5. J-0200000-06_NASCC_SPCC_Plan.pdf

SPILL PREVENTION, CONTROL,

AND COUNTERMEASURE (SPCC) PLAN

NAVAL AIR STATION CORPUS CHRISTI

Corpus Christi, Texas

Under Contract to:

Naval Facilities Engineering Systems Command Southeast Region Headquarters

PO Box 30, Bldg. 135 North, Ajax Street NAS Jacksonville, FL 32212

Navy Contract

N69450-14-D-0029

September 2021

Prepared by:

https://www.google.com/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&cad=rja&uact=8&ved=2ahUKEwj02tfa4d3dAhXlzIMKHQhUDtEQjRx6BAgBEAU&url=https://www.facebook.com/NASCorpusChristi/&psig=AOvVaw3q4NctlY-kiu_BG_Ao5bN6&ust=1538226268842565

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

Plan Administration ........................................................................................................................ 1-1 Executive Summary ............................................................................................................ 1-1 Cross-Reference with SPCC Provisions............................................................................... 1-2 Management Approval ...................................................................................................... 1-5 Professional Engineer Certification .................................................................................... 1-7 Location of SPCC Plan ......................................................................................................... 1-9 Designated Person ........................................................................................................... 1-10 Amendments of SPCC Plans ............................................................................................. 1-10

1.7.1 Five Year Plan Reviews ......................................................................................... 1-10

1.7.2 Facility Change Amendments............................................................................... 1-10

1.7.3 Spill Reports & EPA Directed Amendments ......................................................... 1-11

General Facility Information ............................................................................................................ 2-1 Facility Description ............................................................................................................. 2-1 Oil Storage Containers ....................................................................................................... 2-2

2.2.1 High-Risk Oil Storage Facilities ............................................................................... 2-4

2.2.2 Ancillary Aboveground Storage Tanks ................................................................. 2-13

2.2.3 Mobile Refueler Trucks and Portable Containers ................................................ 2-13

2.2.4 Used Cooking Oil Containers ................................................................................ 2-14

2.2.5 Drum Storage Areas ............................................................................................. 2-14

2.2.6 Facility Piping ....................................................................................................... 2-15

2.2.7 Underground Storage Tanks ................................................................................ 2-15

2.2.8 Oil-Filled Operational Equipment ........................................................................ 2-16

2.2.9 Oil/Water Separators ........................................................................................... 2-17

2.2.10 Out of Service or Permanently Closed Containers............................................... 2-18

Conformance and Environmental Equivalence ................................................................................. 3-1 Conformance with Requirements ...................................................................................... 3-1 Environmental Equivalence ............................................................................................... 3-1 Facilities or Equipment Not Yet Fully Operational ............................................................. 3-1

Predicted Spills as Result of Equipment Failure ................................................................................ 4-1 Discharge Notification and Response Procedures ............................................................. 4-1 Predicted Spill Scenarios .................................................................................................... 4-2

4.2.1 High-Risk Oil Storage Facilities ............................................................................... 4-3

4.2.2 Other Ancillary Tanks ............................................................................................. 4-5

4.2.3 Mobile Refueler Equipment ................................................................................... 4-5

4.2.4 Drum Storage Areas ............................................................................................... 4-6

4.2.5 Oil-Filled Operational Equipment .......................................................................... 4-7

4.2.6 Other Ancillary Piping ............................................................................................ 4-7

Discharge or Drainage Controls ......................................................................................... 4-9 Disposal of Recovered Materials ..................................................................................... 4-10

Secondary Containment .................................................................................................................. 5-1

SPCC PLAN – NAS CORPUS CHRISTI

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Requirements ..................................................................................................................... 5-1 Secondary Containment for Stationary Bulk Storage Tanks .............................................. 5-2

5.2.1 Freeboard for Precipitation .................................................................................... 5-2

5.2.2 Sufficiently Impervious ........................................................................................... 5-2

5.2.3 Field Erected Tanks ................................................................................................ 5-3

5.2.4 Shop-Fabricated Ancillary Tanks ............................................................................ 5-3

Secondary Containment for Mobile and Portable Containers .......................................... 5-6

5.3.1 Portable Containers ............................................................................................... 5-6

5.3.2 Mobile Refueler Equipment ................................................................................... 5-7

Secondary Containment for Loading and Unloading Racks ............................................... 5-9

5.4.1 Industry Standard Consideration ........................................................................... 5-9

Secondary Containment for Fuel Transfer Areas ............................................................... 5-9 Secondary Containment for Piping .................................................................................. 5-11 Oil-Filled Operational Equipment .................................................................................... 5-12 Impracticability of Secondary Containment .................................................................... 5-14

Inspections and Testing ................................................................................................................... 6-1 Inspection Schedule and Recordkeeping ........................................................................... 6-1 Stationary Bulk Storage Tank Inspections .......................................................................... 6-5

6.2.1 Field Erected Tanks ................................................................................................ 6-5

6.2.2 Shop-Fabricated Tanks ........................................................................................... 6-5

6.2.3 Industry Standard Considerations........................................................................ 6-10

Mobile and Portable Container Inspections .................................................................... 6-11 Liquid Level Sensing Device Inspections .......................................................................... 6-12

