(TE 03) Fort Bliss Spill Prevention Control and Countermeasures Plan.pdf

SPILL PREVENTION, CONTROL AND

COUNTERMEASURE (SPCC) PLAN

FORT BLISS DIRECTORATE

OF PUBLIC WORKS

ENVIRONMENTAL DIVISION

November 2017

Technical Exhibit 03 Fort Bliss SPCC Plan

Spill Prevention, Control and Countermeasure Plan i

FOR OFFICIAL USE ONLY

TABLE OF CONTENTS

ABBREVIATIONS AND ACRONYMS .......................................................................V

COMMANDING COLONEL APPROVAL (40 CFR 112.7) ....................................... VII

DESIGNATED POSITION ACCOUNTABLE FOR SPILL PREVENTION ............... VII

PROFESSIONAL ENGINEER CERTIFICATION (40 CFR 112.3(D)) ...................... IX

SPCC PLAN REVIEW LOG ..................................................................................... XI

PART 1. INTRODUCTION (40 CODE OF FEDERAL REGULATIONS (CFR) 112(a)(1))

1. Purpose of SPCC Plan

2. Scope……

3. Applicability

4. Description of Fort Bliss (40 CFR 112.7(a)(3))

a. Location and Setting

b. Mission………

5. Operational Definition of “Facility” (40 CFR 112.7(a)(3))

6. Evaluation of Discharge Potential

a. Oil Storage on Fort Bliss (40 CFR 112.7(a)(3)(i))

c. Requirements of Impracticability

d. Discharge Potential (40 CFR 112.7(b))

7. Fort Bliss Key Contact Information (40 CFR 112.7(a)(3)(vi))

8. Legal Considerations

9. Security Instructions

10. Location of Plan (40 CFR 112.3(e))

11. Plan Review (40 CFR 112.5(a) and (b))

a. Scheduled Reviews

b. Amendments… ii

FOR OFFICIAL USE ONLY

12. Cross-Reference with SPCC Rule Provisions (40 CFR 112.7)

PART 2: COMPLIANCE WITH REQUIREMENTS (40 CFR 112.7(A)(1) AND 8(A))

1. Bulk Oil Storage Containers

a. AST Compliance

b. Secondary Containment for Drum Storage (40 CFR 112. 7(c) and 8(c)(2))

2. Secondary Containment for Mobile Refuelers (40 CFR 112. 7(c) and 8(c)(11))

3. Secondary Containment for Oil-Filled Operational Equipment [40 CFR 112.7(c)]

4. Active Secondary Containment Measures

a. Military Equipment

b. Oil Transfer Operations

5. Oil-Water Separators [40 CFR 112.8(c)(9)]

6. Drainage of Diked Areas [40 CFR 112.7(a)(3)(iii), 8(b) and 8(c)(3)]

7. Visible Discharges [40 CFR 112.8(c)(10)]

8. Spill Response and Reporting

a. Response to a Release of Oil (40 CFR 112.7(a)(3))

b. Spill Reporting (40 CFR 112.4(a))

9. Inspections, Tests and Records [40 CFR 112.7(e) and 8(c)(6)]

a. Industry Standards for Tank Inspections and Testing (40 CFR 112.8(c)(6))

b. General Inspection and Testing Requirements

c. Inspection and Testing of Field-Constructed Oil Storage Tanks (40 CFR 112. 7(i) and 8(c)(6))

d. Inspection and Testing of Shop-Fabricated Oil Storage Tanks

e. Inspection and Testing of Stationary Generators

f. Inspection and Testing of Portable Containers

g. Inspection and Testing of Military Equipment, Piping and Valves (40 CFR 112.8(c)(6))

h. Inspection and Testing of Elevators iii

FOR OFFICIAL USE ONLY

i. Inspecting and Testing of Aboveground Valves, Piping and Appurtenances

10. Training and Discharge Prevention Procedures (40 CFR 112.7(f) and 112.7(a)(3)(ii)) . 37

a. Personnel Training

b. Discharge Prevention and Countermeasure Procedures (112.7(a)(3)(ii))

PART 3. OIL SPILL CONTINGENCY PLAN (40 CFR 112.7(D), 112.7(A)(3)(IV) AND

(V), 112.7(A)(4) AND (5))

1. Fort Bliss OSCP

a. Purpose and Scope

b. Resources at Risk

c. Risk Assessment

d. Response Strategy

2. Spill Discovery and Response

a. Distribution of Responsibilities

b. Response Activities

3. Response Resources and Preparedness Activities

a. Equipment, Supplies, Services and Manpower

b. Access to Receiving Waterbody

c. Communications and Control

d. Training Exercises and Updating Procedures

APPENDICES

Appendix 1 - Certifications of the Applicability of Substantial Harm Criteria…… A1-1

Appendix 2 - Fort Bliss Cantonment (Texas)………………………………………. A2-1

Appendix 3 - Biggs Army Airfield (Texas)…………………………………………… A3-1

Appendix 4 - Texas Army National Guard Facility…………………………………. A4-1

Appendix 5 - William Beaumont Army Medical Center (Texas)…………………...A5-1

Appendix 6 - Dona Ana Range (New Mexico)……………………………………… A6-1 iv

FOR OFFICIAL USE ONLY

Appendix 7 - Orogrande Range (New Mexico)……………………………………...A7-1

Appendix 8 - McGregor Range (New Mexico)……………………………………… A8-1

Appendix 9 - Regulatory Requirements……………………………………………...A9-1

Appendix 10 - Industry Standards………………………………………………….. A10-1

Appendix 11 – References………………………………………………………….. A11-1

Appendix 12 - SPCC Equipment Guidance Forms………………………………. A12-1

LIST OF TABLES

Table 1-1 Potential Spills Prediction Information

Table 1-2 Fort Bliss Key Contact Information

Table 1-3 Plan Cross Reference with SPCC Rule

Table 2-1 Levels of Spills

Table 2-2 Texas and New Mexico Reportable POL Spill/Release Quantities

LIST OF FIGURES

Figure 1-1 Fort Bliss Facility Locations (40 CFR 112.7(a)(3))

