J-1800000-02.2 ISA_Spill_Prevention_and_Response_Plan.pdf

Commander, Navy Region Europe, Africa, Southwest Asia

Annex D to

COMNAVREGEURAFSWAINST

5090.4, Enclosure (3)

ISA Air Base Spill Prevention and Response Plan

Prepared by

NAVFAC Atlantic

April 2012

DRAFT

Table of Contents

Contents

REGULATORY CROSS REFERENCE

SECTION 1. INTRODUCTION

1.1 Applicable Regulations

1.2 Inventory of Storage, Handling and Transfer Sites

1.3 Significant Spill Potential

SECTION 2. RESPONSIBILITIES

2.1 On-Base Spill Response

2.2 Capability for Response to Off-Base Spills

SECTION 3. RELEASE PREVENTION

SECTION 4. SPILL NOTIFICATION AND RESPONSE

4.1 OHS Spill Notification

4.2 Incident Response and Emergency Services

4.3 Spill Response Actions

4.4 Spill Response Equipment and Materials

4.5 Medical Waste Release Response

4.6 Assessment of Worst Case Discharge Scenario

SECTION 5. RECORD KEEPING AND REPORTING

5.1 Record Keeping

5.2 Reporting

5.3 Incident Review

SECTION 6. TRAINING

6.1 FIC and FRT Training

6.2 Shop Environmental Coordinators and Personnel

6.3 Security

6.4 All Installation Personnel

ATTACHMENT 1: SPRP RECOMMENDATIONS

List of Tables

Table 1 Regulatory Cross Reference Table 2 Personnel Duties and Responsibilities Table 3 Release Prevention Methods Table 4 Spill Notifications

Table 5 Facility Response Team (FRT) Table 6 Response Actions

Table 7 Worst Case Scenario Locations Table 8 OHS Spill Event Reporting Decision Matrix Table 9 After Action Reporting

Annex D to COMNAVREGEURAFSWAINST 5090.4, Enclosure (3) Draft April 2012

List of Figures

Figure 1 Emergency Notification Procedures……………………………………….……7

Figure 2 Oil or Hazardous Substance Incident Checklist…………………………………8

Figure 3 Navy OHS Response Tiered Approach………………………………………..17

Figure 4 Spill Response and Cleanup Decision Tree……………….……………………33

Figure 5 Response Decision Process………………………………………...…………..35

Figure 6 Worst Case Discharge Support Area……………………….…………………. 36

Figure 7 Worst Case Discharge Temporary Fuel Farm………………………………….37

Appendices

Appendix A - Facility Data Sheets and Photo Log

Appendix B - Standard Operating Procedures

Appendix C - AST Inspection and Testing Checklists and Procedures

Appendix D - Emergency Call Down List

Appendix E - ICS Forms 201, 202, 204

Appendix F – Emergency Response Equipment

Appendix G - Spill Message Formats (Oil and Hazardous Substance Spills)

REGULATORY CROSS REFERENCE

This Spill Prevention and Response Plan (SPRP) is Annex D to

COMNAVREGEURAFSWAINST 5090.4, Enclosure (3), and contains all of the elements required by the Environmental Final Governing Standard (FGS) for United

States Forces in Bahrain (March 2012) and the Overseas Environmental Baseline

Guidance Document (OEBGD). Table 1 presents a cross-reference of the plan sections relative to applicable parts of the FGS.

Table 1 Regulatory Cross Reference

FGS Chapter 16 Requirement Description

ISA SPRP Section

Location

C16.3.2.1 Facility Incident Commander contact information and duties

2.1 On-Base Spill

Response

C16.3.2.2 General Information on the Installation SECTION 1.

INTRODUCTION

C16.3.2.2

Critical water resources, land uses, and possible migration pathways

4.2 Incident Response

and Emergency

Services

C16.3.2.3 and

C16.3.2.4

Inventory of storage, handling, and transfer sites that could produce significant spill

1.2 Inventory of

Storage, Handling and

Transfer Sites

C16.3.2.5

C16.3.2.6

Procedures for the periodic integrity testing of aboveground storage containers

SECTION 3.

RELEASE

PREVENTION

C16.3.2.7 Arrangements for emergency services 4.2 Incident Response and Emergency

Services

C16.3.2.8 Means to contact emergency services 4.2 Incident Response and Emergency

Services

C16.3.2.9 Description of prevention, control, and countermeasures

SECTION 3.

RELEASE

PREVENTION

C16.3.2.10 Measures to prevent spills SECTION 3.

RELEASE

PREVENTION

C16.3.2.11 List of emergency equipment 4.4 Spill Response

Equipment and

Materials

C16.3.2.12 Evacuation plan for each site listed in the Section 4.3 inventory

C16.3.2.13 List of deficiencies Attachment 1

C16.3.2.14 (1-3)

Written procedures for operations to preclude spills of POLs and hazardous substances; inspections; and record keeping requirements

Table 3, Appendix B and C

C16.3.2.15

Site-specific procedures should be maintained at each site on the facility where significant spills could occur

4.3 Spill Response

Actions

C16.3.3 Spill Control Section SECTION 4. SPILL

NOTIFICATION

AND RESPONSE

C16.3.3.1

Responsibilities, duties, procedures, and resources to be used to contain and clean up spills

SECTION 2.