6.4.1 Field Erected Tanks .............................................................................................. 6-12

6.4.2 Shop-Fabricated Tanks ......................................................................................... 6-12

6.4.3 Mobile Refueler Trucks ........................................................................................ 6-13

6.4.4 Industry Standard Considerations........................................................................ 6-13

Aboveground Piping Inspections ..................................................................................... 6-14 Containment Dike Inspections ......................................................................................... 6-15 Underground Storage Tank Inspections .......................................................................... 6-16 Underground Piping Inspections ...................................................................................... 6-16 Oil Water Separator Inspections ...................................................................................... 6-17

OFOE Inspections ............................................................................................................. 6-17

Oil-Handling Personnel Training ...................................................................................................... 7-1 Initial SPCC Training ........................................................................................................... 7-1 Annual Discharge Prevention Briefings .............................................................................. 7-2 State UST Operator Training .............................................................................................. 7-2

Security ........................................................................................................................................... 8-1 Site Access and Fencing ..................................................................................................... 8-1 Master Flow and Drain Valves ........................................................................................... 8-1 Starter Controls .................................................................................................................. 8-2 Pipeline Loading and Unloading Connections.................................................................... 8-2 Lighting ............................................................................................................................... 8-2

Procedures for Fuel Transfers .......................................................................................................... 9-1

CONTENTS

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Loading/Unloading of Military Refuelers & Commercial Fuel Delivery Trucks ................. 9-1 General Transfer Procedures ............................................................................................. 9-2 Refueler Trucks to Ancillary Tanks ..................................................................................... 9-4 Hand Pour Oil into Tank or Container ................................................................................ 9-5 Vacuum Oil from Tank or Container .................................................................................. 9-5 Dispenser Hose Fueling to Motor Vehicles or Boats.......................................................... 9-6 Refueler Trucks to and from Aircraft ................................................................................. 9-7

Brittle Fracture Evaluation ............................................................................................................. 10-1

Conformance with State and Local Applicable Requirements ......................................................... 11-1 State Regulatory Standards .............................................................................................. 11-1 Other Relevant Standards .............................................................................................. 11-23

Other SPCC Requirements ............................................................................................................. 12-1 Container Construction .................................................................................................... 12-1 Corrosion Protection for Buried, Partially Buried and Bunkered Storage Tanks ............. 12-1 Corrosion Protection for Buried Piping ............................................................................ 12-2 Heating Coils..................................................................................................................... 12-2 Overfill Prevention ........................................................................................................... 12-2 Effluent Treatment Facility .............................................................................................. 12-4 Terminal Connections ...................................................................................................... 12-4 Pipe Supports ................................................................................................................... 12-4 Vehicle Warning ............................................................................................................... 12-5

Facility Drainage: Design and Equipment ........................................................................ 12-5

Appendices

A Tank Data Sheets AB Equipment Photos B Facility Diagrams C Inspection Forms and Checklists D Record of Initial Training and Annual Discharge Prevention Briefings E Record of SPCC Plan Five Year Reviews and Amendments F Assumptions and Calculations

Tables

1-1 Regulatory Cross-Reference Matrix 1-2 List of SPCC Plan Recipients

2-1 Summary of Oil Storage Containers & Capacities 2-2 Oil Water Separators 2-3 Container Inventory and Summary of Conditions 2-4 Oil-Filled Operational Equipment

3-1 List of Tank Deficiencies

5-1 Secondary Containment of Single-Walled Tanks 5-2 Secondary Containment for Mobile and Portable Containers vi SEPTEMBER 2021

5-3 Secondary Containment for High-Risk Loading / Unloading Racks & Fuel Transfer Areas

6-1 Inspection Schedule 6-2 Tank Category and Inspection Requirements 6-3 STI SP001 Periodic Testing Requirements

11-1 Relevant Military & Industrial Standards

Figures

2-1 Location Map 2-2 Aviation Fuel Facility 2-3 GOV Gas Station 2-4 NEX Gas Station 2-5 CCAD Fuel Farm

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Acronyms and Abbreviations API American Petroleum Institute ASME American Society of Mechanical Engineers AST Aboveground Storage Tank ATG Automatic Tank Gauging

BUMED Bureau of Medicine

CBP Customs and Border Patrol CCAD Corpus Christi Army Depot CDO Command Duty Officer CFR Code of Federal Regulations CNATRA Chief of Naval Air Training CNIC Commander of Naval Installations Command CP Cathodic Protection CRDM Continuous Release Detection Method

DCRF Dynamic Component Repair Facility DHS Department of Homeland Security DLA Defense Logistics Agency DOT Department of Transportation DRMO Defense Reutilization and Marketing Office DSA Drum Storage Area

ELMR Enterprise Land Mobile Radio EPA Environmental Protection Agency

FRP Facility Response Plan ft Feet gal/ft3 Gallons Per Cubic Feet GOV Government Operated Vehicle gpm Gallons per Minute GRI Guidance for Regional Inspectors (EPA) GSE Ground Support Equipment

