2245 Fort Sill SPCCP-ISCP June 2020.pdf

FINAL

Spill Prevention, Control, and Countermeasures Plan/ Installation Spill Contingency Plan

Facility 2245 – Petroleum, Oil, and Lubricants Point

U.S. Army Garrison

Fort Sill, Oklahoma

June 2020

Contract No.: W912BV-15-D-0019, TO: W912BV17F0071 June 2020

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FINAL SPCCP/ISCP

U.S. Army Garrison Fort Sill, OK

TABLE OF CONTENTS

Section Page

1.0 Facility 2245 – Petroleum, Oil, and Lubricants Point – LRC Main Fuel Point

1.1 Spill Categories and Procedures

1.2 Site Hazardous Materials / Hazardous Waste and POL Information

1.3 Site Description and Operations

1.4 Security

1.5 Spill Factors and Probable Spill Routes

1.6 Spill Discovery and Response

1.7 Evacuation Procedures

1.8 Spill Response Equipment Inventory and Location

1.9 Training

1.10 Containers, Secondary Containment, and Uncontained Spill Rate/Flow

1.11 Inspections

LIST OF ATTACHMENTS

Site Map Spill or Incident Report Record Weekly Environmental Inspection Log Monthly STI-SP001 AST Inspection Checklist Monthly STI-SP001 Mobile Refueler/Fuel Pod Inspection Checklist Annual STI-SP001 AST Inspection Checklist POL Containment Drainage Record

LIST OF ABBREVIATIONS / ACRONYMS

AR Army Regulation AST Aboveground Storage Tank DPW Directorate of Public Works EO Environmental Officer EQD Environmental Quality Division F-24 Jet Fuel F&ES Fire & Emergency Services gal/min gallon per minute HM Hazardous Materials HMC Hazardous Materials Conex IOSC Installation On-Scene Coordinator ISCP Installation Spill Contingency Plan LRC Logistics Readiness Center MFT Mobile Fuel Tanker NA not applicable OWS Oil/Water Separator POL Petroleum, Oil, and Lubricants PPE Personal Protective Equipment SDS Safety Data Sheet SOP Standard Operating Procedure SPCCP Spill Prevention, Control, and Countermeasure Plan

Facility 2245 – Petroleum, Oil, and Lubricants Point

1.0 Facility 2245 – Petroleum, Oil, and Lubricants Point – LRC Main Fuel Point

Facility 2245 and support facilities 2246 and petroleum storage tanks M2185A and M2185B and M2247A, M2247B, M2247C, and M2247D constitute the constructed buildings at the Petroleum, Oil, and Lubricants (POL) Point. Facility 2245 houses the office operations. The POL Point is located in the northwest portion of the cantonment area on the south side of Randolph Road approximately one-eighth mile west of Currie Road. The site map is provided in the Attachments.

1.1 Spill Categories and Procedures

Personnel at each facility handling hazardous materials(HM) should review these procedures periodically and implement these procedures in the event of a spill. All “Small Spills” are required to be reported to Environmental Quality Division (EQD), using the Spill or Incident Report Record. All “Large Spills” are immediately reported to 911.

INCIDENTAL SPILLS – Spills incidental to routine operations that are limited in quantity, exposure, or toxicity and present minor safety or health hazards to employees in the immediate work area.

• Contain the spill using on-site spill kits, drip pans, rags, etc.;

• Remove standing liquids by safe means if possible;

• Use absorbent materials to remove residual contamination;

• If not on a hard surface excavate as necessary to remove contamination;

• Place all contaminated materials into labeled containers suitable for turn-in to EQD;

• No reporting is required for incidental spills.

SMALL SPILLS – Less than fifty-five (55) gallons of POL that does not enter a stormwater conveyance or body of water.

• Contain the spill using on-site spill kits, drip pans, dirt berms, etc.;

• Remove standing liquids by safe means if possible;

• Use absorbent materials to remove residual contamination;

• If not on a hard surface excavate as necessary to remove contamination;

• If unsure, contact EQD for assistance in determining the proper amount of excavation;

• Place all contaminated materials into labeled containers suitable for turn-in to EQD;

• Report the release to EQD within 72 hours using the Spill or Incident Report Record.

LARGE SPILLS – Fifty-five gallons or greater of POL or an uncontained spill of POL; a hazardous substance spill other than POL that is not an Incidental Spill; Any spill of POL or hazardous substance that enters a stormwater conveyance or body of water; or an emergency situation.

• Ensure personnel safety by wearing proper personal protective equipment (PPE), barricading off the spill site, or evacuating the area;

• Immediately call 911 providing the following details of the release:

• Name and phone number of the individual reporting the release;

• Organization responsible for the release, a point of contact, and phone number;

• Date, time, and location of release;

• Name, stock number, manufacturer, and amount of chemical material spilled;

Facility 2245 – Petroleum, Oil, and Lubricants Point

• Source and cause of release;

• Environment the spill entered (ground, air, water, sewer line, confined within building);

• Actions taken, and any planned actions to be taken while waiting for emergency services.

• Notify EQD;

• Eliminate any ignition sources and quickly assess the spill and safety hazard;

• If safe, stop the source of the spill (i.e., shut down pumps, close valves, etc.);

• Initiate spill control: construct berms, apply absorbent materials, block storm drains, etc.

For more information see the section titled Spill Discovery and Response below.

1.2 Site Hazardous Materials / Hazardous Waste and POL Information

The primary hazardous substances stored at this facility are jet propulsion fuel F-24, bio-diesel, and MOGAS. There is one hazardous materials conex (HMC) located in the southwest corner of the facility.