RESPONSIBILITIES

SECTION 4. SPILL

NOTIFICATION

AND RESPONSE

C16.3.3.2 Immediate response when a spill is first discovered

Figure 1 Emergency

Notification

Procedures

C16.3.3.3

Responsibilities, composition, and training requirements of the FRT

4.2 Incident Response

and Emergency

Services

6.1 FIC and FRT

Training

C16.3.3.4 Command structure to manage a worst case discharge

4.2 Incident Response

and Emergency

Services

C16.3.3.5(1-2)

Procedures for FRT alert and response

4.2 Incident Response

Services

C16.3.3.6 Current roster 4.2 Incident Response and Emergency

Services

C16.3.3.7 Notification 4.1 OHS Spill

Notification

C16.3.3.8 Notification responsibilities 4.1 OHS Spill

Notification

C16.3.3.9 Surveillance procedures for early detection of POL and hazardous substance spills

SECTION 3.

RELEASE

PREVENTION

C16.3.3.10 Prioritized list of critical water and natural resources

4.2 Incident Response

Services

C16.3.3.11 Other resources available to the installation to cleanup or reclaim a large spill due to DoD activities

2.1 On-Base Spill

Response

C16.3.3.12 Cleanup methods 4.3 Spill Response

Actions

C16.3.3.13 Procedures for the proper reuse and disposal of recovered substances

4.3 Spill Response

Actions

C16.3.3.14 A description of general health, safety, and fire prevention precautions for spill cleanup actions

4.3 Spill Response

Actions

C16.3.3.15 Public affairs responsibilities 2.1 On-Base Spill

Response

C16.3.4 Reporting Section SECTION 5.

RECORD KEEPING

AND REPORTING

C16.3.4.1 Recordkeeping 5.1 Record Keeping

C16.3.4.2

C16.3.4.3(1-4)

C16.3.4.4

Significant spill reporting and notification 5.2 Reporting

C16.3.4.5 Notification of a significant spill outside of ISA Air Base

2.2 Capability for

Response to Off-Base

Spills

C16.3.5 Training and spill response drill requirements

SECTION 6.

TRAINING

C16.3.6 Spill residue and waste management SECTION 6.

TRAINING

Page Intentionally Blank

Figure 1 Emergency Notification Procedures In the event of an Oil or Hazardous Substance spill, begin response actions with number

1 below, and follow numbered blocks until incident completion.

Name, telephone number, and identification of caller;

Time and location of spill;

Identity and quantity of spill materials;

Origin and cause of spill;

Description of spill (behavior of spill, affected areas);

Anticipated movement of spill;

Planned or initiated actions;

Type of assistance required;

Stay in the area, if it is safe to do so, until Facility Response Team (FRT) arrives and direct them to the spill; and

Provide Material Safety Data Sheets as needed.

While timely, accurate reporting is essential to minimizing the impacts of an oil or hazardous substance incident; do not delay reporting while trying to gather all the information.

Make the call!!

Shutdown all appropriate manifold storage tank and truck valves and/or pumps.

Restrict all ignition sources and activate available spill control devices.

If a person has been splashed with a fuel or chemical, wash with water for at least 15 minutes, remove all contaminated clothing, and get medical attention by calling the Fire Chief. If a person has been over-exposed by inhalation, get the victim to fresh air.

Notify supervisor and people working nearby; and evacuate the immediate area to a safe distance upwind and upgrade from spill.

1. Anyone discovering/causing an oil or hazardous substance spill

CALL IMMEDIATELY:

a. All actual or suspected oil or hazardous substance spills onboard ISA Air

Base will be reported to the Command Duty Officer 3635-0923

b. In case of Spill or Fire: ISA Fire Chief 3634-9417

See other notifications in Section 4.1.

2. Provide as much of the following information as possible:

3. Person discovering the spill will conduct the following immediate first responder actions as appropriate; but only if properly trained and they can be done safely:

Figure 2 Oil or Hazardous Substance Incident Checklist

1. Date and Time of Incident: ______________________________________

2. Name of Caller: _________________ Return Phone__________________

Location of Spill: ______________ Type of Material: ________________

Quantity: ________________Cause, if known: _____________________

3. ISA Air Base Notifications: Command Duty Officer (3635-0923) _____

Army Tactical Operations Center (3961-4093) ___ Medical (DSN 741-1507 or 741-

1511)______ Fire Department (3634-9417) _____Others __________

4. Status of Response Actions: _____________________________________

FRT Dispatched? _______________ Source controlled_________________

Substance contained ___________ Injuries _________________________

5. Immediate Danger to Life or Health: YES ____ NO____

If YES, what _________________________________________________

6. Resources at risk? ____________________________________________

7. Facility Incident Commander :____________________________

8. Facility Response Team: FRT__________

9. Is additional assistance required? YES____ NO____

If yes, what type? ______________________________________________

Provider? _____________________ Who is taking action? _____________

10. Is spill significant and a reportable quantity? YES____ NO____

If yes: How determined? ______________________________________

Who is making reports?: __________________________________

11. Voice reports made to: NOSC (NSA Bahrain): __ COMM +973-17-85-4603 DSN

318-439-4603 COMM +973-3-946-3697 (cell)

Host Nation _________________ DOD EA __________ Other______________

12. Estimated Time of Completion: ___________ Completed: ____________

13. Method of waste disposal _______________________________________

14. Follow-on Reports Required: NOSC _____ CNI______ Host Nation ________

DOD EA ________Other _______________________________________

15. Comments:

Notes:

Incident Map

SECTION 1. INTRODUCTION

This document is the Spill Prevention and Response Plan (SPRP) for ISA Air Base

Bahrain. This plan will be implemented for US related spills or any type of release of a petroleum product, hazardous substance, or hazardous waste on board ISA Air Base or

US related spills off-camp involving non-weaponized, industrial grade chemicals used onboard or transported via adjacent railway or highway. Logistical support for ISA Air

Base is provided by the CNREURAFSWA Detachment Bahrain. NSA Bahrain

Environmental department is responsible for environmental oversight of petroleum, oils or lubricants (POL), hazardous substances, and hazardous waste at the ISA Air Base.