Figure 1-2 Modular fuel systems (shown in green)

Figure 1-3 Fuel pod on spill pallet

Figure 1-4 Portable Refrigerator Units

Figure 1-5 Mobile Generator

Figure 1-6 Prime Power Unit (PPU)

Figure 1-7 Building 196 AST

Figure 1-8 Building 2969 AST

Figure 3-1 Incident/Spill Response & Clean-Up Report v

FOR OFFICIAL USE ONLY

ABBREVIATIONS AND ACRONYMS

API .................................... American Petroleum Institute AR ..................................... Army Regulation AST ................................... Aboveground Storage Tank

BAAF ................................ Biggs Army Airfield BMP .................................. Best Management Practice BRAC ............................... Base Closure and Realignment

CFR .................................. Code of Federal Regulations CWA ................................. Clean Water Act

DLA .................................. Defense Logistics Agency DPTMS ............................. Directorate of Plans, Training, Mobilization and Security DPW ................................. Directorate of Public Works DPW-ED ........................... Environmental Division, Directorate of Public Works

EO ..................................... Environmental Officer EPA .................................. Environmental Protection Agency

FRP ................................... Facility Response Plan FWPCA ............................. Federal Water Pollution Control Act

GAA .................................. Grease Automotive and Artillery GOCO ............................... Government Owned/Contractor Operated

HAZMAT ........................... Hazardous Material HEMTT ............................. Heavy Expanded Mobility Tactical Truck HMMP ............................... Hazardous Materials Management Plan

IMCOM ............................. Installation Management Command ICP .................................... Incident Command Post

LRC .................................. Logistics Readiness Center

MFS .................................. Modular Fuel System

N ....................................... Tank shell corrosion rate in mils per year NMAC ............................... New Mexico Administrative Code NMED ............................... New Mexico Environment Department NRC .................................. National Response Center vi

FOR OFFICIAL USE ONLY

O&M ................................. Operation and Maintenance OSCP ................................ Oil Spill Contingency Plan OSWER ............................ Office of Solid Waste and Emergency Response OTC .................................. Operational Test Command OWS ................................. Oil-Water Separator

PE ..................................... Professional Engineer PMCS ............................... Preventive Maintenance Checks and Services POL .................................. Petroleum, Oil and Lubricants PPU .................................. Prime Power Unit PST ................................... Petroleum Storage Tank

RCA .................................. Difference between measured tank shell thickness and the minimum required thickness in mils RQ .................................... Reportable Quantity

SAP .................................. Satellite Accumulation Point SPCC ................................ Spill Prevention, Control and Countermeasure [Plan] STI .................................... Steel Tank Institute

TAC .................................. Texas Administrative Code TCEQ ................................ Texas Commission for Environmental Quality TM ..................................... Technical Manual TPU ................................... Temporary Portable Unit TXANG ............................. Texas Army National Guard

UFC .................................. Unified Facilities Criteria UL ..................................... Underwriters Laboratories ULSD ................................ Ultra Low Sulfur Diesel US ..................................... United States UST ................................... Underground Storage Tank

WBAMC ............................ William Beaumont Army Medical Center

GARRISON COMMANDER APPROVAL (40 CFR 112.7)

As the Garrison Commander, I approve the Fort Bliss Spill Prevention, Control and Countermeasure (SPCC) Plan. As required by 40 CFR 112, Oil Pollution Prevention, I am at the level of authority to commit the necessary resources to implement the prescribed management procedures and required improvements to ensure compliance with applicable federal and state laws. In the event of an accidental or otherwise unauthorized release of oil on Fort Bliss, I will commit the personnel, materials and equipment required to expeditiously control and remove any quantity of discharged oil that may be harmful.

The Director, or the Acting Director, of the Directorate of Public Works is a duly authorized representative of the undersigned and is empowered to sign Resource Conservation and Recovery Act, Clean Water Act and Safe Drinking Water Act permit documentation and to make any certification required by federal or state statute or regulation. This certifications/signatory authority includes: notices of intent to obtain permit coverage, plans, reports and other records requiring signature of certification of an authorized representative. The individuals occupying the indicated positions will ensure that qualified personnel gather and evaluate the information submitted. They will also certify that the information presented is, to the best of their knowledge and belief, accurate and complete.

MURPHY

COL, AV

manding

DESIGNATED POSITION ACCOUNTABLE FOR SPILL PREVENTION

The Director, Directorate of Public Works (DPW), is the designated individual responsible for the oil spill prevention program on Fort Bliss.

In this capacity, the Director, DPW, is responsible for implementing a program to monitor compliance across Fort Bliss with the provisions of 40 CFR 112, relevant Texas regulations, associated Army Regulations and this SPCC Plan. As may be required, the Director, DPW, will bring to the attention of senior Fort Bliss leadership—via the established chain-of-command as appropriate—any deficiency, non-conformance or concern that cannot otherwise be resolved at his/her level.

VII

viii

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x xi

SPCC PLAN REVIEW LOG

Plan Reviewed /Amended By:

Date Action

(Review/Amendment)

PE

Certification Required?