This HMC is used to store small containers of POL, empty small POL containers, shop towels/wipe rags, and used shop towels/wipe rags. The facility is used as a fueling point for government-owned vehicles.

Building 2245 is an office building used by the facility management. The fuel used at the facility is stored in five steel aboveground storage tanks (ASTs) located along the south perimeter of the facility. This is the Main Fuel Point. Three of the ASTs contain F-24 with a capacity of 40,000 gallons each. The other two ASTs each have a 30,000-gallon capacity and contain either diesel or MOGAS fuel. All five ASTs are double-walled and surrounded by secondary containment.

Building M2185 (Backup Fuel Point) is located approximately 1,300 feet south of the Main Fuel Point and approximately 75 feet north and east of Building 2182. Two 6,000-gallon, Ecovault ASTs are located here and are managed by the Main Fuel Point (see drawing titled Figure 2245.1, Site Map - Facility 2245 (Backup Fuel Point). One of the ASTs is used to store MOGAS and the other is used to store diesel fuel.

This facility does not have floor drains inside the structure/bays. The floor is cleaned using a dry sweep absorbent material that is collected and transported to the Fort Sill Landfill. Personnel conduct weekly inspections to confirm that all HM are stored properly, wastes are disposed or staged in appropriate containers, and other environmental and safety protocols are being followed. The Weekly Environmental Inspection Log is provided in the Attachments. The following table summarizes the HM (including POL) stored at this facility and indicates the types and sizes of the largest storage containers.

Description Type of Container (largest)

F-24 40,000-gallon AST

Diesel 30,000-gallon AST

MOGAS 30,000-gallon AST

Diesel Fuel 6,000-gallon AST

Vehicle fuels (dispensing/receiving areas) 10,000-gallon Fuel Tanker AST aboveground storage tank F-24 jet fuel

1.3 Site Description and Operations

The Main Fuel Point encompasses approximately 3.8 acres and is located along Randolph Road near the Hand Road intersection. The Main Fuel Point serves as the primary re-fueling location for Fort Sill vehicles, including military, civilian, and maintenance vehicles. Fuel is delivered to the POL Receiving Area, which includes tanker pad, catchment channel, POL spill collection area, aboveground pumping

Facility 2245 – Petroleum, Oil, and Lubricants Point and piping equipment, on the west end of the facility. Tankers with capacities up to 10,000 gallons arrive at the POL Receiving Area to supply fuel to the ASTs. The tankers typically deliver between 7,500 gallons and 8,500 gallons of fuel. Fuel is delivered to the five ASTs via a network of aboveground piping.

F-24 is stored in three ASTs which have the capacity to hold 40,000 gallons each, diesel is stored in a 30,000-gallon AST, and MOGAS is stored in a 30,000-gallon AST.

POL Receiving Area at POL Point

ASTs Area at POL Point

The fuels are dispensed in two primary methods. The POL Dispensing Islands consists of seven islands with dispensers that are used to directly fuel vehicles and equipment. These dispensers are operated by individual users. A spill response kit is assigned to each dispensing island and is located adjacent to it.

Underground piping delivers the fuel from the ASTs to the POL Dispensing Islands.

Facility 2245 – Petroleum, Oil, and Lubricants Point

POL Dispensing Islands at POL Point

The POL Bulk Dispensing Area, which includes tanker pad, boom, aboveground pumping, and piping equipment, is located on the east end of the facility. This dispenser is used to refill HEMTTs outfitted with a fuel tanker having a capacity of 5,000 0r 2,500 gallons. Aboveground piping near the perimeter of the facility delivers fuel from the ASTs to the POL Bulk Dispensing Area.

POL Bulk Dispensing Area at POL Point

Additional fuel storage is located at Building M2185 (Backup Fuel Point), which is approximately 1,300 feet south of the main facility. Two 6,000-gallon Ecovault ASTs are located here and are managed by the Main Fuel Point. One of the ASTs is used to store MOGAS and the other is used to store diesel fuel.

Facility 2245 – Petroleum, Oil, and Lubricants Point

1.4 Security

Fort Sill provides appropriate physical security measures for the facility in accordance with Army Regulation (AR) 190-51. The facility has a fence with a locking gate to prevent unwanted access. The POL Point is open and staffed during standard business hours of 0730 to 1600. The facility is entirely fenced and has locking gates. Emergency personnel have key access after hours.

In addition to the facility and installation security, the aboveground equipment of the POL operational areas has bollards to protect the piping, tanks, pumps, and other fuel handling equipment. Portable median barriers for additional physical security are throughout the POL Point. Exterior lighting at this facility is adequate. The POL Point is well lit and in the event of a release in dark or dusky conditions, visibility would be maintained so that the release could be observed and response procedures conducted immediately.

1.5 Spill Factors and Probable Spill Routes

The Main Fuel Point has a number of containment regions based on its size and functionality. At the POL Receiving Area, the tanker pad is curbed on the west side and bermed on the east side; the floor is sloped toward the center. This area flows directly west through the catchment channel and into the POL Catch Basin. Rainwater collected in the catch basin is drained through a manual valve. Site personnel are instructed to inspect the collected rainwater prior to opening the valve for discharge of the collected water. If no visible POL or oil sheen is detected, they are to complete the appropriate POL Containment Drainage Record and discharge the collected water. Once discharge is completed, they are to ensure the discharge valve is placed in the closed position. If visible POL or oil sheen is detected they are to complete the appropriate POL Containment Drainage Record and contact the EQD for appropriate offsite disposal/recycling. The POL Containment Drainage Record is included in Appendix B of Volume I. The aboveground piping carries fuel from the POL Receiving Area to the ASTs, then from the ASTs to the POL Bulk Dispensing Area. Most of this piping is located near the edge of the POL facility and situated over a gravel base. There is no passive secondary containment for most of the piping.