CNREURAFSWA Detachment Bahrain as Regional Environmental Coordinator and

Navy On-Scene Coordinator (NOSC) Program Manager provides oversight and management of an oil or hazardous substance (OHS) spill or release response and clean up at ISA Air Base. This plan is structured as follows:

Section 1 – Introduction – Provides an overview of the regulations applicable to

ISA Air Base and describes each area where the potential for a significant spill exists.

Section 2 – Responsibilities – Summarizes responsibilities of various ISA Air Base personnel for spill prevention and response.

Section 3 – Release Prevention –Describes prevention, control and countermeasures to minimize releases.

Section 4 – Spill Notification and Response – Describes notification and response actions to be followed during a spill, including responsibilities and clean-up methods. Describes a worst case spill event for ISA Air Base, and identifies an event requiring action from the CNREURAFSWA NOSC.

Section 5 – Reporting – Outlines the record keeping and reporting requirements for spill events.

Section 6 – Training – Provides training requirements for personnel involved in management of materials and wastes that may be harmful if released to the environment and for the Facility Response Team (FRT).

Definitions and acronyms are found throughout this document.

1.1 Applicable Regulations

Spill prevention and response at ISA Air Base are subject to the applicable overseas requirements described in OPNAV 5090.1C Navy Environmental Readiness Program

Manual, the Overseas Environmental Baseline Guidance Document (OEBGD), the

Environmental Final Governing Standard (FGS) for United States Forces in Bahrain, and applicable Bahrain Environmental Regulations. The primary guidance document is the

FGS. A cross reference matrix of the Bahrain FGS and OEBGD requirements and the

ISA Air Base SPRP is provided at the front of this document.

The key requirements of the FGS and OEBGD are as follows:

All DoD installations must prepare Spill Prevention and Response Plans (SPRP) to prevent and mitigate spills of hazardous substances and POL (refined petroleum, oils, and lubricants).

The plan must be reviewed and updated every five years or when there are significant changes to operations.

The plan must address areas with the potential for a significant spill. A significant spill means a release:

1. In excess of a reportable quantity listed in Table AP1.T4 of the OEBGD;

2. In excess of 400 liters (110 gallons) for POL, liquid or semi-liquid hazardous substances;

3. In excess of 225 Kg (500 pounds) of solid hazardous material, or

4. In excess of 340 Kg (750 pounds) of a mixture of POL, liquid, semi-liquid and solid hazardous substances.

A spill within secondary containment, on a non-porous surface or contained in a building is not considered a significant spill as long as it is not volatilized, did not enter a floor drain, and is cleaned up. Such a spill is classified as a contained release.

1.2 Inventory of Storage, Handling and Transfer Sites

The majority of hazardous materials onboard ISA Air Base are POL. POL and hazardous substances are stored and used at ISA Air Base by both DoD personnel and by on-site contractors. The transfer of fuel to US aircraft and other vehicles is performed by active duty US and Coalition forces. The DoD inventory of materials is discussed first followed by contractor owned inventory.

A temporary fuel farm comprised of eight 210,000 gallon fuel bladders lie within separate, plastic lined containment berms located in an isolated area in the Air Base.

These temporary fuel bladders contain JP-8 and are refilled by a fuel contractor as needed depending on usage. The fuel is transferred from the bladders to a tanker truck that supports the flight line operations. The temporary fuel bladder equipment is owned by the

Air Force and overseen by Air Force personnel but operated by Navy fuel personnel. It should be noted that the temporary fuel bladder facility will be transferred from the Air

Force to the Navy in the near future. A 500 gallon AST containing diesel fuel is used to fuel a power generator associated with the office trailer located adjacent to the temporary fuel bladder site.

Oil and lubricants are handled in containers up to 208 liters (55 gallons) at various shop locations. These materials are rarely used or transported in quantities over 250 gallons.

The Army 243 Battalion ADA operates an equipment maintenance shop where hazardous materials are stored in approved material storage units. A Hazardous Waste

Accumulation Point is maintained at this site where used POL, rags, aerosol cans, and used dry sweep are temporarily stored in 55 gallon drums, or smaller containers on containment pallets which provide secondary containment.

There is a potable water treatment facility onboard ISA Air Base. Water treatment chemicals containing chlorine in both liquid and powered form are stored in five gallon containers located at the water treatment plant.

Base operations support is provided by private contractors who own and operate ASTs, power generators and portable lighting units. The ASTs contain diesel fuel that supply power generators located throughout the Air Base. All generators are equipped with internal fuel tanks that function as day tanks. However, the majority of generators are fueled by external ASTs ranging in size from 250 gallons to 675 gallons. The generator draws fuel directly from the AST and the internal tank fuel valve is closed bypassing the day tank. Portable light stands are equipped with an internal 30 gallon fuel tank. There are eighteen contractor owned light stands and twelve government owned light stands.

The onsite contractor KBR operates a fuel farm consisting of three aboveground storage tanks. The capacity of each tank is 5,283 gallons (20,000 liters). Each tank contains diesel fuel. The primary use of the fuel is to power generators (AGGRECO brand) that provide the primary power to the base. Each 5,283 gallon AST is in a double walled tank.