HQ Headquarters HW Hazardous Waste

ID Identification

KVA Kilovolt Ampere

ME Mobile Equipment MWR Morale, Welfare, and Recreation

N/A Not Applicable NAPL Non-Aqueous Phase Liquid NAS Naval Air Station NATOPS Naval Air Training and Operating Procedures Standardization NAVAIR Naval Air Systems Command viii SEPTEMBER 2021

NAVFAC-SE Naval Facilities Engineering Systems Command – Southeast NEC Nueces Electric Cooperative NEX Navy Exchange NFPA National Fire Protection Association NRC National Response Center

OFOE Oil-Filled Operational Equipment OLF Out-Lying Field OPNAV M Navy Operations Manual OPV Overfill Prevention Valve OS Out of Service OWS Oil Water Separator

PAR Precision Approach Radar PE Professional Engineer PEI Petroleum Equipment Institute PIV Post Indicator Valve POL Petroleum, Oil, and Lubricant PWD Public Works Department

SAA Satellite Accumulation Area SOP Standard Operating Procedure SPCC Spill Prevention, Control, and Countermeasure STI Steel Tank Institute

TAC Texas Administrative Code TACAN Tactical Air Navigation System TCEQ Texas Commission on Environmental Quality TRDI Training, Rehabilitation, and Development Institute TWC Texas Water Code

UCO Used Cooking Oil UFC Unified Facilities Criteria UL Underwriters Laboratories U.S. United States UST Underground Storage Tank UT Ultrasonic Testing

WWTP Wastewater Treatment Plant

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SECTION 1

Plan Administration

Executive Summary Title 40 in Code of Federal Regulations (CFR) section 112.1(d)(2)(ii), requires a Spill Prevention Control and Countermeasure (SPCC) plan to be written and maintained if the facility has greater than 1,320 gallons of total aboveground fuel/oil storage capacity. This includes all fixed position tanks, integral generator tanks, mobile refueler trucks, cooking oil tanks, portable containers, drums, and Oil-Filled Operational Equipment (OFOE), such as transformers and hydraulic elevator tanks, with at least a 55-gallon capacity. Naval Air Station (NAS) Corpus Christi exceeds the 40 CFR 112 threshold capacity as detailed in Table 2-3, and so is required to maintain a SPCC plan.

The purpose of this SPCC plan is to identify all tanks, containments, procedures, methods and equipment used at NAS Corpus Christi, to prevent the discharge of oil into the environment. This plan is applicable to all facilities and tenant organizations located at NAS Corpus Christi that store or handle new or used fuel or oil products in aboveground tanks and equipment. NAS Corpus Christi previously maintained an SPCC Plan in accordance with these regulations. This revised plan is a technical update to address facility oil storage changes during the past five years and to maintain compliance with 40 CFR 112 regulations.

Naval Facilities Engineering Systems Command – Southeast (NAVFAC-SE) Region provided oversight and technical assistance with the preparation of this document through NAVFAC-SE Contract N69450-14-D- 0029, Task Order 17F0163. Jacobs Engineering Group (formerly CH2M) performed evaluations at NAS Corpus Christi in July 2018 and collected available information and data for inclusion in the SPCC Plan.

This included the visual evaluation of all aboveground storage tanks (AST), visible portions of underground storage tanks (UST), and connected fuel piping. In addition to container inspections, oil water separators (OWS), refueler truck parking and transfer locations, drum storage areas (DSA), other mobile/portable oil tanks and inspection procedures were evaluated for effectiveness and industry best management practices.

NAS Corpus Christi manages three Out-Lying Fields (OLF) named Cabaniss, Goliad, and Waldron, which are used for aircraft training operations. These are non-contiguous, Navy owned properties, which do not exceed the 40 CFR 112 threshold capacity for oil storage, so they are not required to have a SPCC plan. NAVFAC-SE previously prepared a non-regulated, short format, SPCC plan for each OLF site separately, as a good management practice to document the generator fuel tanks located there. The OLF sites tank inventory data is not included in this SPCC plan update.

NAS Corpus Christi has an inspection program for oil storage tanks and fuel transfer areas. If needed, deficiencies are noted, and funding is requested for correction. NAS Corpus Christi, with assistance from NAVFAC-SE, has a program for improving regulatory compliance through tank repairs or replacements and equipment upgrades to meet industry standards. NAS Corpus Christi maintains a Facility Response Plan (FRP) to address discharges of oil per 40 CFR 112.20, and discharge of hazardous substances in accordance with Navy Operations Manual (OPNAV M-) 5090.1, Chapter 39.

The Environmental office ensures NAS Corpus Christi meets federal, State of Texas Administrative Code (TAC), and local regulations. Appropriate personnel have been designated and trained for spill prevention and response, and written procedures guide personnel who perform inspections and

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monitor regulated activities. Due to periodic changes occurring at NAS Corpus Christi, it is important to continue the practices of training and monthly inspections for spill prevention as equipment degrades and personnel rotate through the facility.

NAS Corpus Christi is presently in substantial conformance with SPCC requirements. However, there are a few existing conditions that should be addressed in order to ensure full compliance with 40 CFR 112.

Refer to Table 3-1, for a list of regulatory deficiencies and best engineering practice recommendations.