Aboveground Piping and Fencing at POL Point

Facility 2245 – Petroleum, Oil, and Lubricants Point

The ASTs have segregated secondary containment based on their size and fuel type. The three F-24 tanks, each with a capacity of 40,000 gallons, along with the fuel filter/sediment traps for removing solids from the fuel prior to entering the ASTs sit inside a concrete basin. Each of the two 30,000-gallon ASTs (one contains diesel and one contains MOGAS) are contained inside concrete basins. Each of these basins has a drain equipped with a manually operated valve which is subject to the same procedures as the POL Catch Basin. The tanker pad at the POL Bulk Dispensing Area slopes toward a drain with a manually operated valve.

Catch Basin Channel and POL Catch Basin

The HMC is located in the southwest corner of the facility. The unit is used to store POL in 55-gallon or smaller containers. The unit is designed with built in secondary containment. There also is an oil/water separator (OWS) located near the southwest corner of the facility. Rainwater collected from the tertiary containment structures discharges into the OWS. The OWS discharges into the sanitary sewer system.

Approximately 1,300 feet south of the main facility are two 6,000-gallon Ecovault ASTs (M2185) which are managed by the facility. These ASTs are double walled and used to store MOGAS and diesel. The ASTs are sitting on a concrete pad with concrete retainer walls surrounding them providing tertiary containment. The tertiary containment area is drained by two manually operated discharge valves, which are subject to the same procedures as the POL Catch Basin.

The fuel is dispensed through two dispenser pumps which are located northeast and northwest of the ASTs. The dispenser pumps are elevated on a concrete pedestal, to prevent contact with storm water, and are protected from vehicular traffic by bollards. The pipelines running from the ASTs to the dispenser pumps are placed in concrete lined trenches and are protected from vehicular traffic by bollards and a concrete block wall. The fueling area is concrete hardstand, surrounded by a concrete curb. The fueling area drains into a storm drain located in the center of the area. Water flows from this drain to a manually operated discharge valve. After visual inspection, the water is released and the POL Containment Drainage Record is completed. Storm water from the east side of this facility (outside the fueling area) sheet flows generally to the south and east. Storm water from the west side of the facility (outside the

Facility 2245 – Petroleum, Oil, and Lubricants Point fueling area) sheet flows generally to the south and west. Once leaving the facility, storm water flows to the south, into an unnamed tributary, and eventually discharges into Sitting Bear Creek.

Spill factors at this facility include container failure or human error while transferring contents between containers or while using fork-lift type equipment to move larger containers. Surface runoff direction inside the POL Point is determined by the slope of the concrete. The south half, generally between the POL Dispensing Islands and the AST area flows to the west-southwest towards Building 2246. From the POL Dispensing Islands north, runoff flows to the west and is re-directed to the south by the berm at the POL Receiving Area. A large rain event has the potential to overtop or defeat the berm causing an amount of runoff to enter the POL Catch Basin. The northeastern quarter of the POL area flows northeast toward the driveway on Randolph Road, with the exception of the tanker pad at the POL Bulk Dispensing Area which is sloped to flow towards its center. If a release from the POL Point occurs, the discharge would enter an unnamed tributary of Sitting Bear Creek which drains into East Cache Creek. The site map depicts the anticipated surface flow lines. Spills of waste material will be contained within curbed areas and the catch basin.

1.6 Spill Discovery and Response

SMALL SPILLS

For a Small Spill (non-emergency release of less than fifty-five gallons of POL that does not enter a stormwater conveyance or body of water), the following actions should be taken:

• Notify supervisor or Environmental Officer (EO);

• Notify occupants in the immediate area of the spill;

• Attend to any persons that may have been contaminated. Contaminated clothing must be removed immediately, and appropriate first aid applied;

• If a volatile flammable material is spilled, control any possible sources of ignition and ventilate the area;

• Wear appropriate personal protective equipment for the material spilled and avoid breathing any vapor from the spill. Be aware that the use of a respirator requires specialized training. Never enter a contaminated atmosphere without respiratory protection or use a respirator without training. If respirator protection is required and no trained personnel are available, call the Fire Department at 911;

• Eliminate the source of contamination as soon as possible. This can be accomplished by uprighting or sealing containers, closing valves, or transferring contents from damaged containers to another suitable container;

• Eliminate lateral spread of contamination by preventing spilled material from entering inside floor drains, outside storm drains, and drainage ditches. All inside floor drains should be plugged, and absorbent pads or booms put in place to stop the migration of the spill. Every effort should be made to prevent the spill from reaching floor drains in buildings, outside storm drains, and drainage ditches;

• Once the spill source has been stopped and the spread controlled, apply absorbent materials to the impacted area to collect all spilled material. Use appropriate spill control material to first contain and absorb the spill according to procedures previously obtained from the Safety Data Sheet (SDS).