The tanks are refilled as needed depending on usage by a fuel contractor who transfers the fuel from a tanker truck to the AST. KBR fills a tanker truck from these ASTs and delivers fuel to ASTs, generators and portable light stands located throughout the support area and flight line area. Fueling is done on an as needed basis which is typically on a daily basis.

The base support contractors also store hazardous materials in containers up to 55 gallons. Contractors are responsible for the storage of their own hazardous materials and management of hazardous wastes. There is a Hazardous Waste Accumulation Area where the contractor KBR stores wastes generated from their activities. Hazardous wastes are temporarily stored in 55 gallon drums, or smaller containers on containment pallets within a berm. A spill kit and posted spill response procedures and notifications are located at the accumulation area. Multiple drums can be stored within the accumulation area.

1.3 Significant Spill Potential

The locations of storage areas with a reasonable potential to have a significant spill are shown in Appendix A which lists the container identification numbers, contents and capacities for both Navy owned/operated, and contractor owned/operated tanks or sites.

Data sheets and photo log for each AST are also provided in Appendix A. The listed container capacity is the total quantity of POL or hazardous substance that might be spilled as a result of a major failure. All Navy POL containers have built in secondary containment, i.e. are double walled containers with the exception of the 500 gallon AST at the temporary fuel bladder site. Contractor owned ASTs also have secondary containment as noted in the tank data sheet (Appendix A). Due to security reasons this plan does not contain maps identifying the location of POL and hazardous substance storage, transportation or transfer areas.

Contractors are responsible for prevention, maintenance, spill response and clean up of spills or releases from contractor owned tanks, storage locations, equipment and activities. Contractors must follow all notifications and reporting procedures contained in this SPRP and comply with Navy procedures for spill cleanup and waste disposal. The

Navy will oversee all contractor activities related to spill response, cleanup and waste disposal.

Navy owned/operated area with potential for a significant fuel spill is the temporary fuel farm (temporary fuel bladder and 500 gallon AST). POL delivery/transfer areas and malfunctioning high level cut-off switches at generator day tanks have a reasonable potential to cause a significant spill. There is a reasonable potential of a leak from the flexible hose or tubing that carries fuel from ASTs to generators. This hose is either contained in metal open topped channels typically used for electrical cords or the hosing is run directly on top of the ground to the generator. The water treatment chemicals stored at the water treatment plant represent a potential source for a hazardous substance spill.

The hazardous waste accumulation point at the Army 243 Battalion ADA maintenance area does not represent a potential for significant spill. Quantities accumulated are limited to 55 gallons or less of POL related waste.

In order to reduce the potential for a significant spill from transfer operations and storage locations a number of prevention measures, described in Section 3, are employed.

SECTION 2. RESPONSIBILITIES

This section provides responsibilities for implementing the prevention and management aspects of the plan. Throughout this plan personnel involved in spill prevention are only referred to by title to facilitate plan update.

The Navy uses a three tiered approach for OHS response (see Figure 3). A Tier I spill is within the response capabilities of the activity, in this case ISA Air Base. Response to a

250 gallon spill and containment of an associated fire can be effectively achieved with current ISA Air Base capabilities (a Tier 1 response). The Commanding Officer, ISA Air

Base, is designated as the Facility Incident Commander (FIC).

Figure 3 Navy OHS Response Tiered Approach

Tier II and III spills exceed the response capabilities of the activity (i.e. ISA Air Base). A

Tier II or III OHS release at ISA Air Base is the responsibility of the installation

Commanding Officer, with back-up support from CNREURAFSWA as Navy On-Scene

Coordinator (NOSC). The Area Environmental Coordinator (AEC), named the Region

Detachment Bahrain Environmental Director as the Regional Environmental Coordinator, and NOSC Program Manager for OHS land based spill response for the Southwest Asia

AOR, including ISA Air Base, Bahrain. The NOSC is responsible for monitoring Tier I spill response effectiveness and coordinating Tier II/III level spill response support if required. The NOSC’s role is fully described in the Commander Navy Region Europe, Africa, Southwest Asia Navy On-Scene Coordinator (NOSC) Oil and Hazardous

Substance Response Plan (COMNAVREGEURAFSWAINST 5090.4) and includes:

Ensure timely, effective response and reporting to all applicable OHS pollution incidents within assigned AOR. Direct response operations when required.

Direct response efforts for Navy hazardous substance releases from Navy vessels or facilities that are beyond local capability.

Coordinate response operations with adjacent NOSCs, including Fleet NOSCs, for Navy OHS spills that may have an impact on more than one NOSC region.

Direct and coordinate response operations closely with ongoing fleet salvage operations.

Contact support activities as soon as practicable, when additional response support is required.

Ensure sufficient response resources are available, through organic and/or non-organic assets (e.g.; NAVFAC, FLSC, or Supervisor of Salvage).

2.1 On-Base Spill Response

Spill response for ISA Air Base is provided by military and contractor resources. Facility personnel and their responsibilities are summarized in Table 2. In the event a spill exceeds current ISA Air Base resources ISA Air Base staff may provide spill management support until the CNREURAFSWA Region Detachment Bahrain and NOSC

Program Manager can arrive on-scene to direct and manage US Navy spill response activities. The NSA Bahrain environmental office staff will provide long term spill response and clean up oversight.

In addition to local Navy response assets, commercial OHS pollution response assets may be the best means of meeting response requirements for spill scenarios beyond the capability of the local Navy assets. The CNREURAFSWA Detachment Bahrain NOSC

Representative ashore has the capability to engage a commercial OHS pollution response organization for spill response assistance within the pre-assigned AOR. Cleanup of Navy spills is funded by the organization responsible for the spill. The Navy spiller shall provide cost accounting data to the CNREURAFSWA Detachment Bahrain NOSC

Representative.