The NAS Corpus Christi, Public Works Department (PWD), Environmental office (Building 19), maintains a current file or database of SPCC inspection reports and corrective action status.

The Environmental Protection Agency (EPA) definition of “Facility” is subject to interpretation, but it usually includes all buildings, structures, or properties, which are contiguously located, and owned or operated by the same organization (such as a Navy base). Corpus Christi Army Depot (CCAD), Defense Logistics Agency (DLA), and Department of Homeland Security (DHS) Customs and Border Patrol (CBP) are tenant commands that operate oil containing tanks and equipment located on Navy-owned properties at NAS Corpus Christi. Each tenant organization and contractor is responsible for their own environmental compliance, equipment management, training, and recordkeeping, in regard to oil storage and transfer operations. Although some equipment may be owned by non-Navy tenant organizations, this SPCC plan is intended to document a full inventory of all oil containing tanks and equipment at NAS Corpus Christi.

Cross-Reference with SPCC Provisions “112.7: If you do not follow the sequence specified in this section for the Plan, you must prepare an equivalent Plan acceptable to the Regional Administrator that meets all of the applicable requirements listed in this part, and you must supplement it with a section cross-referencing the location of requirements listed in this part and the equivalent requirements in the other prevention plan.”

TABLE 1-1

Regulatory Cross-Reference Matrix

Regulation Citation

(40 CFR 112)

Regulatory Requirement Description SPCC Plan

Section

112.3(d) Professional Engineer (PE) Certification Section 1.4

112.3(e)(1) Location of SPCC Plan Section 1.5

112.4 Amendments by Regional Administrator Section 1.7

112.5(a) Amendments Section 1.7, Appendix E

112.5(b) SPCC Plan Review Section 1.7

112.7 Management Approval Section 1.3

112.7 Facilities or Equipment Not Yet Fully Operational Section 3.3

112.7(a)(1) Conformance with Requirements Section 3.1

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TABLE 1-1

Regulatory Cross-Reference Matrix

Regulation Citation

(40 CFR 112)

Regulatory Requirement Description SPCC Plan

Section

112.7(a)(2) Environmental Equivalence Section 3.2

112.7(a)(3) Facility Description Section 2.1, Appendix B

112.7(a)(3)(i) Oil Storage Containers Section 2.2

112.7(a)(3)(ii) Discharge Prevention Measures Section 9, Appendix A

112.7(a)(3)(iii) Discharge or Drainage Controls Section 4.3

112.7(a)(3)(iv) Discharge Discovery Countermeasures Section 4.1

112.7(a)(3)(v) Disposal of Recovered Materials Section 4.4, FRP

112.7(a)(3)(vi) Contact List Section 4.1, FRP

112.7(a)(4) Discharge Notification Section 4.1, FRP

112.7(a)(5) Discharge Response Procedures Section 4.1, FRP

112.7(b) Predicted Spill Scenarios Section 4.2, Appendix F

112.7(c) Secondary Containment Requirements Section 5.1

112.7(d) Impracticability of Secondary Containment Section 5.8

112.7(e) Inspections Schedule and Recordkeeping Section 6.1

112.7(f)(1) Initial SPCC Training Section 7.1, 7.2

112.7(f)(2) Designated Person Section 1.6

112.7(f)(3) Discharge Prevention Briefings Section 7.2

112.7(g) Security Section 8

112.7(h)(1-3) Transfer Procedures for Loading and Unloading Racks Section 9.1

112.7(i) Brittle Fracture Evaluation Section 10

112.7(j) Conformance with Applicable State and Local Requirements Section 11

112.7(k) Oil-Filled Operational Equipment (OFOE) Section 5.7

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TABLE 1-1

Regulatory Cross-Reference Matrix

Regulation Citation

(40 CFR 112)

Regulatory Requirement Description SPCC Plan

Section

112.8(b)(1-2) Containment Dike Inspections Section 6.6

112.8(b)(3-4) Facility Drainage: Design and Equipment Section 12.10

112.8(b)(5) Facility Drainage: Pump Transfer Section 12.10

112.8(c)(1) Container Construction Section 12.1

112.8(c)(2) Secondary Containment for Stationary Bulk Storage Tanks Section 5.2

112.8(c)(3)(i-

iv) Containment Dike Inspections Section 6.6

112.8(c)(4 - 5) Corrosion Protection for Buried, Partially Buried, and Bunkered Storage Tanks Section 12.2

112.8(c)(6) Stationary Bulk Storage Tank Inspections Section 6.2, 6.3

Mobile and Portable Container Inspections Section 6.3

112.8(c)(7) Heating Coils Section 12.4

112.8(c)(8)(i-v) Liquid Level Sensing Device, Overfill Prevention Section 6.4, 12.5

112.8(c)(9) Effluent Treatment Facilities Section 12.6

112.8(c)(10) Correct Visible Discharges Section 4.3

112.8(c)(11) Secondary Containment for Mobile or Portable Containers Section 5.3

112.8(d)(1) Corrosion Protection for Buried Piping Section 12.3

112.8(d)(2) Terminal Connections Section 12.7

112.8(d)(3) Pipe Supports Section 12.8

112.8(d)(4) Aboveground Piping Inspections Section 6.5

112.8(d)(5) Vehicle Warning Section 12.9

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Management Approval “112.7: The Plan must have the full approval of management at a level of authority to commit the necessary resources to fully implement the Plan.”