Generally, loose spill control material should be distributed over the entire spill area, working from the outside, circling to the center. This reduces the chance of splashing or spreading of the spill;

• For spills of acids and bases, use appropriate procedures (as obtained from SDS) and material to contain, neutralize and absorb the material;

• When the spilled materials have been absorbed, use brooms and shovels (spark resistant if flammable material is involved) to place materials in an appropriate container. Store the container in

Facility 2245 – Petroleum, Oil, and Lubricants Point a secure ventilated area;

• Decontaminate the surface where the spill occurred before allowing normal work activities to resume in the area;

• Collect contaminated items including soil, absorbent materials, pads, booms, PPE, etc. and place them in a labeled container suitable for turn-in for disposal (i.e., an approved 55-gallon drum). All residual contamination must be removed. Stains on pavement or asphalt can be removed by applying dry sweep and scrubbing. Contaminated soil should be excavated until no visual or other evidence of the spilled materials remains;

• Contact EQD directly if technical assistance is needed;

• Coordinate disposal of spilled material with EQD.

LARGE SPILLS

A Large Spill is fifty-five gallons or greater of POL or an uncontained spill of POL, a hazardous substance spill other than POL that is not an incidental spill, any spill of POL or hazardous substance that enters a stormwater conveyance or body of water, or an emergency situation. The Fort Sill Fire & Emergency Services(F&ES) will provide emergency response to large spills.

Most spills of this magnitude will be discovered and reported by on-site personnel. Additionally, spills may be reported by civilians or emergency services personnel during a transportation-related accident or they may be discovered during response activities associated with a natural disaster or other large-scale incident.

In most anticipated spill situations, the supervisor or EO will proceed to the spill site to evaluate the situation and make the determination of whether to request additional support from emergency services personnel. If the supervisor or EO determines that additional support is needed, they must immediately place a call to 911.

If potential hazards posed by the spill are unknown, personnel should evacuate the spill site until emergency services personnel arrive. In such situations, it is critical to provide the 911 operator with as much information as possible so that the initial response agencies can be as prepared as possible for the situation. Once emergency services personnel arrive, personnel with information on the spill or facility should cooperate with, and assist the response team, and provide them with any information possible.

In some situations, action can be taken to minimize impacts from the spill while waiting for emergency services personnel to arrive. If the type of material spilled is known and there is no immediate safety hazard, the supervisor or EO, with the assistance of other trained personnel, should try to stop or control the spill to minimize further impacts. These actions should be limited to closing valves, uprighting drums or other containers, applying absorbent materials, deploying booms or spill pads, etc. Only properly trained personnel with adequate PPE should participate in these initial spill control activities.

The 911 network must be contacted for any spill or other release immediately upon discovery if:

• The spill enters a stormwater conveyance or body of water.

• The spill involves a quantity in excess of 55 gallons of POL.

• The release is of a hazardous substance other than POL and is not an incidental spill.

• The spill causes an immediate safety or environmental hazard (emergency situation).

• The spill is beyond the capabilities of facility personnel to contain and clean up (uncontained).

Facility 2245 – Petroleum, Oil, and Lubricants Point

The 911 personnel answering a call for assistance will notify the Fort Sill Directorate of Emergency Services as appropriate to provide initial response to an emergency situation. When contacting 911, the following information must be provided:

• Name and phone number of the individual reporting the release;

• Organization responsible for the release, a point of contact, and phone number;

• Date, time, and location of release;

• Name, stock number, manufacturer, and amount of chemical material spilled;

• Source and cause of release;

• Environment the spill entered (ground, air, water, sewer line, confined within building);

• Actions taken, and any planned actions to be taken while waiting for emergency services.

1.7 Evacuation Procedures

If a spill could potentially endanger the health of personnel in the vicinity of a spill, evacuation of the area will be initiated. Evacuation of personnel shall be through the nearest exit upwind and away from the spill area. Prior to evacuation, employees should quickly shut down operations and secure equipment, if there is time to safely do so. Once outside the facility at a safe distance from the spill, facility personnel will assemble with their supervisor for roll call and further instructions.

1.8 Spill Response Equipment Inventory and Location

Facilities that use or store POL or other hazardous substances have spill kits and absorbent materials at all locations where these materials are kept or handled. At the time of the site visit, this facility had a spill response kit with sufficient materials to contain and clean up small spills or leaks. In addition, the facility was equipped with the following regularly tested and maintained equipment: fire extinguisher(s), land-line telephone, an emergency eyewash/shower and a fire alarm.

1.9 Training

Military units and civilian organizations are responsible for obtaining all required training for their personnel. Army regulations require that all facilities using or storing hazardous substances on the Installation appoint a primary and an alternate EO. The EO at each facility is accountable for discharge prevention and reports to facility management. EOs receive formal, specialized environmental training related to hazardous material identification, classification, and characteristics; understanding hazards and the SDS; hazardous material management; hazardous waste classification and management; hazardous materials transportation; stormwater pollution prevention and spill response; pollution prevention and sustainability. The training also includes a discharge prevention briefing that highlights and describes known discharges that have occurred on the Installation in the past year as well as failures, malfunctioning components, and any recently developed precautionary measures. This training typically consists of, at a minimum, an initial 40-hour training class and an annual 8-hour refresher course. 40-hour initial and 8-hour refresher training is provided by a Contractor and scheduled through EQD. Additional training may be required depending upon specific duties.

EOs are required to conduct training within their respective units and organizations for personnel engaged in operations utilizing hazardous substances. These personnel may also be required to attend formal training classes depending on their specific responsibilities.

Appropriate personnel are trained in the proper operation and safety procedures for materials and equipment that they use. All in-house training is documented and kept on file at the facility. EOs often prepare facility-specific standard operating procedure (SOPs) for material handling, storage, and spill

Facility 2245 – Petroleum, Oil, and Lubricants Point response. Personnel must be trained on the provisions of these SOPs and the facility specific Spill Prevention, Control, and Countermeasure Plan / Installation Spill Contingency Plan (SPCCP/ISCP).