Table 2 Personnel Duties and Responsibilities

Position/Title Duties/Responsibilities

Commanding Officer The Commanding Officer is responsible for all spill prevention, control and countermeasures at

ISA Air Base. This includes ensuring that the plan is reviewed and updated as required and that adequate resources are available to enact this plan. The CO or his designee is the Facility Incident

Commander.

Facility Incident Commander

(FIC)/Alternate FIC

The Facility Incident Commander (FIC) coordinates and directs all spill control and countermeasure efforts. The FIC for ISA Air Base is the Commanding Officer. The Alternate FIC is the Fire Chief. Specific responsibilities include:

Activate all or part of the Facility Response Team as required.

Make notifications as necessary.

Coordinate required assistance from local response organizations and contractors.

Direct and coordinate all on-scene spill response actions during a major emergency.

Identify the type and amount of material released and obtain all equipment and personnel needed to control and clean-up the release.

Supervise containment, control, and clean-up actions including contractor clean-up operation.

Determine the adequacy of the clean-up effort.

Designate, train and maintain a Facility Response Team to clean up spills and to dispose of any recovered spill material according to applicable regulations and the ISA Air Base Hazardous

Waste Management Plan.

Public Works Officer The PWO has heavy construction equipment that is available for defensive spill response actions such as containing, securing or diverting the spill. Equipment is also available for cleaning up a spill, e.g. removing contaminated soil and putting it into barrels.

Fire Department Fire Department has equipment to provide fire suppression, spill containment for small spills, medical assistance. The Fire Department is the first responders to an OHS spill incident and will assume the role of FIC until relieved by the CO or his designee.

Position/Title Duties/Responsibilities

Command Duty Officer The CDO will take incoming calls or messages concerning a spill and relay information following established notification procedures through the Chain of Command including the Host Nation. The

CDO is authorized to act on behalf of the Commanding Officer.

Public Affairs Officer or

Command Liaison Officer

Coordinate all required notifications to local authorities and the news media. Public Affairs duties are provided by the Command Liaison Officer located at ISA Air Base.

Emergency Management Office

(EMO)

During a release, the EMO may perform the following functions in the event that the site is not under the control of the FIC. If the FIC is on the scene, these activities should be coordinated accordingly.

Evaluation and Site Control. Develop an initial assessment of the incident to include:

o Extent of damage.

o Injuries to personnel.

o Initial evacuation if necessary.

Identify evacuation zones and routes and coordinate the evacuation of all personnel from areas of potential exposure.

Secure gas and electricity rapidly to reduce potential for fire and explosion.

Secure ignition sources such as engines, electric motors, cigarettes, and open flames.

Control fires.

Prevent spill from spreading.

Conduct air monitoring.

Safety Office The Safety Office will assist the EMO where practicable.

Medical Officer of the Day Administer first aid to injured personnel.

For known substance(s), consult appropriate technical references and Material Safety Data Sheets

(MSDSs) for First Aid measures and symptoms of exposure.

Transfer injured to emergency medical attention.

Forward record of action to the FIC.

Shop Environmental

Coordinators

The Environmental Coordinators within each shop are responsible for ensuring that materials and waste are handled in a manner that minimizes the potential for release or chemical reactions. This includes verifying that the prevention measures described in Section 3 are employed.

Security Officer The Security Officer is responsible for ensuring that POL, hazardous materials/waste storage areas and facilities are checked during non-duty hours, including holidays, to assure that they are not being tampered with, subjected to unauthorized use, or display evidence of leaks, spillage, and chemical reactions (bulging containers unusual heat generation, etc. ) During a release, the Security

Officer is responsible for:

Initial notifications.

Isolating nonessential personnel from the area.

Establishing a secure perimeter at a safe distance from the affected area.

Diverting traffic and controlling access.

COMNAVREGEURAFSWA

Detachment Bahrain Navy On-

Scene Coordinator (NOSC)

Representative

The Navy official pre-designated to coordinate Navy OHS spill contingency planning and to direct

Navy OHS spill response efforts in a pre-assigned area. The NOSC also acts as the incident commander for OHS spills beyond the FICs AOR, and as incident commander for spills which exceed the response capability of the FIC.

Tenant Commands Tenant Commands, e.g. Army, Air Force and Marines will follow their own procedures for prevention and will follow the spill notification, response, and reporting procedures in this SPRP.

On-site Base Operation Support

Contractors

Responsible for spill prevention, spill response and clean up of spills or releases from contractor owned tanks, equipment or activities, e.g. fuel transfer operations. Must comply with Navy notification and reporting procedures and follow the Navy’s cleanup and waste disposal requirements.

2.2 Capability for Response to Off-Base Spills

If a significant spill from a US asset occurs outside ISA Air Base, the person in charge at the scene will immediately notify the Command Duty Officer, and will take appropriate action, if properly trained, to secure the source and contain the spill. The Command Duty

Officer shall follow the established notification procedures through the Chain of

Command including notifying the Host Nation. There is no contracted capability for response to off-base spills. Spills which occur outside the fence line that produce a hazardous vapor “cloud” or fumes would most likely require evacuation of a portion, or all of the Base. This would be dependent on the specific chemical, the amount released, dissipation factors, and prevailing weather conditions at the time of the release.

The probability of an exterior hazardous material spill that could impact Base operations and/or safety of personnel are extremely slight. It should be noted that a major spill outside the fence line has not occurred to date.

