stormwater channel and no physical barriers to stop a flow, during loading and unloading operations of the USTs, rubber spill blockers should be put in place to contain any spills or overfills during transfer operations and divert from the concrete lined stormwater channel. At the time of the site visit, a recent spill at the fuel dispensers nearly entered the stormwater trench. First responders were able to block the fuel flow path before entering the trench and allowed for the spill fuel to be collected.

Figure 2-5 presents the most likely spill flow direction for a spill at the Souda Bay Filling Station.

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Figure 2-5. Tanks UST-078-01, UST-078-02, UST-078-03, Marathi Pier Complex

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Tank EMR-PTO-01

Generator EMR-PTO-01 has a 122-gallon (462-liter) diesel belly AST. The generator sits within a concrete diked containment area and is under cover. At the time of the site visit, the generator was 50 feet (16 meters) from the water line. However, the generator will be within 25 feet (8 meters) of the water line during tidal and storm conditions and the slope of the shore.

The most likely discharge scenario is a release of fuel from fuel transfers filling the tank. Response should focus on containment and prevention by diverting spill and damming the flow path. When used, spill kits with sorbents and damming materials must be maintained at the site. In the event discharge reaches the bay, booming strategies identified in Appendix F will be employed.

Figure 2-6 presents the most likely spill flow direction for a spill at EMR-PTO-01.

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Figure 2-6. Tank EMR-PTO-01

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2.4 Inspections and Testing

NSA Souda Bay follows the inspection and testing requirements for POL ASTs, USTs, OFOE, and piping that are included in the NSA Souda Bay STMP.

All POL ASTs, aboveground piping, valves, and appurtenances are visually inspected for leaks on a routine basis (monthly and annually). All buried piping is monitored monthly if the piping system has a leak detection system or tightness tested annually for leaks. Transformers considered OFOE are inspected annually. The NSA Souda Bay STMP provides inspection checklists for POL storage tanks and DSAs. Containers located at TWSAs must be inspected weekly in accordance with the NSA Souda Bay HWMP (Navy, 2018b).

Inspection and testing records are maintained by the PWD Environmental Division, NAVSUP DLA fuels contractor, and Navy Exchange.

2.5 Facility Prevention, Control, and Countermeasures

2.5.1 General Measures

Personnel that use or manage POL or HS will adhere to the storage and handling requirements for the chemical or physical hazardous described in the Safety Data Sheets (SDSs) and many other Navy and DoD policies, requirements, instructions, and procedures. To protect human health and the environment, the general prevention, control, and countermeasures listed in Table 2-1 will be used when handling and storing POL and HS containers.

Table 2-1. Spill and Release Prevention Methods

Release Prevention Method Description 1

Standard Operating Procedures SOPs are available in the STMP, Hazardous Waste Management Point, Hazardous Material Management Point, Appendix D.

Booming strategies for Marathi Pier are provided in Appendix F.

The Marathi Pier Resource Guide is provided in Appendix G.

Inspections Routine inspections are one of the most important spill prevention tools used at NSA Souda Bay. See the NSA Souda Bay STMP (Jacobs, 2023a) and HWMP (Navy, 2018b) for inspection procedures.

Training HAZAMT Coordinators receive training that includes detailed discussions of potential spills at NSA Souda Bay. Personnel are trained in the location and use of personal protective equipment (PPE) and spill response equipment. More detail on the training requirements is provided in Section 3.6.

Security and Lighting NSA Souda Bay maintains a secure perimeter that is patrolled by security forces.

Recordkeeping Inspection recordkeeping requirements are discussed in Section 4.

Preventive Maintenance All ASTs, USTs, oil-containing equipment, and other POL and HS response equipment are serviced regularly to ensure that it is available to support the mission of NSA Souda Bay.

The emergency generators are operated to ensure that they will function properly in an emergency. When preventive maintenance is performed on the generators, the entire oil supply and transfer system is inspected and any required maintenance is performed.

Secondary Containment Tanks at NSA Souda Bay are provided with adequate secondary containment except those listed in Table C-1. New AST installations shall be of double-walled construction, eliminating the need for open containment structures.

Facility Drainage The stormwater infrastructure is mapped to aid in spill prevention and response. Maps are located in the current version of the Stormwater Pollution Prevention Plan and are also located at the PWD office.

1 NAVSUP also has separate SOPs not detailed in this SPRP.

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2.5.2 Sized Secondary Containment

2.5.2.1 POL and Hazardous Substances Storage Containers

OEBGD, Volume 4, Section 5.4.c.(1).(a) requires all POL storage containers to be provided with a sized secondary means of containment capable of holding the entire contents of the largest single tank plus sufficient freeboard to allow for precipitation (DoD, 2020).

Based off the Mediterranean Cyclone Characteristics Related to Precipitation Occurrence in Crete, Greece, it is estimated that 55 millimeter (2.2 inches) of rain can fall over a 24-hour period (Technical University of Crete, 2015).

NSA Souda Bay uses double-walled ASTs and diked containments as methods of secondary containment for shop-fabricated tanks. Refer to Table C-1 and the NSA Souda Bay STMP (Jacobs, 2023a) for detailed secondary containment specifications for each POL storage container.

NSA Souda Bay has a Navy Supply Hazardous Materials facility (Building 59), also known as Consolidated Material Reutilization and Inventory Management Program (CHRIMP), that stores hazardous materials before being distributed to the customer. The Navy Supply Hazardous Materials facility has sized secondary containment units that provide containment sufficient to contain the contents of the single largest chemical containers stored within.

Directly beside the Navy Supply Hazardous Materials facility is the NSA Souda Bay Hazardous Waste Storage Area (HWSA) (Building 60) that stores HWs received from the Base tenants and Navy ships. The HWSA facility has a partially covered secondary containment that provides sufficient secondary storage (4,265 square feet steady state and maximum contingency area of 7,429 square feet) for in excess of the single largest storage container stored within.

Throughout NSA Souda Bay are temporary hazardous materials and HW storage structures or Hazardous Waste Accumulation Points (HWAP) including lockers, larger walk-in containers, and smaller containment, which are all designed to provide secondary containment.

2.5.2.2 Sufficiently…