Minimum training requirements for personnel handing oil include the following:

• Discharge briefings at least once per year. These briefings highlight and describe known discharges or failures, malfunctioning components, and any recently developed precautionary measures.

• Training in the operation and maintenance of equipment to prevent discharges; discharge procedures and protocols; applicable pollution control laws, rules, and regulations; general facility operations;

and contents of the facility specific SPCCP/ISCP.

1.10 Containers, Secondary Containment, and Uncontained Spill

Rate/Flow

Spill prevention measures employed at this facility include:

♦ Double-walled tanks used for storing fuel ♦ Tertiary containment for all ASTs ♦ Built-in secondary containment for the HMC ♦ Concrete curbing around the perimeter of the bulk fuel unloading and dispensing areas ♦ Concrete catch basin for the bulk fuel unloading area ♦ Bollards and concrete barricades providing vehicular traffic protection for all above ground piping systems

Each type of secondary containment area or device is designed to contain, at a minimum, the volume of the largest individual container stored. The tertiary containment is designed to contain, at a minimum, the volume of the largest container plus an allowance for precipitation and the displacement caused by other containers within the area (if applicable). All of the POL and other HM are stored in containers that are made of materials compatible with the type of material stored and are constructed in a manner appropriate for the conditions of storage, such as pressure and temperature.

Discharge from the POL catch basin, the AST storage area, and the bulk fuel dispensing area is controlled through a discharge valve. This valve remains closed at all times preventing indiscriminant discharges from the containment structure. Storm water is allowed to be discharged only after it has been determined that it has not been contaminated with POL or any other potentially HM. Operations personnel are instructed to perform a visual inspection of the contents, if no visible floating oil or oil sheen is detected and there is no other evidence of contamination, the valve is opened and the contents are allowed to discharge. If floating oil or visible oil sheen is detected, the contents are removed for offsite disposal. The person performing the inspection and subsequent discharge is instructed to close the valve as soon as possible after the discharge is completed. Documentation for these inspections is recorded on a POL Containment Drainage Record (Appendix B of Volume I) which is maintained at the facility.

The following tables provide details of the materials stored, secondary containment capacities, typical container types and sizes, estimated flow rates in the event of a spill, and estimated distances from the container storage areas to navigable waters.

Facility 2245 – Petroleum, Oil, and Lubricants Point

Storage Area Information

Storage Area Identification

HMC

Facility 2245 ASTs (Main Fuel Point)

3 – 40,000 gal ASTs 30,000 gal AST 30,000 AST

Material Stored Fuel, POL F-24 Diesel MOGAS

Container Type/ Volume of Largest Container (gallons)

Drums / 55

Steel AST / 40,000

Steel AST / 30,000 Double walled steel /

30,000

Secondary/Tertiary Containment Structure Type

Built in / NA

Concrete pad with concrete retainer wall

Concrete pad with concrete retainer wall

Steel / Concrete pad with concrete retainer wall

Secondary/Tertiary Containment Dimensions (feet)

19’10”L X 7’10”W X 6”D

70’L X 64’W X 41”D

64’L X 35’W x 44”D NAa / 64’L X 35’W x

44”D

Secondary/Tertiary Containment Total Volume (gallons)

114,502 / NA

61,440 / NA

NAa / 61,440

Required Volume (Gallons) 55 62,965b 32,094b 32,094c

Ground Covering Gravel Concrete Concrete Concrete Estimated Flow Distance to Navigable Water (feet)

Estimated Average Rate of Flow (gal/min)

67d

526e

505e

505e

Potential Causes of Spill

Vehicle impact;

loading/unloading accidents; container failure

Vehicle impact;

loading/unloading accidents; container failure

Vehicle impact;

loading/unloading accidents; container failure

Vehicle impact;

loading/unloading accidents; container failure

Upgrade/Procedural Change Required No No No No

Spill Control and Countermeasure

Unit personnel will be present during all container filling or emptying, ensure spill kits are readily available when filling or emptying container(s), clean up all incidental spills immediately, secure leaking containers, deploy spill kits, and only transfer products stored inside HMCs inside the

HMC.

a AST is double walled, it can be assumed that the secondary containment is greater than the primary tank volume b Calculations based upon volume of largest tank, plus an allowance for precipitation, plus an allowance caused by the displacement of the other tanks (if applicable) c Calculations are made for tertiary containment. Calculations based upon Bernoulli Equation for gravity-fed flow, with

4” drain pipe (with valve) draining tertiary containment with valve open and tertiary containment completely full d Calculations based upon Bernoulli Equation for gravity-fed flow, for an overturned 55-gallon drum with the 2” bung not in place e Calculations based upon Bernoulli Equation for gravity-fed flow, with 4” drain pipe (with valve) draining secondary containment with valve open and secondary containment completely full AST aboveground storage tank F-24 jet fuel gal/min gallons per minute NA not applicable HMC hazardous material conex POL petroleum, oil, and lubricants

Facility 2245 – Petroleum, Oil, and Lubricants Point

Storage Area Information

Storage Area Identification

Facility 2245 (continued) M2185 ASTs (Backup Fuel Point)

POL Receiving Area/tanker pad

POL Bulk Dispensing

Area/tanker pad

6,000 gal AST (Diesel)

6,000 gal AST

(MOGAS)