This SPCC Plan has the full approval of management at NAS Corpus Christi, at a level of authority to commit the necessary resources for full implementation of the Plan. Management will use personnel, equipment, and materials necessary to prevent and control spills, and to implement SPCC requirements set forth in this Plan. By virtue of my office, I have authority to approve this document on behalf of the facility, and to commit resources to implement the corrective actions and improvements needed, to comply with applicable federal and state laws.

The implementation of and compliance with this SPCC Plan are subject to the provisions of the Anti- Deficiency Act, as amended, 31 United States Code section 1341 et seq, and requisite regulations that control funding of operations and activities. Nothing in this plan is intended to make or authorize an expenditure or obligation, exceeding an amount or purpose available in a U.S. Government appropriation or fund, for an expenditure or obligation in violation of the Anti-Deficiency Act. Further, this plan is not intended to involve the U.S. Government in a contract or obligation for payment or any other expense, before an appropriation is adopted, unless otherwise authorized by law.

CAPT Christopher Jason Date Signed Commanding Officer, NAS Corpus Christi

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Designated Person “112.7(f)(2): Designate a person at each applicable facility who is accountable for discharge prevention and who reports to facility management.”

The PWD Environmental Director, located in Building 19, telephone (361) 961-5353, is the primary Designated Person, described in 40 CFR 112.7(f)(2), who reports to NAS Corpus Christi management and is accountable for discharge prevention.

The first backup designated person is the Environmental SPCC/Tank Manager, telephone (361) 961- 5355.

The second backup person to call, in case of a spill emergency, is the 24-hour Command Duty Officer (CDO), telephone (361) 534-9093.

Amendments of SPCC Plans

1.7.1 Five Year Plan Reviews

“112.5(b): Notwithstanding compliance with paragraph (a) of this section, complete a review and evaluation of the SPCC Plan at least once every five years from the date your facility becomes subject to this part; or, if your facility was in operation on or before August 16, 2002, five years from the date your last review was required under this part. As a result of this review and evaluation, you must amend your SPCC Plan within six months of the review to include more effective prevention and control technology if the technology has been field-proven at the time of the review and will significantly reduce the likelihood of a discharge as described in §112.1(b) from the facility. You must implement any amendment as soon as possible, but not later than six months following preparation of any amendment. You must document your completion of the review and evaluation, and must sign a statement as to whether you will amend the Plan, either at the beginning or end of the Plan or in a log or an appendix to the Plan. The following words will suffice, “I have completed review and evaluation of the SPCC Plan for (name of facility) on (date), and will (will not) amend the Plan as a result.”

The Designated Person identified in Section 1.6 is responsible for initiating and coordinating the SPCC Plan reviews. The Facility Owner/Operator, Designated SPCC person, NAVFAC-SE region, or authorized contractor firm, must complete a review of the SPCC plan and on-site evaluation of the facility oil storage tanks at least once every five (5) years or when significant changes in the Facility occur. The completed review and evaluation must be followed by a signed statement as to whether the Plan will be amended. The record of the SPCC Plan Five-Year Reviews and Amendments is contained in Appendix E.

40 CFR 112.3(d) requires that SPCC plan five-year updates and technical amendments must be reviewed and certified by a licensed Professional Engineer (PE).

The SPCC Plan must be amended within six (6) months of the review and evaluation to include all identified facility changes, and more effective field-proven prevention and control technology, that will significantly reduce the likelihood of a discharge from regulated oil tanks and oil transfers. The site must implement any SPCC plan update or amendment as soon as possible, but not later than six (6) months following the preparation and PE certification of any amendment.

1.7.2 Facility Change Amendments

“112.5(a): Amend the SPCC Plan for your facility in accordance with the general requirements in §112.7, and with any specific section of this part applicable to your facility, when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge as described in §112.1(b). Examples of changes that may require amendment of the Plan include, but are not limited to: commissioning or decommissioning containers; replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of piping systems; construction or

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demolition that might alter secondary containment structures; changes of product or service; or revision of standard operation or maintenance procedures at a facility. An amendment made under this section must be prepared within six months, and implemented as soon as possible, but not later than six months following preparation of the amendment.”

The SPCC plan must be amended when there is a change in the Facility design, construction, operation, or maintenance that materially or significantly affects the Facility’s potential for an oil discharge, in quantities that may be harmful, into or upon navigable or surface waters, or adjoining shorelines, or into a drainage system that may connect to open waters, or an oil discharge that may seriously affect natural resources. Examples of changes include, but are not limited to, the following:

• Commissioning or decommissioning containers

• Replacement, reconstruction, or movement of containers

• Reconstruction, replacement, or installation of piping systems

• Construction or demolition that might alter secondary containment structures

• Changes of product or service

• Revision of standard operation, inspection, or maintenance procedures

A plan technical amendment to include any of these changes must be prepared within six (6) months after the change occurs and must be implemented as soon as possible, but not later than six (6) months following preparation of the amendment. 40 CFR 112.3(d) requires that SPCC plan 5-year updates and technical amendments must be reviewed and certified by a licensed PE.