(Yes/No)

The Thrival Company

November

5-Year Review Yes xii

FOR OFFICIAL USE ONLY

PART 1. INTRODUCTION (40 CODE OF FEDERAL REGULATIONS (CFR)

112(a)(1))

1. Purpose of SPCC Plan

a. This SPCC Plan, hereafter referred to as “this Plan,” has been prepared in accordance with 40 CFR 112. It describes the policies and procedures that are implemented at Fort Bliss to prevent the discharge of harmful quantities of oil, of any kind or any form, into the navigable waters of the United States (U.S.).

b. Specifically, this Plan details the following:

(1) Operating procedures that will be implemented on Fort Bliss to prevent the accidental discharge of oil from regulated storage facilities and equipment;

(2) Control measures that must be installed to preclude contamination of the environment due to an accidental or unauthorized discharge of oil; and

(3) Countermeasures that will be employed to contain and mitigate a release of oil into the navigable waters of the U.S.

2. Scope

The concept of operation detailed in this Plan conforms to federal, state and U.S.

Army requirements regarding oil pollution prevention to include the following regulations:

40 CFR 109, Criteria for State, Local and Regional Oil Removal Contingency Plans

40 CFR 110, Discharge of Oil 40 CFR 112, Oil Pollution Prevention Title 30, Texas Administrative Code (30 TAC), Environmental Quality, where applicable Title 20, New Mexico Administrative Code (20 NMAC), Chapter 5, Petroleum

Storage Tanks, where applicable Army Regulation (AR) 25-55, Department of Army Freedom of Information Act

Program, 1 November 1977 Steel Tank Institute (STI) SP001, Standard for the Inspection of Aboveground

Storage Tanks American Petroleum Institute (API) 653, Tank Inspection, Repair, Alteration and Reconstruction Unified Facilities Criteria (UFC) 3-460-03, Operation and Maintenance (O&M):

Maintenance of Petroleum Systems AR 200-1, Environmental Protection and Enhancement

The discussion of regulation requirements and industry standards, as well as a list of references, are located in Appendices 9-11, respectively.

3. Applicability

a. This Plan is applicable to all Fort Bliss units including tenant units, other federal agencies and supporting government contractors and their subcontractors that handle oil on Fort Bliss in containers having a capacity of 55 gallons or more.

b. “Oil” means oil of any kind or in any form including, but not limited to: fats, oils or greases of animal, fish or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits or kernels; and other oils and greases including petroleum, fuel oil, sludge, synthetic oils, mineral oil, oil refuse or oil mixed with wastes other than dredged spoil.

c. Cognizant government offices must include the requirements of this Plan in requirements packages, solicitations and contracts entailing the handling and management of oil and any associated storage tank, container and item of oil containing equipment having a capacity of 55 gallons or more.

4. Description of Fort Bliss (40 CFR 112.7(a)(3))

a. Location and Setting

(1) Fort Bliss is a United States Army post encompassing an area of 1.12 million acres extending east from El Paso, Texas, 45 miles north to New Mexico’s White Sands Missile Range and 75 miles northeast to New Mexico’s Lincoln National Forest. Fort Bliss provides the largest contiguous tract of restricted air space and maneuver area which are comprised of the McGregor, Dona Ana and Orogrande Ranges. The Fort Bliss Cantonment, Biggs Army Airfield (BAAF), Texas Army National Guard (TXANG) Facility, William Beaumont Army Medical Center (WBAMC) (Texas) areas are located within the limits of El Paso County, Texas.

(2) The installation is located in the westernmost corner of Texas within the Chihuahuan Desert at the confluence of Texas, New Mexico and Mexico, nestled between the Franklin Mountains and the Rio Grande.

b. Mission

(1) Organizationally, Fort Bliss falls under the United States Installation Management Command (IMCOM) and it is home to the 1st Armored Division which serves as the host unit. With the implementation of the 2005 Defense Base Closure and Realignment Commission (BRAC) recommendations, Fort Bliss was transformed into a heavy armor training post and has seen an increase of over

FOR OFFICIAL USE ONLY

16,000 in its military and civilian workforce since then.

(2) Among Fort Bliss’ missions are the following:

Conduct live fire exercises of nearly every type of Army weapon;

Accommodate the testing of armored tanks and other military equipment;

Host joint military exercises with other U.S. and foreign units;

Provide anti-aircraft and missile defense capabilities;

Host a number of maintenance crews and supply units;

Operate a military airfield; and Operate a secured drone airfield.

5. Operational Definition of “Facility” (40 CFR 112.7(a)(3))

a. This Plan has been crafted as a multi-facility Plan for the portions of the base located in Texas and New Mexico. The Texas facility is comprised of the following four areas of the base:

(1) Fort Bliss Cantonment (Texas);

(2) Biggs Army Airfield (Texas);

(3) Texas Army National Guard Facility (Texas); and

(4) William Beaumont Army Medical Center (Texas).

The New Mexico facility is comprised of the following three areas of the base:

(1) Dona Ana Range (New Mexico);

(2) Orogrande Range (New Mexico); and

(3) McGregor Range (New Mexico).

b. A map of Fort Bliss showing the Fort Bliss-Texas and Fort Bliss-New Mexico facilities is in Figure 1-1. Maps and tables providing estimates of the potential number, types of Petroleum, Oil and Lubricants (POL) and anticipated storage capacities of mobile and bulk storage containers specific to each of these two facilities (seven areas) in this Plan are shown in Appendices 2-8.

c. Appendix 1 includes Certifications of the Applicability of Substantial Harm Criteria for Fort Bliss-Texas and Fort Bliss-New Mexico facilities.

d. Appendices 2-8 detail area-specific information to include area description, exempt USTs, transfer stations and connecting pipes, description of regulated oil storage facilities, security, map and inventory of regulated oil storage containers.