Material Stored F-24, Diesel, MOGAS

F-24, Diesel, MOGAS Diesel Diesel

Container Type/ Volume of Largest Container (gallons)

Fuel Tanker / 10,000

MFT / 5,000 Double walled steel /

6,000 Double walled steel /

6,000

Secondary/Tertiary Containment Structure Type

Concrete curbed area / POL Catch Basin

4” curbed area sloped to 24” in center

Concrete pad with concrete retainer walls

Concrete pad with concrete retainer walls Secondary/Tertiary Containment Dimensions (feet)

130’L X 26’W X 3”D / 48’L X 48’W X 4’D

109’L X 24.5’W X 28”D

35’L X 27’W X 11”D

35’L X 27’W X 11”D

Secondary/Tertiary Containment Total Volume (gallons)

6,320 / 68,940

46,612

NAa / 6,480

NAa / 6,480

Required Volume (Gallons) 15,314b 6,248 NAa / 7,357c NAa / 7,357c

Ground Covering Pavement Concrete Concrete Concrete Estimated Flow Distance to Navigable Water (feet)

Estimated Average Rate of Flow (gal/min)

515d

394d

61.7e

61.7e

Potential Causes of Spill

Vehicle impact;

loading/unloading accidents; container failure

Vehicle impact;

loading/unloading accidents; container failure

Vehicle impact;

loading/unloading accidents; container failure

Vehicle impact;

loading/unloading accidents; container failure

Upgrade/Procedural Change Required No No No No

Spill Control and Countermeasure

Unit personnel will be present during all container filling or emptying, ensure spill kits are readily available when filling or emptying container(s), clean up all incidental spills immediately, secure leaking containers, deploy spill kits, and only transfer products stored inside HMCs inside the

HMC.

a Tanks are double walled, it can be assumed that the secondary containment is greater than the primary tank volume b Largest tank + Catch Basin Precipitation + Receiving Pad Precipitation c Tanks are double walled providing adequate secondary containment d Calculations based upon Bernoulli Equation for gravity-fed flow, with 4” drain pipe (with valve) draining secondary/tertiary containment with valve open and secondary/tertiary containment completely full e Calculations based upon Bernoulli Equation for gravity-fed flow, with 2” drain pipe (with valve) draining tertiary containment with valve open and tertiary containment completely full AST aboveground storage tank MFT mobile fuel tanker gal/min gallons per minute NA not applicable HMC hazardous material conex POL petroleum, oil, and lubricants F-24 jet fuel

Facility 2245 – Petroleum, Oil, and Lubricants Point

1.11 Inspections

Refer to the List of Attachments in the Table of Contents and the Attachments in this facility specific SPCCP/ISCP for the required inspection checklists, logs, and records that must be completed and retained at your facility. The facility’s operations and equipment determine which of the following checklists, logs, and records are in this facility specific SPCCP/ISCP:

Spill or Incident Report Record: Submit to EQD when a small spill has occurred. EQD’s fax number and Email POC are listed at the bottom of the spill or incident report record. Large spills are reported through the 911 system, as a result EQD or the Fort Sill Fire Department will complete the spill or incident report records in these cases.

Weekly Environmental Inspection Log: Use when conducting weekly inspections of your facility. This walk-through inspection is intended to detect any leaks or spills from containers, oil-filled operational equipment, mobile refuelers, fuel pods, storage tanks, and material transfer areas. Other good housekeeping measures are checked as well like damaged containers, proper segregation of materials, volume of waste accumulation, secondary containment, and storm water pollution prevention.

Monthly STI-SP001 Portable Container Inspection Checklist: Use when conducting monthly inspections of portable containers (drums/totes) that are designated for oil storage and have a shell size of 55 gallons or greater. Note that each container must be identified on the checklist (new motor oil drums 1 through 4, contaminated F-24 drums 1-3, etc.).

Monthly STI-SP001 Mobile Refueler/Fuel Pod Inspection Checklist: Use when conducting monthly inspections of mobile refuelers and/or fuel pods. Note that each mobile refueler and/or fuel pod must be identified on the checklist (HEMTT refuelers 1 through 6, fuel pods 1 and 2, etc.).

POL Containment Drainage Record: Inspect secondary containment areas and document drainage of rain water on the POL Containment Drainage Record after rain events. Contact EQD and Do Not drain secondary containment areas if POL or a sheen is observed.

• All inspection checklists, logs, and records must be kept at your facility for 3 years.

• Releases are reported in accordance with Section 1.1 of this plan. Any leakage or malfunctions of equipment and containers must be reported to EQD for assessment and to Directorate of Public Works (DPW) for repair, if applicable.

• Oil is defined as “oil of any kind or any form” which means anything from jet fuel (F-24) to cooking or pine oil and even lubricating grease in a more solid form is considered “oil”.

• Containers that store “oil” with a shell size of 55 gallons or greater must be inspected and have adequate secondary containment. This does not include a fuel tank(s) in a vehicle that only provides fuel to power the vehicle. DPW is responsible for technical inspections of fixed fuel storage tanks, used oil tanks, and fixed GenSets (Backup Electrical Generators).

• Employees or on-site personnel at facilities included in this plan include Military, Department of the Army civilian, and private contractor personnel.

• Notify EQD of any substantial changes to oil storage capacity or changes in oil storage locations.