SECTION 3. RELEASE PREVENTION

This section provides general spill prevention measures for ISA Air Base. Table 3 identifies the release prevention measures that are employed to prevent spills at ISA Air

Base. Contractors are responsible for taking preventative actions (e.g. SOPs, training, inspections, maintenance, etc.) to reduce or eliminate spills or releases from contractor owned storage tanks, hazardous material storage areas, waste accumulation areas, oil containing equipment and operations such as fuel transfers.

Table 3 Release Prevention Methods

Release

Prevention

Method Description

Standard

Operating

Procedures

Standard Operating Procedures for Fuel Delivery Operations

(Appendix B)

Inspections

ASTs are visually inspected once every two months by the NSA

Bahrain Environmental Staff.

Temporary Fuel Bladders are visually inspected weekly and during fuel transfer operations.

Hazardous Waste Accumulation Areas are inspected weekly.

SOP for periodic inspection and testing of ASTs and associated valves, piping and appurtenances are found in Appendix C.

Training

All personnel receive on-the-job training for tasks dealing with hazardous substances, medical waste and POL. 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 6.

Security and

Lighting

ISA Air Base maintains a secure perimeter and is patrolled by security forces. Security patrols will detect spills beyond normal working hours. Lighting is adequate to detect spills beyond a containment structure.

Recordkeeping Recordkeeping requirements are discussed in Section 5.

Preventive

Maintenance

All oil-containing equipment is serviced regularly to ensure that it is available to support the mission of ISA Air Base. Generators are maintained by contractors who ensure they function properly.

Secondary

Containment

The three 5,283 gallon ASTs at the fuel farm are double walled tanks.

The temporary fuel bladders are in secondary containment (lined sand bern).

New AST installations should be of double wall construction, eliminating the need for open containment structures.

SECTION 4. SPILL NOTIFICATION AND RESPONSE

This section provides specific steps to take in the event of a release of oil and/or a hazardous substance, including hazardous material, hazardous waste, POL or medical waste.

4.1 OHS Spill Notification

Any person discovering an OHS release of any quantity, whether the source is known or not, shall immediately take appropriate actions to report and if properly trained to respond to the OHS release. All OHS spills shall be reported using the Emergency

Response Procedures identified in Figure 1 at the front of this plan. Initial notification will be made as follows. The person discovering the spill will report it to their immediate supervisor. The supervisor will contact the Command Duty Officer (CDO) or

Emergency Dispatch. The CDO or Emergency Dispatch will accept and relay initial spill reports and is responsible for contacting the Fire Department as first responder. The Fire

Department will follow their call down list or applicable checklists (see Appendix D).

Information provided during the initial reporting can be collected on Figure 2 at the front of this plan. The Spill Report Form found in Appendix E, can be used to collect additional information and relay situational awareness. Additional Incident Command

System forms to be used throughout the response are available on the CD provided with this plan.

The Commanding Officer, as the Facility Incident Commander (FIC), will determine if the Facility Response Team, discussed below, is activated. The FIC will determine if the additional notifications shown in Table 4 should be made. In addition to ISA Air Base reporting requirements, the CNREURAFSWA Region Detachment Bahrain NOSC representative shall be notified of all spills involving US assets.

Table 4 Spill Notifications

Title Phone Number

ISA Air Base Public Works 3925-2366

ISA Air Base USN Security 3947-3721

CNREURAFSWA ROC forward

(NSA Bahrain)

+973-1785-6586

COM: 1785-6585

CNREURAFSWA ROC +39-081-568-4551/2

DSN 314-626-1983/4/5

NSA Bahrain Environmental COMM +973-17 -85-4603

COMM +973-17-85-4197

DSN 318-439-4197

CNREURAFSWA Detachment

Bahrain NOSC

COMM +973-17-85-4603

DSN 318-439-4603

COMM +973-3-946-3697 cell

4.2 Incident Response and Emergency Services

The ISA Air Base FRT is composed of personnel from the various departments identified in Table 5. The FRT is under the command and responds to incidents as directed by the

FIC (ISA Air Base Commanding Officer or his designee). The FRT will provide coordinated response to control, contain and recover spilled materials from all spills of

OHS. The FRT will perform incident response actions only within the capabilities and training of the FRT, with particular regard to worker health and safety. The FRT will evaluate the situation and provide information to the FIC to make initial reports and recommendations for response actions and additional resources needed. For spills beyond the facility boundary or beyond the response capability of the FRT, the local

Bahrain Fire Department is contacted. If additional resources are required, the NOSC will activate a services contract for a contractor to respond to OHS contamination.

Table 5 Facility Response Team (FRT)

Position Responsibility Office Phone 24-hr. Number

Fire Department First

Responder

3634-9417

Public Works FRT Member 3925-2366 XXXXXX

Safety Officer FRT Member XXXXX XXXXXXX

Medical FRT Member DSN 741-1507 or

741-1511

XXXXXXX

NOSC (at NSA

Bahrain)

Navy On

Scene

Coordinator

COMM +973-17-

85-4603 DSN

318-439-4603

COMM +937-3-

946-3697

NSA Bahrain

Environmental

Staff

FRT Member COMM +973-17 -

85-4603

COMM +973-17-

85-4197

DSN 318-439-

+973-1785-4603

DSN 318-439-

There are no critical water resources, designated water protection areas or critical natural resources at ISA Air Base. Given the arid climate and small amount of annual rainfall

(less than 3 inches) in Bahrain, there are no fresh water surface water resources located on or adjacent to ISA Air Base. Additionally, there is no man made storm water drainage, collection or conveyance system. While infrequent, rainfall of one-two inches in a short period (e.g. 24 hours) can cause localized flooding from storm water runoff.