Non-technical amendments can be made by the Designated SPCC person and are documented in the appropriate plan section. Non-technical amendments can include administrative updates, such as changing facility or person names and telephone numbers, correcting data errors, and noting that ancillary tanks were removed or taken out of service (OS).

The record of SPCC Plan Five-Year Reviews and Amendments is contained in Appendix E.

1.7.3 Spill Reports & EPA Directed Amendments

“112.4(a): Notwithstanding compliance with §112.3, whenever your facility has discharged more than 1,000 U.S. gallons of oil in a single discharge as described in §112.1(b), or discharged more than 42 U.S. gallons of oil in each of two discharges as described in §112.1(b), occurring within any twelve-month period, submit the following information to the Regional Administrator within 60 days from the time the facility becomes subject to this section:

• Name of the facility.

• Name of the owner or operator of the facility.

• Location of the facility.

• Date of initial facility operation.

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

• Description of the facility, including maps, flow diagrams, and topographical maps.

• A complete copy of the SPCC Plan with any amendments.

• The cause of such spill, including a failure analysis of the system or subsystem in which the failure occurred.

• The corrective actions and/or countermeasures taken, including an adequate description of equipment repairs and/or replacements.

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• Additional preventive measures taken or contemplated to minimize the possibility of reoccurrence.

• Such other information as the EPA Regional Administrator may require.”

If any spill were to occur at the facility that meets the criteria of 40 CFR 112.4(a), which is listed above, then a written spill report must be submitted to the EPA Regional Administrator within 60 days.

Following receipt of the facility spill report, the EPA may decide to require an amendment to the SPCC Plan, and the facility will be notified by certified mail. EPA will specify the terms of such a plan amendment.

Within 30 days from receipt of the notice, the facility may submit written information, views, and arguments on the proposed amendment. After considering all material presented, EPA will either notify NAS Corpus Christi that an amendment is required or will rescind the notice.

Any EPA proposed amendment becomes a part of the SPCC Plan 30 days after such notice unless NAS Corpus Christi appeals. The amendment should be implemented as soon as possible, but not later than six months after the amendment becomes a part of the SPCC Plan.

NAS Corpus Christi did not discharge more than 1,000 United States (U.S.) gallons of oil in a single discharge as described in §112.1(b), or discharge more than 42 U.S. gallons of oil in each of two discharges as described in §112.1(b), occurring within any twelve-month period. As such, NAS Corpus Christi was not required to submit their SPCC Plan with any amendments to the EPA for review. The NAS Corpus Christi list of reportable spills is maintained at the PWD Environmental office.

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SECTION 2

General Facility Information

Facility Owner/Operator: Commanding Officer

Address: Naval Air Station Corpus Christi 11001 ‘D’ Street, Suite #101 Corpus Christi, Texas 78419

Telephone: CDO (361) 534-9093

Facility Description “112.7(a)(3): Describe in your Plan the physical layout of the facility and include a facility diagram, which must mark the location and contents of each container. The facility diagram must include completely buried tanks that are otherwise exempted from the requirements of this part under §112.1(d)(4). The facility diagram must also include all transfer stations and connecting pipes.”

NAS Corpus Christi is located 10 miles southeast of downtown Corpus Christi, in Nueces County, Texas.

The station is situated on 2,844 acres of land on the northern end of the Encinal Peninsula. NAS Corpus Christi was commissioned in 1941 and has served as headquarters for the Naval Air Advance Training since 1948. The station is headquarters for Chief of Naval Air Training (CNATRA) and Training Air Wing FOUR, which provides training to potential Naval and Marine aviators as well as students from other allied nations. Currently, the station produces approximately 500 newly qualified aviators each year.

The station is also home to the CCAD, one of the Army’s major repair depots for rotary wing aircraft, and the CBP, Air and Marine P-3 Operations facility.

The mission of NAS Corpus Christi is to provide support to aviation facilities and units of CNATRA and other tenant activities. This station is a well-developed military facility, with most areas containing structures, impervious paved roads, and parking lots. However, there are also natural land areas within the station, with grass and trees, and a coastal waterfront. The station has an approximate elevation of 15 feet above mean sea level, located adjacent to Corpus Christi Bay. The station has a large and varied drainage system, including interconnected ditches and swales, infiltration areas, storm water inlets, culverts, and other flow structures; OWS; and storm water ponds. The station is divided into 47 storm water drainage basins. Industrial areas are drained through storm water basins and eventually into Corpus Christi Bay. In the event that oil is released into navigable waters, the NAS Corpus Christi FRP describes the process to hire a spill response contractor, who has the equipment and trained personnel to perform the cleanup actions.

Figure 2-1 shows the NAS Corpus Christi location and Appendix B includes a facility diagram.