Facility 2245 – Petroleum, Oil, and Lubricants Point

Facility 2245 – Petroleum, Oil, and Lubricants Point

ATTACHMENTS

Facility 2245 – Petroleum, Oil, and Lubricants Point

Facility 2245 – Petroleum, Oil, and Lubricants Point

Facility 2245 – Petroleum, Oil, and Lubricants Point

Facility 2245 – Petroleum, Oil, and Lubricants Point

Spill or Incident Report Record

Date: Time: Location of Incident:

Unit/Organization: Point of Contact:

Phone Number: Substance/Material Released:

Stock Number and Manufacturer of Substance/Material Released:

Quantity Released:

Environment Affected:

Confined Within Building Pavement

Gravel Soil Storm Drain

Water Air Other (Describe)

Source and Cause of Release or Incident:

Actions Taken To Contain/Mitigate the Release or Incident:

Units/Organizations Responding to the Release or Incident:

Weather Conditions:

Actions Taken to Cleanup/Mitigate the Release or Incident:

Disposition of Waste Generated During Cleanup/Mitigation Activities:

Actions Taken to Prevent Reoccurrence:

Person Completing Record Signature Date

Facility 2245 – Petroleum, Oil, and Lubricants Point

Facility 2245 – Petroleum, Oil, and Lubricants Point

Fort Sill Weekly Environmental Inspection Log

FACILITY:

DATE: WEATHER:

Y N NA Are weekly environmental inspection logs (this checklist) filed and retained for a three year period?

Y N NA Has an Environmental Officer been appointed in writing?

Y N NA Have the appropriate personnel been properly trained in the following: used oil and spent solvent management, fueling procedures, good housekeeping practices, proper painting (touch up) procedures, used battery management, inspection procedures, SWP3 plan maintenance, and recordkeeping procedures?

Y N NA Are spill plans, storm water pollution prevention plans, HMWMP, SOPs and emergency response kits readily available?

Y N NA Are all POL storage areas identified in the storm water (SWP3) and spill (SPCC) plans?

Y N NA Are the refuse containers (dumpsters etc.) closed to ensure no storm water violations?

Y N NA Are curbs or other drainage areas clean of debris and/or trash? Are the outfalls clean with no evidence of spills, accumulated pollutants, or erosion?

Y N NA Is the facility inspected after every rainfall event to determine if spill/drip pans and/or secondary containment structures contain contamination and were properly drained? Note: discharge of uncontaminated rain water from HM secondary containment areas and documentation of the discharge shall be IAW procedures described in the SPCCP.

Y N NA Is the POL containment drainage record completed when rainwater is drained from secondary containment?

Y N NA Are awareness signs properly posted and maintained?

Y N NA Are good housekeeping and best management practices being observed? Are drip pans being properly used and maintained, are emergency spill kits readily available and adequately stocked, are leaks, spills and oil stains cleaned up in a timely manner?

Y N NA Are all POL containers/vessels, including mobile fuel tankers, staged in sufficient secondary containment?

Y N NA Are designated storage areas located away from storm drains and/or storm water outfalls?

Y N NA Are everyday in-use items stored in spill containment and protected from precipitation?

Y N NA Are vehicles and other stored equipment checked for leaks, and spills cleaned up immediately?

Y N NA Do oil spills receive adequate attention (proper use of sorbents, proper contact with sorbents –rubbing with boot, and/or all stains capable of creating a discharge or sheen removed)?

Y N NA Are all containment systems in good condition, leak-free, and functioning properly?

Y N NA Are the oil water separators being maintained?

Y N NA Have storage tanks, piping, valves and equipment been visually inspected for defects or leaks?

Y N NA Is the interstitial space free of liquids and all alarms on tanks and separators working properly?

Y N NA Is there an inventory of hazardous materials and MSDS/SDS located at this site?

Y N NA Is hazardous waste being accumulated at a Satellite Accumulation Point only?

Y N NA Are hazardous materials/waste stored in a manner that protects them from storm water, properly labeled, and segregated?

Y N NA Are wastes being accumulated in proper containers and tightly closed when not in use?

Y N NA Are all containers marked IAW the waste protocol sheet?

Y N NA Are container markings visible and is there adequate aisle space?

Y N NA Are all containers free of corrosion, bulges or other damage and not leaking?

For questions on environmental compliance, call 442-3266.

Unit/Building Inspected:

Inspector and Telephone Number:

Facility 2245 – Petroleum, Oil, and Lubricants Point

STI SP001 Monthly AST Inspection Checklist

General Inspection Information:

Inspection Date:

Prior Inspection Date:

Retain until date:

Inspector Name (print): Title:

Inspector’s Signature

Tank(s) inspected ID

Regulatory facility name and ID number (if applicable)

Inspection Guidance:

This checklist is intended as a model. Locally developed checklists are acceptable as long as they are substantially equivalent (as applicable). Inspections of multiple tanks may be captured on one form as long as the tanks are substantially the same.

For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures.

The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified

Inspector. It shall be performed by an owner’s inspector per paragraph 4.1.2 of the standard.

Upon discovery of water in the primary tank, secondary containment area, interstice, or spill container, remove promptly or take other corrective action. Inspect the liquid for regulated products or other contaminants and dispose of properly.

Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section.

Retain the completed checklists for at least 36 months.

After severe weather (snow, ice, wind storms) or maintenance (such as coating) that could affect the operation of critical components (normal and emergency vents, valves), an inspection of these components is required as soon as the equipment is safely accessible after theevent.

ITEM STATUS COMMENTS / DATE CORRECTED

Tank and Piping

Is tank exterior (roof, shell, heads, bottom, connections, fittings, valves, etc.) free of visible leaks?

Note: If "No", identify tank and describe leak and actions taken.