Figure 1-1. Fort Bliss Facility Locations (40 CFR 112.7(a)(3))

6. Evaluation of Discharge Potential

Fort Bliss is located in an arid region with no perennial creeks or streams.

The only navigable waterway, the Rio Grande, is located at least two and one-half miles from the southernmost Fort Bliss boundary in Texas and farther yet from the nearest regulated oil containing equipment. There are no navigable waters located on or adjacent to Fort Bliss range facilities in New Mexico. As a result, the likelihood that a discharge from any oil container or facility on Fort Bliss in Texas or New Mexico would reach a navigable water is extremely low. To further ensure that oil spills are adequately contained, Fort Bliss employs best management practices (BMPs), when practicable.

a. Oil Storage on Fort Bliss (40 CFR 112.7(a)(3)(i))

SPCC-regulated storage and handling of oil includes ground vehicle and aircraft fueling and maintenance, emergency and mobile power generation, cooking oil storage, elevators and oil-containing transformers owned and operated by Rio Grande Electric Cooperative, Inc. and El Paso Electric Company.

(1) All SPCC-regulated equipment is constructed of materials, typically steel or plastic, which are compatible with the material stored.

(2) The types of oil stored in bulk on Fort Bliss typically include both virgin and used/contaminated forms of jet fuel, diesel fuel, gasoline, motor oil, hydraulic oil, transformer oil and cooking oil. The specific size, contents and location of each storage container, to include potential discharge volumes and direction of flow, are detailed in Appendices 2-8.

(3) The number and status of aboveground oil storage tanks on Fort Bliss changes regularly as the mission of the post evolves and as infrastructure improvements are made. Accordingly, DPW-ED maintains an electronic inventory of aboveground oil storage tanks subject to this Plan. This electronic inventory, which is continuously updated to reflect the status of oil storage tanks on the installation, is incorporated into this Plan by reference.

b. Practicability of Secondary Containment (40 CFR 112.7(d)) Fort Bliss has determined that, in general, secondary containment is impracticable for the following equipment at the facility motor pools:

Modular Fuel Systems (MFSs);

Fuel pods;

Portable refrigerator units; and Mobile generators/Prime Power Units (PPUs).

FOR OFFICIAL USE ONLY

A discussion of impracticability for each of these pieces of equipment is below.

(1) MFSs are 2,500-gallon fuel tanks that are mounted inside steel racks. MFSs may be mounted on trucks and trailers for transport, as shown in Figure 1-2. When deployed in the field, they are removed from the trucks/trailers and placed directly on the ground. The MFSs are then linked together via hoses with other MFSs and a rack-mounted pump module to form a mobile fueling system. When the MFSs are left on trucks and trailers, they are considered mobile refuelers and do not require sized secondary containment. However, when placed directly on the ground, MFSs are considered portable bulk storage tanks and require sized secondary containment.

Figure 1-2. Modular fuel systems (shown in green).

When not deployed in the field, MFSs are housed and maintained at their designated motor pool at the Fort Bliss facility. Motor pool lots have rectangular bermed concrete containment areas that are sized to hold 5,000-gallon tankers lined up side-by-side. Because MFSs weigh over 25,000 pounds when full, they cannot be placed in the bermed containment areas, nor can pop-up berms be used without damaging the containment areas beyond repair. The cost of repairing/replacing containment areas and pop-up berms at such a high rate of frequency is impracticable. Also, due to the limited space in the motor pool lots, large drive-in containment areas frequently used in bulk fueling facilities cannot be constructed to contain this equipment. Based on this, sized secondary containment of MFSs is considered impracticable.

(2) Fuel pods, also known as temporary portable units (TPUs), are single-walled oil tanks, having a typical capacity ranging from 500 to 600 gallons. When fuel pods are left on trucks and trailers, they are considered mobile refuelers and do not require sized secondary containment. However, when not mounted, they are considered portable bulk storage tanks and require sized secondary containment. A photo of a fuel pod is shown in Figure 1-3.

Figure 1-3. Fuel pod on spill pallet.

When not deployed in the field, fuel pods are housed and maintained at their designated motor pool at the Fort Bliss facility. While at motor pools, they are drained and labeled “empty”. Like MFSs, fuel pods cannot be placed in the bermed containment areas nor can pop-up berms be constructed without damaging the containment areas beyond repair. The cost of repairing/replacing containment areas and pop-up berms at such a high rate of frequency is impracticable. Also, due to the limited space in the motor pool lots, large drive-in containment areas frequently used in bulk fueling facilities cannot be constructed to contain this equipment. Based on this, sized secondary containment of fuel pods is considered impracticable.

(3) Portable refrigerator units are used to provide refrigeration for food and other perishable items when deployed in the field. When not deployed in the field, they are housed and maintained at their designated motor pool at one or more Fort Bliss facilities. They are powered by an onboard diesel generator that is fed by a 75-gallon fuel tank mounted on the exterior, front facing side of the trailer. The generator portion of a portable refrigerator unit is in part a bulk storage container that must have sized secondary containment. A photo of portable refrigerator units is shown in Figure 1-4. The single-walled fuel tank does not have onboard double containment. Due to limited space between the trailer and its accompanying truck, it is not feasible to construct a secondary containment shell underneath the tank.

The only alternatives are to set up a pop-up berm under the trailer or tank portion of the trailer or place the entire trailer in a bermed secondary containment area. Like the MFSs, the placement of portable refrigerator units in pop-up berms would cause them irreparable damage after only a few uses. The cost of repairing/replacing pop up berms at such a high rate of frequency is impracticable.