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FIGURE 2-1

Location Map

Oil Storage Containers “112.7(3)(i): You must also address in your Plan the type of oil in each fixed container and its storage capacity. For mobile or portable containers, either provide the type of oil and storage capacity for each container or provide an estimate of the potential number of mobile or portable containers, the types of oil, and anticipated storage capacities;

(capacities of 55 gallons or greater)”

NAS Corpus Christi stores a variety of Petroleum, Oils, and Lubricants (POL) for use in ground vehicles, aircraft, marine vessels, as well as fuel for back-up emergency electricity generation. These POLs are stored in a variety of ASTs, USTs, DSAs, and mobile/portable equipment throughout the Station. In addition, ASTs containing used engine oils, Used Cooking Oils (UCO), and various types of OFOE (including electrical transformers and hydraulic oil reservoir tanks) are found throughout the station.

DSAs with 55-gallon drums containing new and used lubricating oils are located throughout the station.

Other oil storage tanks or transport areas such as mobile equipment, loading areas, OWS, and facility piping are found at NAS Corpus Christi, and are also discussed in this Plan, where appropriate.

The total oil storage capacity is summarized in Table 2-1. Information on OWS units at NAS Corpus Christi is found in Table 2-2. Information pertaining to ASTs, and mobile/portable equipment that meet

SECTION 2 – GENERAL FACILITY INFORMATION

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the criteria specified in 40 CFR 112 can be found in Table 2-3. Information pertaining to OFOE can be found in Table 2-4. USTs are counted separately as discussed in Section 2.2.7.

TABLE 2-1

Summary of Oil Storage Containers & Capacities

Container Type Quantity Total Oil Storage Capacity (gallons) Additional Details

NAS

Bulk Field-Erected ASTs 2 492,231 See Appendix A

Shop-Fabricated ASTs 37 35,679 See Appendix A

Out of Service ASTs 5 3,500 See Appendix AB

Mobile / Portable Storage 10 29,449 See Appendix AB

Drum Storage Areas 26 4,895 See Appendix AB

OFOE (Pad-mounted Transformers) 158 28,910 See Table 2-4

OFOE (Hydraulic Containers) 19 2,230 See Table 2-4

UCO 2 588 See Appendix AB

Total NAS Aboveground Oil Storage Capacity 597,482

USTs 3 30,000 See Appendix A

Out of Service USTs (not Fillable) 9 210,000 See Appendix AB

Total NAS Oil Storage Capacity (with USTs) 627,482

CCAD

Shop-Fabricated ASTs 17 43,808 See Appendix A

Out of Service ASTs 3 4,150 See Appendix AB

Mobile / Portable Storage 4 260 See Appendix AB

Drum Storage Areas 26 10,285 See Appendix AB

OFOE (Pad-mounted Transformers) 68 21,010 See Table 2-4

OFOE (Hydraulic Containers) 62 11,462 See Table 2-4

Total CCAD Aboveground Oil Storage Capacity 90,975

Total Aboveground Oil Storage Capacity (NAS + CCAD) 688,457

Each of the items listed in Table 2-1 is addressed in this Plan, in the following order:

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1. High-Risk Oil Storage Facilities

• Aviation Fuel Facility 1717

• Government Operated Vehicle (GOV) Gas Station – Facility 154

• Navy Exchange (NEX) Gas Station – Facility 1290

• CCAD Fuel Farm – Facility 8

2. Ancillary Aboveground Storage Tanks

3. Mobile Refueler Trucks and Portable Containers

4. Used Cooking Oil Containers

5. Drum Storage Areas

6. Facility Piping

7. Underground Storage Tanks

8. Oil-Filled Operational Equipment

• Elevator Hydraulic Oil Tanks

• Electrical Transformers

9. Oil Water Separators

10. Out of Service or Permanently Closed Containers

2.2.1 High-Risk Oil Storage Facilities

High-risk oil storage sites at NAS Corpus Christi were established based upon review of both the volume of oil stored at each location and the frequency of transfer operations completed at that facility. The sites are listed below.

2.2.1.1 Aviation Fuel Facility 1717

Detailed information for tanks at the Aviation Fuel Facility is included in Table 2-3 and Appendix A, Tank Data sheets. See Figure 2-2 and Appendix B for diagram and location of this area.

The Aviation Fuel Facility 1717 is located at the south end of the airfield on First Street. This facility is a government-owned, contractor-operated facility. LB&B Associates operates the bulk fuel storage and transfer services at NAS Corpus Christi, under a contract with DLA.

There are two single walled, carbon steel, field-erected ASTs, 1716-1 and 1720-2, installed in 1987 that store 244,604-gallons and 247,627-gallons of F-24 jet fuel, respectively. The bulk storage ASTs are equipped with leak detection, automatic tank gauging (ATG), and high-level alarms. Both ASTs have automatic high-level control, overfill prevention valves (OPV) installed on fuel receipt inlet pipelines.

The bottom plating of ASTs 1716-1 and 1720-2 (in contact with sand) is provided with cathodic protection (CP) using an impressed-current system. Each tank has a fixed, cone shaped roof. Secondary containment is provided by individual dikes, with vertical concrete walls and sloped earthen floors, all covered with a flexible membrane liner. Each containment has a normally closed drain with post indicator valve (PIV) that controls flow to OWS-1717-1 (3,450-gallons).