Should there be a spill during such a storm the POL will be transported via storm water beyond the immediate area of the release. Possible migration pathways and the prediction of direction and flow rate of a POL or hazardous substance release are TBD.

4.3 Spill Response Actions

In the event of a spill the incident must be reported promptly. Upon discovery or notification of an OHS spill, the CDO will refer to Figure 1, the Initial Emergency

Response Checklist, in Section 1 of this Plan. Site specific written spill response procedures are posted at significant spill sites owned by the base operations support contractors and at the temporary fuel bladder storage site. It is recommended that a copy of Figure 1 the Initial Emergency Response Checklist should be posted at all Navy sites with the potential for a significant spill. The CDO is authorized to act on behalf of the

Commanding Officer. The FIC will assess the situation and take immediate actions to protect people and property and avoid loss of life. Upon arrival at the site, the FIC will initiate actions to establish control of the area. The general response actions for a significant spill are provided in Table 6. A Spill Response Decision Tree that summarizes the spill response actions is provided in Figure 4. The FIC will direct and coordinate the following concurrent efforts of all emergency units. Response actions may vary at the discretion of the FIC based on the type of contaminant, the amount released and the location of the spill. Evacuation plans are posted in individual buildings.

Evacuation rally points for circumstances such as heavy weather or an OHS spill have been determined but are not included in this plan for security reasons.

Table 6 Response Actions

Response

Action

Response Steps

Establish

Command

Post and

Evaluate

Situation

Determine the type and amount of hazardous substances and/or POL released.

Determine the extent of the release and whether it has the potential to enter the environment outside of ISA Air

Base.

Determine equipment required to control and cleanup the release.

Determine health and safety precautions to be taken when handling the released substance.

Control Site Establish the work and safety zones within the Control Site and record the names of individuals entering the site.

Plan entrance and exits from the contaminated area and identify emergency evacuation routes.

Assure that only personnel with proper protective equipment and an assigned activity will enter the contaminated area.

Establish decontamination procedures.

Thoroughly brief personnel on health and safety requirements and operational procedures prior to each entry and debrief after decontamination.

Evacuation Provide air monitoring as required.

Determine whether evacuations are necessary in the event of a hazardous substance release.

If necessary, Security will notify all personnel to leave the immediate vicinity. Evacuation boundaries should exceed 500 feet around the incident site, but may be more depending upon the extent of the situation. See MSDS for substance spilled or released.

Security may designate a rally point at which evacuees should gather. Supervisors will account for all personnel.

Missing personnel will be reported to the FIC immediately. Every attempt will be made to locate missing personnel.

However, extreme care must be exercised to minimize risks to the security staff or other personnel involved in the search effort.

The FIC assumes responsibility for all people inside the perimeter of the evacuation boundary. No person shall remain in or reenter the evacuated area unless specifically authorized by the FIC.

Spill Control and

Containment

Take actions to control the source of a spill and prevent the spread of hazardous substances. Immediate hazards, such as those caused by fire, explosion, or toxic gas release will be controlled, to the extent possible, by the FRT.

If required, coordinate with the Bahrain Fire Dept. to provide additional personnel trained in the use of spill control equipment and procedures.

Response

Action

Response Steps

Take appropriate action to stop the source of the spill, including:

Closing valves

Plugging leaks

Up-righting containers

Emptying leaking containers into non leaking containers, or overpacking leaking container

Confine the spill as close to the source as possible. Prevent spill runoff from entering the groundwater or from exiting Base property. Based on the storage and use of hazardous substances and past experiences, all spills should be contained through a combination of dike/berm and/or absorption.

Transport appropriate equipment to the spill site. If Base resources are insufficient, or if property and/or resources outside the Base are threatened, the local fire department will be called. In the meantime, preliminary containment actions must be taken to minimize the impact and spread of the spill.

Cleanup and disposal

The FRT or a spill contractor under Navy supervision is responsible for spill cleanup. Cleanup methods depend on the characteristics of the spilled material, size and location of the spill, character of the area and potential impacts.

Standard cleanup methods may include, but are not limited to: Absorption, On-site neutralization, Dilution, Evacuation, Dredging / Pumping, Suction.

Clean up efforts must meet regulatory requirements, prevent public health hazards and further contamination, and restore environmental quality of the affected area.

Clean up efforts may require collection of soil or water samples to determine the degree of contamination.

Sampling may also be required following clean-up efforts to determine whether any residual contaminant remains.

Properly containerize, store, manifest and dispose of contaminated cleanup material and wastes.

Ensure that cleanup materials that are incompatible with other wastes are segregated during temporary storage, and that incompatible wastes are not accidentally mixed during clean up operations.

Insure that all reusable protective clothing and equipment has been thoroughly decontaminated before being returned to the proper storage location.

Additional remedial actions will be governed by DoD Instruction 4715.8, “Environmental Remediation for DoD

Activities Overseas.”

Figure 4 Spill Response and Cleanup Decision Tree

4.4 Spill Response Equipment and Materials

Spill kits are available at fueling facilities, hazardous material storage sites, and hazardous waste accumulation areas. All fuel delivery trucks are required to be equipped with spill response kits.