Figure 1-4. Portable Refrigerator Units.

Although it is possible to place portable refrigerator units in the bermed containments at the motor pools, Fort Bliss parks vehicles with much higher oil volumes, such as mobile refuelers and other portable containers, in these containments because they pose a greater threat in case of a spill. Bermed containment space is limited and there are a large number of vehicles in these motor pools; therefore, it would not be practical to use this containment space for this lower-risk equipment. Based on this, sized secondary containment of portable refrigerator units is considered impracticable.

(4) Mobile generators/PPUs – are used to provide power to various equipment in the field. When not deployed in the field, they are housed and maintained at their designated motor pool at one or more of the Fort Bliss facilities.

This equipment contains fuel tanks that vary from 20 to 200 gallons in capacity, depending on the power rating and configuration. Because they are gen-sets, those that contain 55 gallons or more are in part bulk storage containers that must have sized secondary containment. Photos of a mobile generator and a PPU are shown in Figures 1-5 and 1-6.

The single-walled fuel tanks do not have onboard double containment. Due to limited space inside the generator housing, it is not feasible to construct a secondary containment shell underneath the tank. The only alternatives are to set up a pop-up berm under the equipment or tank portion of the equipment or place entire equipment in a bermed secondary containment. Like the MFSs, the placement of this equipment in pop-up berms would cause them irreparable damage after only a few uses. The cost of repairing/replacing them at such a high rate of frequency is impracticable.

Figure 1-5. Mobile generator.

Figure 1-6. Prime Power Unit (PPU).

While it is possible to place PPUs in the bermed containments in the motor pools, Fort Bliss chooses to place vehicles with much higher oil volumes, such as mobile refuelers and other portable containers in these containments because they pose a greater threat to the environment in case of a spill. Because bermed containment space is limited and there are a large number of vehicles in these motor pools, it would not be practical to use this containment space for lower-risk equipment.

Based on this, sized secondary containment of mobile generators and PPUs is considered impracticable.

Common threads among the impracticability determinations of the above four equipment types are cost and risk. Motor pools at military installations are extremely busy areas which house many vehicles in a relatively small space. Because of the large number of mobile refuelers, mobile containers and portable containers, bermed area space is in high demand, especially during periods where military training activity is high. Available bermed containment space must be reserved for equipment that poses the highest risk of discharge to the environment.

The same four types of equipment discussed above are also used on the ranges located on Fort Bliss in New Mexico. On the ranges, this equipment cannot be

FOR OFFICIAL USE ONLY

provided secondary containment with pop-up berms due to reasons discussed above. To achieve more realistic training, military units adhere to the “train as we fight” guidelines, which limits Soldiers to what they would actually do in theater.

Because secondary containment would detract from mission readiness, providing it in these range areas is impracticable. It should be noted that the risk of spills reaching navigable waters is extremely unlikely as there are no navigable waters near these training areas.

Fort Bliss is applying impracticability for portable equipment used on the ranges because secondary containment is infeasible to use and maintain during military exercises.

(5) An aboveground storage tank (AST), located at Building 196 of the Main Cantonment, is a single-walled tank with no secondary containment. The AST, which contains used cooking oil, is built into the building, so it is not possible to place the entire tank in secondary containment. This tank is shown in Figure 1-7. While it is possible to rebuild the entire tank system, the capital required to pay for this is not available. Secondary containment of this tank is therefore deemed to be impracticable.

(6) An AST, located at Building 2969 of the Main Cantonment, is a single-walled tank with no secondary containment that contains used cooking oil. This tank is shown in Figure 1-8. While it is possible to buy a double-walled tank, the capital required to pay for this is not available. Secondary containment of this tank is therefore deemed to be impracticable.

Figure 1-7. Building 196 AST.

Figure 1-8. Building 2969 AST.

c. Requirements of Impracticability

Pursuant to 40 CFR 112.7(d) and the SPCC Guidance for Regional Inspectors, December 16, 2013, a determination of impracticability requires:

More stringent periodic integrity testing of bulk storage containers and periodic integrity and leak testing of valves and piping than required for passive secondary containment.

An Oil Spill Contingency Plan following the provisions of 40 CFR part 109 along with a written commitment of manpower, equipment and materials.

Due to the portable nature of this equipment, portable containers only require visual inspections as a determination of integrity which Fort Bliss is completing.

Regarding stringency when secondary containment cannot be provided, preventative Maintenance Checks and Services (PMCS) inspections provided by military units are extensive and include inspections of valves and piping. These are done weekly, which is four times the typical inspection frequency. Because visual inspections constitute integrity testing per the EPA guidance and the integrity testing requirement of impracticability has been met under this Plan for the equipment listed below:

MFSs;

Fuel pods;

Portable refrigerators units;

PPUs;

Building 196 AST; and Building 2969 AST.

FOR OFFICIAL USE ONLY

Note that employees will inspect the Building 196 and 2969 ASTs that do not have secondary containment, at least twice per month.

(1) Periodic integrity and leak testing of valves and piping

Because the above portable equipment contains minimal piping and valves, visual inspection of the piping and valves constitute both adequate integrity and leak testing under this Plan. Additionally, the more frequent, weekly inspections of piping and valves ensure that the impracticability requirement for more stringency in lieu of secondary containment is met.

(2) Oil Spill Contingency Plan (OSCP)

An OSCP is required to ensure immediate response, control and removal of any quantity of oil discharged that may be harmful and must be prepared in accordance with 40 CFR 109, unless the facility has submitted a Facility Response Plan (FRP) under §112.20.