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The piping associated with the bulk ASTs is aboveground, single walled, stainless steel. The section of piping from the containment dike walls to the pump/filter pad is out of containment. Then it travels to the loading/unloading station, Facility 1719, directly north of the ASTs, in a covered concrete trench, which is supported above the trench bottom surface (not in contact with soil). The loading/unloading station contains an unloading area (not considered a rack) for commercial fuel truck deliveries to the bulk ASTs.

There is also a loading rack for filling military refueler trucks, using a flexible hose attached to a mechanical swivel arm. Each side of the loading/unloading station has a concrete containment area, which is curbed and sloped towards the mid-point, with a center trench drain between the two sides. The drain flows into a remote spill basin (11,316 gallons) with a dual PIV that can be used to control flow into either OWS-1717- 1 (3,450 gallons) or the sanitary sewer. The bulk ASTs are electronically gauged during filling and continuously monitored via the ATG system installed in each tank.

There is one shop-fabricated AST generator, 1717-2, that stores 1,000-gallons of diesel. The generator provides backup power to the Fuels operation office and fuel sampling lab. The lab drains into OWS- 1717-2 for grey water pretreatment. The spill basin also serves as secondary containment for DSA-1719, which stores two 55-gallon drums for F-24 waste fuel recovery, and for storm drains located around the fuel facility.

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FIGURE 2-2

Aviation Fuel Facility

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2.2.1.2 GOV Gas Station – Facility 154

Detailed information for tanks at the GOV Gas Station is included in Table 2-3 and Appendix A, Tank Data sheets. See Figure 2-3 and Appendix B for diagram and location of this area.

The GOV Gas Station, Facility 154, is located at the North end of the airfield off Second Street. It operates 24 hours per day, 7 days per week, but is unmanned and unassisted. This facility is a government-owned, contractor-operated facility, used to store fuel products and fill GOVs. LB&B Associates (DLA contractor) fills and operates military refueler trucks (2,000-gallon capacity) that are used to deliver gasoline and diesel products to generators and ASTs throughout the station.

There are two shop-fabricated, concrete encased, double-walled ASTs, 154-1 and 154-2, which were both installed in 2005. AST 154-1 stores 8,000-gallons of diesel, and AST 154-2 stores 4,000-gallons of gasoline. The ASTs are equipped with leak detection, ATG system, low- and high-level alarms, and manual shut-off valves. The ATG system is monitored at the Aviation Fuel Facility office. There are automatic high-level control OPVs installed on fuel receipt inlet pipeline. The ASTs are installed on a concrete slab adjacent to a loading/unloading station.

The section of piping from the ASTs to the piping transition sumps are coated carbon steel, single walled, which then changes to fiberglass/plastic, double-walled, for the underground portion to the dispensers.

Commercial delivery trucks off-load fuel into the ASTs at the loading/unloading station directly west of the ASTs, by standard camlock fitting on a flexible hose. The ASTs are electronically gauged during filling, and continuously monitored via the ATG system installed in each tank. The loading/unloading station has the ability to fill military refueler trucks, by use of a flexible transfer hose and camlock fitting, or to fill smaller sized vehicles through the use of two standard fuel nozzle dispenser pumps. The driveway for the loading/unloading station has a containment area, which is curbed and sloped towards the mid-point, with a trench drain and normally closed PIV. This containment area has a volume of 7,050 gallons. The PIV can be used to control flow to OWS-169 (OS), but it is currently out of service. A project is planned to replace the OWS with a remote spill basin of 3,340-gallon capacity. Additional details on this project can be found in Section 3.3.

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FIGURE 2-3

GOV Gas Station

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2.2.1.3 NEX Gas Station – Facility 1290

Detailed information for tanks at the NEX Gas Station is included in Table 2-3 and Appendix A, Tank Data sheets. See Figure 2-4 and Appendix B for diagram and location of this area.

The NEX Gas Station, Facility 1290, is located near the south entrance of the base, at the corner of Lexington Boulevard and First Street. This facility provides retail sales and motor vehicle fuel to authorized personnel. A NEX attendant is on duty to monitor fuel dispensing operations, but only during hours when the Mini-Mart is open. The dispensers remain open after hours for credit card sales only.

There is an emergency shut-off switch, located next to the Mini-Mart entry door. This facility is considered a higher risk due to the frequency of vehicle fuel transfers at the dispensers by untrained personnel and the large quantity commercial fuel deliveries by trained personnel into the USTs.

The NEX Gas Station has three 10,000 gallon, fiberglass reinforced plastic, single-walled USTs, which were installed in 1986. UST-1 stores regular gasoline, UST-2 stores premium gasoline, and UST-3 stores diesel. The USTs are monitored by a Veeder Root TLS 350 ATG, which includes a leak detection system.

The ATG is automatically updated after each receipt of fuel, and the leak detection system cycles every 24 hours with a print-out. The NEX Mini-Mart manager verifies and files the leak detection slips daily.

The ATG system is tested for proper operation annually.

The USTs are filled by commercial fuel delivery trucks, via a transfer hose with camlock connections into the UST fill ports, located within containment sumps on top of each UST. These sumps are intended to capture any minor spills during fuel transfer. There is no secondary containment berm around the fuel truck unloading area.