□ Yes □ No

2 Is the tank liquid level gauge legible and in good working condition? □ Yes □ No □ N/A

3 Is the area around the tank (concrete surfaces, ground, containment, etc.) free of visible signs of leakage? □ Yes □ No

Is the primary tank free of water or has another preventative measure been taken?

NOTE: Refer to paragraphs 6.10 and 6.11 of the standard for alternatives for Category 1 tanks. N/A is only appropriate for these alternatives.

□ Yes □ No □ N/A

5 For double-wall or double bottom tanks or CE-ASTs, is interstitial monitoring equipment (where applicable) in good working condition? □ Yes □ No □ N/A

6 For double-wall tanks or double bottom tanks or CE-ASTs, is interstice free of liquid?

Remove the liquid if it is found. If tank product is found, investigate possible leak. □ Yes □ No □ N/A

Equipment on tank

7 If overfill equipment has a “test” button, does it activate the audible horn or light to confirm operation? If battery operated, replace battery if needed. □ Yes □ No □ N/A

8 Is overfill prevention equipment in good working condition?If it is equipped with a mechanical test mechanism, actuate the mechanism to confirm operation. □ Yes □ No □ N/A

9 Is the spill container (spill bucket) empty, free of visible leaks and in good working condition? □ Yes □ No □ N/A

10 Are piping connections to the tank (valves, fittings, pumps, etc.) free of visible leaks?

Note: If "No", identify location and describe leak. □ Yes □ No

11 Do the ladders/platforms/walkways appear to be secure with no sign of severe corrosion or damage? □ Yes □ No □ N/A

Containment (Diking/Impounding)

12 Is the containment free of excess liquid, debris, cracks, corrosion, erosion, fire hazards and other integrity issues? □ Yes □ No □ N/A

13 Are dike drain valves closed and in good working condition? □ Yes □ No □ N/A

14 Are containment egress pathways clear and any gates/doors operable? □ Yes □ No □ N/A

Concrete Exterior AST (CE-AST)

15 Inspect all sides for cracks in concrete. Are there any cracks in the concrete exterior larger than 1/16”? □ Yes □ No □ N/A

16 Inspect concrete exterior body of the tank for cleanliness, need of coating, or rusting where applicable. Tank exterior in acceptable condition? □ Yes □ No □ N/A

Visual inspect all tank top openings including nipples, manways, tank top overfill containers, and leak detection tubes. Is the sealant between all tank top openings and concrete intact and in good condition?

□ Yes □ No □ N/A

Other Conditions

18 Is the system free of any other conditions that need to be addressed for continued safeoperation? □ Yes □ No

Additional Comments:

STI SP001 Annual AST Inspection Checklist

General Inspection Information:

Inspection Date:

Prior Inspection Date:

Retain until date:

Inspector Name (print):

Title:

Inspector’s Signature:

Tank(s) inspected ID

Regulatory facility name and ID number (if applicable)

Inspection Guidance:

This checklist is intended as a model. Locally developed checklists are acceptable as long as they are substantially equivalent (as applicable).

For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures.

The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified

Inspector. It shall be performed by an owner’s inspector per paragraph 4.1.2 of the standard.

Remove promptly standing water or liquid discovered in the primary tank, secondary containment area, interstice, or spill container. Before discharge to the environment, inspect the liquid for regulated products or other contaminants and disposed of it properly.

In order to comply with EPA SPCC (Spill Prevention, Control and Countermeasure) rules, a facility should regularly test liquid level sensing devices to ensure proper operation (40 CFR 112.8(c)(8)(v)).

Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section.

Retain the completed checklists for at least 36 months.

Complete this checklist on an annual basis, supplemental to the owner monthly-performed inspection checklists.

Note: If a change has occurred to the tank system or containment that may affect the SPCC plan, the condition should be evaluated against the current plan requirement by a Professional Engineer knowledgeable in SPCC development and implementation.

ITEM STATUS COMMENTS / DATE CORRECTED

Tank Foundation/Supports

1 Free of tank settlement or foundation washout? □Yes □No

2 Concrete pad or ring wall free of cracking and spalling? □Yes □No □N/A

3 Tank supports in satisfactory condition? □Yes □No □N/A

4 Is water able to drain away from tank if tank is resting on a foundation or on the ground? □Yes □No □N/A

5 Is the grounding strap between the tank and foundation/supports in good condition? □Yes □No □N/A

Tank Shell, Heads and Roof

6 Free of visible signs of coating failure? □Yes □No

7 Free of noticeable distortions, buckling, denting, or bulging? □Yes □No

8 Free of standing water on roof? □Yes □No □N/A

9 Are all labels and tags intact and legible? □Yes □No

Tank Manways, Piping, and Equipment

10 Flanged connection bolts tight and fully engaged with no sign of wear or corrosion? □Yes □No □N/A

Tank Equipment

11 Normal and emergency vents free of obstructions? □Yes □No

12 Normal vent on tanks storing gasoline equipped with pressure/vacuum vent? □Yes □No □N/A

13 Are flame arrestors free of corrosion and are air passages free of blockage? □Yes □No □N/A

Is the emergency vent in good working condition and functional, as required by manufacturer? Consult manufacturer’s requirements. Verify that components are moving freely (including long-bolt manways).

□Yes □No □N/A

Is interstitial leak detection equipment in good condition? Are windows on sight gauges clear? Are wire connections intact? If equipment has a test function, does it activate to confirm operation?”

Are all valves free of leaks, corrosion and other damage?