Fort Bliss has prepared an OSCP that covers SPCC-regulated equipment where secondary containment is deemed to be impracticable (see Part 3). Per the OSCP, where impracticable equipment is maintained, adequate spill kits and absorbent material is kept readily available for use in the event of a spill.

d. Discharge Potential (40 CFR 112.7(b))

Where experience indicates a reasonable potential for equipment failure, this Plan must include a prediction of the direction, rate of flow and total quantity of oil which could be discharged from the facility as a result of each type of major equipment failure.

The most common spills occur during refueling operations in motor pools. These spills are typically less than 50 gallons and are readily contained and cleaned up via pads and socks in nearby spill kits as well as dry sweep located in motor pool buildings.

The largest volume spills may occur as a result of a rollover of a mobile refueler while in transit. These incidents could result in spills of up to 8,000 of gallons of oil.

In the rare case that this would occur, the U.S. Army Corps of Engineers (USACE) has contracted with an external spill cleanup strike team to support Fort Bliss in case it is needed. The City of El Paso may also provide support to Fort Bliss if it is necessary.

Even in the case of large oil spills, it is highly unlikely that spills would reach navigable waters due to the intensive and immediate spill response and cleanup efforts as well as the distance that a spill would need to travel through developed

FOR OFFICIAL USE ONLY

areas to reach the Rio Grande.

Table 1-1 provides additional details of these scenarios. While the directional information in Table 1-1 is shown as variable, flow direction specific to each SPCC-regulated tank/container is shown in the inventory tables in Appendices 2-8.

Table 1-1 – Potential Spills Prediction Information

Failure Scenario

Flow Direction*

Flow Rate

(gpm)

Total Quantity Released (gallons) Notes

Hose or fitting failure during motor pool fueling

Varies 100 50 Oil flow must be shut off within 30 seconds, worst case.

Vehicle-to-container collisions in motor pools or vehicle-to-vehicle collisions while in transit

Varies Varies 50 Flow rate depends on size of rupture.

Mobile fueler rollover while in transit

Varies Varies 100 to 8,000 Flow rate depends on size of rupture. Entire contents of refueler could be spilled.

* See Material Inventory Tables in Appendices 2-8.

7. Fort Bliss Key Contact Information (40 CFR 112.7(a)(3)(vi)).

A listing of key contacts pertinent to the scope of this plan is in Table 1-2.

FOR OFFICIAL USE ONLY

Table 1-2. Fort Bliss Key Contact Information

Fort Bliss Key Contact Information

Spill Response Contact List

Fort Bliss Fire Department 911 for on-Fort Bliss land lines or

915-568-1117

Fort Bliss On-Scene Coordinator 911 for on-Fort Bliss land lines or 915-744-9545/2115

Directorate of Public Works, Environmental Division

915-568-1385/6697

Fort Bliss Operations Center 915-569-6951/6952

Fort Bliss Spill Response Team 915-637-6881

Directorate of Public Works 915-568-6200/5919

Directorate of Health Services 915-568-7016

Public Affairs 915-568-2497/4601 (Duty hours)

915-637-6821 (Non-duty hours)

Provost Marshall 915-568-2115

Safety Office 915-744-8457/8504/8513

Staff Judge Advocate 915-525-0061

On-Installation Contacts

Operations Center for Directorate of Plans, Training, Mobilization and Security

(DPTMS)

915-569-6957/6951 (Duty hours)

915-568-1501/4228 (Non-duty hours)

Military Police 911 for on-Fort Bliss land lines or 915-568-2115/2116/2117

Ambulance 911 for on-Fort Bliss land lines

William Beaumont Army Medical Center

915-742-2121

Off-Installation Emergency Contacts

National Response Center 800-424-8802

U.S. EPA Region 6 866-372-7745

Texas Commission on Environmental Quality (TCEQ)

800-832-8224 (24-hr Emergency Hotline)

512-239-2507 (General hotline)

512-463-7727 (General hotline alternate)

915-834-4949 (Region 6)

FOR OFFICIAL USE ONLY

Fort Bliss Key Contact Information

Off-Installation Emergency Contacts (Continued)

USACE Rapid Response Program Manager

402-995-2191 (Office)

402-885-0655 (Cell)

El Paso County Sheriff 915-546-2280

City of El Paso Police Department 915-832-4400

Texas Rangers, (El Paso) 915-834-7664

New Mexico Environment Department

505-827-9329 (24-hr Emergency Hotline)

866-428-6535 (Non-Emergency Spill)

505-476-4397 (Petroleum Storage Bureau)

New Mexico State Police 505-827-9126

CHEMTREC 800-424-9300

8. Legal Considerations

a. This Plan has been prepared to comply with applicable federal, state, local and U.S. Army regulations available at the time of preparation and it is subject to revision as those requirements change.

b. Fort Bliss DPW-ED will review this Plan every year and upon notification of changed requirements and update it as required to ensure its currency, effectiveness and legal sufficiency.

c. If there is a conflict between this Plan and regulatory requirements, the regulatory requirements will take precedence.

d. This Plan may prescribe management requirements at Fort Bliss that are more stringent than associated regulations.

9. Security Instructions

a. This Plan is “FOR OFFICIAL USE ONLY” and has not been authorized for unrestricted distribution to the public. All Fort Bliss personnel, contractors and other persons whose activities are regulated by this Plan and who therefore need access to this Plan are restricted from releasing information contained herein to the public.

The information contained in this document may be distributed in accordance with AR 25-55, “Department of Army Freedom of Information Act Program,” 1 November 1977, upon receipt of a formal request. Operational Security and Communication Security are incorporated into this Plan and must be executed by anyone using this Plan.