The fire department has sorbent material and the capability to put into place temporary dikes, trenches, berms or dams for spill containment and control. The PWO has access to heavy equipment (trucks, front-end loader, backhoe) that may be available for spill containment and control. In the event of a spill that can’t be handled by ISA resources alone additional spill response equipment located at NSA Bahrain and available through the spill response contractor will be utilized. A listing of the spill response equipment and materials located at NSA Bahrain are found in Appendix F.

4.5 Medical Waste Release Response

Personnel who handle medical waste are trained to respond to typical releases of medical waste. In the event of a large release, a release of medical waste mixed with other wastes or a release whose source is unknown (all of which are highly unlikely at ISA Air Base), the notification of the FIC and use of the FRT described in Section 4 are used.

4.6 Assessment of Worst Case Discharge Scenario

A worst case discharge will exceed the capabilities of ISA Air Base and require the assistance of the Region Detachment Bahrain NOSC. The overall spill response process and how the NOSC integrates with or overlaps the on-scene ISA Air Base response is shown in Figure 5 Response Decision Process. Response to a worst case discharge is described in section 4.2 and 4.3. Under the response agreements in place, the Bahrain

Fire Department and possibly other Bahraini agencies would be mobilized to assist with the initial response action. The CNREURAFSWA Detachment Bahrain NOSC organization would mobilize and activate the oil spill removal organization under contract.

Figure 5 Response Decision Process

The “worst-case discharge,” at ISA Air Base is shown in Table 7 and discussed below.

Table 7 Worst Case Scenario Locations

Source Containment Drainage

Support area -- Three

5,328gallon ASTs, for generator fuel supply and as a product dispenser.

Double walled tank. Drainage from the secondary containment area is directly onto the surrounding ground.

Flight Line area --- Eight

210,000 gallon Fuel

Bladders in the temporary fuel farm.

Fuel bladders lie within separate, plastic lined sand containment berms.

Drainage from the bermed containment area is directly onto the surrounding ground.

Any precipitation that might collect within the containment area is removed by tank truck as needed.

Within the support area the largest ASTs are three 5,328 gallon double walled tanks. The worst case discharge scenario would be the catastrophic failure of a single 5,328 gallon tank (see

Figure 6). The release would flow into the secondary containment but if it escaped the secondary containment the fuel would flow into the surrounding unpaved area. The only potentially sensitive receptor in this area is the groundwater. There is no immediate threat to surface or drinking water. Air monitoring should also be conducted to protect personnel from noxious fumes.

Figure 6 Worst Case Discharge Support Area

Will add pictures of the 20,000 liter ASTs after they are cleared by ISA Air Base security.

Within the flight line area there is a temporary fuel storage area consisting of eight 210,000 gallon fuel bladders. Each bladder is within a separate, plastic lined containment berm (see

Figure 7). Visual inspections occur before and after every fuel transfer, in addition to a weekly visual site inspection of the entire fuel farm. The fuel transfer system is inspected before and after each fuel transfer. Fuel transfer operators carry a remote automatic shutdown device. Fuel bladder repair kits are located at the site. The worst case scenario would be the catastrophic failure of a single 210,000 gallon bladder. The release would flow into the lined bermed containment area but if it escaped the containment area the fuel would flow into the surrounding area or soil. The only potentially sensitive receptor in this area is the groundwater. There is no immediate threat to surface or drinking water.

Figure 7 Worst Case Discharge Temporary Fuel Farm

Piping used for fuel transfer. Fuel bladders lie within containment areas.

SECTION 5. RECORD KEEPING AND REPORTING

This section contains reporting and record keeping requirements for this Spill Prevention and

Response Plan. It also contains the procedures for review of spill events.

5.1 Record Keeping

Records for this plan are maintained in the NSA Bahrain Environmental Office in accordance with the Environmental Management System record keeping procedures. The records and the amount of time the records must be maintained include:

Inspection checklists (3 years)

Training records (3 years)

Documentation of periodic review and amendment of the plan (perpetual)

Spill reports and incident evaluations (10 years)

5.2 Reporting

Immediate reporting requirements are addressed in Section 4.1. This section discusses the reporting requirements following discovery and initial assessment of the release.

OPNAVINST 5090.1C requires all Navy activities to report all OHS spills regardless of amount to their Chain of Command and the NOSC by voice immediately. All releases of POL or

Hazardous Substance regardless of size and quantity shall be reported by the message format delineated in Appendix G. An update by SITREP message is required when any new information

(or information different than previously reported) is discovered. Note that the definition of a release does not include spilling or leaking that result in exposure to persons solely within a work place.

A spill or release of oil or hazardous substance triggers different reporting requirements depending on the type of material, the severity of the release, its location and other factors specific to each incident. Table 8 specifies reporting requirements.

Once the incident is completed submit the appropriate message traffic to terminate the incident.

In addition submit the after action reports shown in Table 9. Reporting will follow the report form contained in Appendix G to CNREURAFSWA Detachment Bahrain NOSC Plan.

5.3 Incident Review

Following a spill incident requiring implementation of the plan, the FIC shall conduct a debriefing with the FRT technical staff and any Command Post Advisors to review all internal reports and evaluate the effectiveness of the spill response procedures. The FIC shall identify any needed improvements to the response team, the need for additional training and/or equipment for more efficient response. Additionally, the following actions will be taken to determine the cause of the release and prevent similar releases in the future:

Interviews with the person(s) involved in the incident, any witnesses, the person in charge of the process/equipment involved and shop personnel to understand the event, its cause and how the initial response was handled.

Discussions with others involved with similar processes/equipment to identify possible changes to prevent a similar incident and to relay lessons learned from the event.

Following this debriefing, the FIC shall complete a Hazardous Material Incident Evaluation.

This will be kept in…