FOR OFFICIAL USE ONLY

b. Reproduction of this document in whole or in part is authorized only to assist applicable Fort Bliss and tenant organizations in the development of supporting directives, procedures or operating instructions.

10. Location of Plan (40 CFR 112.3(e))

a. The master copy of this Plan with original signatures as well and hard and electronic copies will be maintained by the Department of Public Works, Environmental Division, in Building 622 on Fort Bliss between Taylor and Doniphan Roads.

b. Copies of this Plan will be provided by DPW-ED to appropriate supervisory personnel at each of the seven facilities.

11. Plan Review (40 CFR 112.5(a) and (b))

a. Scheduled Reviews

Although 40 CFR 112.5(b) requires that this Plan be reviewed every five-years, Fort Bliss will review this Plan at least once a year due to the high likelihood that amendments will be required more frequently.

b. Amendments

(1) Fort Bliss must periodically review and evaluate this Plan for any change in the facility design, construction, operation, or maintenance that materially affects the facility’s potential for an oil discharge, including, but not limited to:

Commissioning of containers;

Reconstruction, replacement or installation of piping systems;

Construction or demolition that might alter secondary containment structures;

Changes of product or service, revisions to standard operation, modification of testing/inspection procedures and use of new or modified industry standards; or

Maintenance procedures.

Amendments to this Plan made to address changes of this nature are referred to as technical amendments and must be certified by a Professional Engineer (PE).

(2) Non-technical amendments can be done (and must be documented on the revision sheet at the front of this Plan) by the facility owner and/or operator. Non-technical amendments include the following:

FOR OFFICIAL USE ONLY

Change in the name or contact information (i.e., telephone numbers) of individuals responsible for the implementation of this Plan; or

Change in the name or contact information of spill response or cleanup contractors.

(3) Fort Bliss must make the amendments to this Plan as soon as possible, but no later than six months after the change occurs. The DPW-ED POL Program Manager, Environmental Division is responsible for initiating and coordinating revisions to this Plan.

Each review and associated amendment of this Plan will be recorded by DPW-ED in the SPCC Plan Review Log on page xi.

12. Cross-Reference with SPCC Rule Provisions (40 CFR 112.7).

Table 1-3 provides a cross-reference between those topics required by 40 CFR 112 and this Plan.

Table 1-3. Plan Cross Reference with SPCC Rule

Provision

(40 CFR)

Plan Requirement

Page or Part Number in this Plan

112.3(d) Professional Engineer Certification p. xi

112.3(e) Location of SPCC Plan 1.10

112.4(a) Spill Reporting 2.8.b

112.5(a) and (b)

Plan Review 1.11

112.7 Management Approval p. ix

112.7 Cross-Reference with SPCC Rule 1.12

112.7(a)(1) Compliance with Applicable Requirements

112.7(a)(2) Deviations from Applicable Requirements

NA

112.7(a)(3) General Facility Information, Facility Diagram

1.4, 1.5, A2.1, A3.1, A4.1, A5.1, A6.1, A7.1, A8.1

112.7(a)(3)(i) Type of Oil 1.6.a(1), A2- A8 Tables

112.7(a)(3)(ii) Discharge Prevention Measures 2.10

FOR OFFICIAL USE ONLY

Provision

(40 CFR)

Plan Requirement

Page or Part Number in this Plan

112.7(a)(3)(iii) Drainage Controls 2.6

112.7(a)(3)(iv) Countermeasures 3

112.7(a)(3)(v) Disposal 3

112.7(a)(3)(vi) Contact List 1.7, 3

112.7(a)(4) Discharge Notifications 3

112.7(a)(5) Discharge Response 3

112.7(b) Potential Discharge Volumes and Direction of Flow

1.6.d, A2-A8 Tables

112.7(c) Containment and Diversionary Structures

2.1, 2.2, 2.3, 2.4, A2-A8 Tables

112.7(d) Practicability of Secondary Containment 1.6.b, 3

112.7(e) Inspections, Tests and Records 2.9

112.7(f) Personnel Training and Discharge Prevention Procedures

2.10

112.7(g) Security

2.10.b(5), A2.5, A3.5, A4.4, A5.4, A6.3, A7.3, A8.3

112.7(h) Loading/Unloading Rack Requirements NA

112.7(i) Brittle Fracture Evaluation NA

112.7(j) Conformation with Applicable State and Local Requirements

A9.2

112.8(b) Facility Drainage 2.6

112.8(c)(1) Construction 2.1.a(2)

112.8(c)(2) Secondary Containment 2.1a(3), A2- A8 Tables

112.8(c)(3) Drainage of Diked Areas 2.6

112.8(c)(4) Corrosion Protection 2.10.b(4)

112.8(c)(5) Partially Buried and Bunkered Storage Tanks

NA

112.8(c)(6) Inspection and Testing 2.9

112.8(c)(6) Facility Inspection Checklists 2.9.b

FOR OFFICIAL USE ONLY

Provision

(40 CFR)

Plan Requirement

Page or Part Number in this Plan

112.8(c)(7) Heating Coils NA

112.8(c)(8) Overfill Prevention System 2.1.a(3), 2.10.b(2), 2.9.d(3)

112.8(c)(9) Effluent Treatment Facilities NA

112.8(c)(10) Visible Discharges 2.7

112.8(c)(11) Refuelers and Portable Containers 2.2, 2.9.f, 2.9.g, A2, A3, A4, A5, A12

112.8(d) Transfer Operations 2.10.b(1)

112.20(e) Certification of Substantial Harm Criteria A1

109 Oil Spill Contingency Plan (OSCP) 3

PART 2: COMPLIANCE WITH REQUIREMENTS (40 CFR 112.7(A)(1) AND 8(A))

1. Bulk Oil Storage Containers

a. AST Compliance

(1) Responsibility for AST Oversight

(a) Each bulk oil storage tank on Fort Bliss subject to the provisions of 40 CFR 112 must be assigned to a military unit or tenant that will be responsible for ensuring the tank complies with federal and applicable state regulations, U.S. Army policy and this Plan. Normally, the designated storage tank owner/operator will be the Army or other government agency responsible for maintaining, replenishing and operating the tank. If tank compliance with this Plan is conducted through a contractor, the owning government agency must ensure contractual mechanisms are in place so compliance status can be regularly verified. It is important to remember that responsibilities required by law or regulation cannot be changed by contract and that the owner may be liable for an operator’s or contractor’s failure to comply with applicable laws and regulations.

(b) In the event the responsible owner/operator for a storage tank cannot be determined—for whatever reason—the tank will be placed under the purview of the DPW-ED or be initiated for permanent closure as defined in Part 2.1.a.(5). The final decision relating to the assignment of owner/operator responsibility for a storage tank rests with the Director, Directorate of Public Works.

(c) Responsible owners/operators of storage tanks subject to this Plan will notify DPW-ED of substantive changes in the status of any storage tank subject to this Plan as they occur.

(d) Any oil storage tank subject to this Plan that is found to be leaking will be taken out of service 24 hours after discovery by the responsible owner/operator and reported to DPW-ED. If any oil escapes secondary containment and enters the environment, DPW-ED will notify regulatory agencies as required per applicable federal and state regulations.

(e) DPW-ED will verify the compliance status of all storage tanks subject to this Plan at least annually.

(2) Tank Construction (40 CFR 112.8(c)(1))

All bulk oil storage containers on Fort Bliss must be constructed in accordance with industry standards.

FOR OFFICIAL USE ONLY

(3) Secondary Containment for Bulk Oil Storage Tanks (40 CFR 112.7(c) and 8(c)(2))

All regulated bulk oil storage tanks on Fort Bliss—except those that are “permanently closed” as defined in Part 2.1.a.(5) or whose secondary containment is deemed impracticable—must be provided or configured with sized, passive secondary containment. As discussed in Part 1.6.b., sized secondary containment for tank rack modules, fuel pods, refrigerated trailers and mobile generators/PPUs is impracticable when located at motor pools and when tactically deployed.

(a) If single-walled bulk oil storage tanks utilize diked containment, the containment must be sized to hold the volume of the largest tank in the containment plus at least an additional 10 percent of freeboard to accommodate precipitation.

The dike must be constructed of materials that can contain a release of oil until the release can be cleaned up.

(b) After each major rainfall event, the respective Environmental Officer (EO) trained in Plan procedures must inspect the containment area to determine if the rainwater must be removed and to assess whether oil, an oil sheen or other contamination is present, as discussed in Part 2.6.

(4) Secondary Containment for Field-Constructed Tanks (40 CFR 112. 7(c) and 8(c)(2))

(a) Concrete or earthen diking is used to provide secondary containment for the field-constructed tanks at Biggs Army Airfield. Details regarding the secondary containment provided for these field-constructed oil storage tanks are included in Appendix 3 of this Plan.

(b) The respective EO trained in Plan procedures must inspect the containment area to determine if the rainwater must be removed and to assess whether oil, an oil sheen or other contamination is present, as discussed in Part 2.6.

This inspection must be performed after each major rainfall event and as part of the Routine In-Service Inspection prescribed by API 653.

(5) Inactive and Permanent Closure of Oil Storage Tanks

(a) There are a number of inactive bulk oil storage tanks on Fort Bliss at any given time. ASTs at Fort Bliss motor pools often become inactive when the occupying unit is deployed. These tanks are emptied (not including sludge or three inches or less of residue), dated, labeled “Inactive” and locked to prevent anyone from adding or removing any material. Inactive tanks may be easily reactivated within 2 to 24 months, depending on unit return or reassignment of another unit.

Inactive tanks are subject to quarterly inspections.

FOR OFFICIAL USE ONLY

(b) If a tank is inactive for more than two years and not expected to be reactivated, it may make sense to permanently close it. A permanently closed tank is no longer subject to SPCC requirements and, is thus, no longer a regulatory burden for the facility. To meet the definition of permanently closed, per 40 CFR 112.2:

If there is manway access to the tank, 100% of contents will be removed, if there is no manway access, less than 3 inches of product will remain in the tank;

All connecting lines and piping must be disconnected and blanked off;

All valves—except ventilation valves—must be closed and locked; and A conspicuous sign must be posted on the tank stating it is permanently closed and noting the date of the closure.

(c) TCEQ 30 TAC, part 334.127(d), requires written notice within 30 days of any change in the operational status of a registered tank, including, but not limited to, permanent closure.

(d) DPW-ED will make any state required notifications for registered tanks.

(e) Note that permanently closing a tank does not preclude reactivating the tank at some future date.

b. Secondary Containment for Drum Storage (40 CFR 112. 7(c) and 8(c)(2))

(1) Drums, which have a capacity of 55 gallons, are portable containers that are robustly designed to maintain their integrity when moved frequently. Drums containing oil are considered bulk storage containers and must be provided a passive form of secondary containment.

(2) Accordingly, drums will be placed on spill pallets or in a suitably curbed area having sufficient capacity to contain the contents of the largest container on/in the secondary containment.

2. Secondary Containment for Mobile Refuelers (40 CFR 112. 7(c) and 8(c)(11))

a. Per 40 CFR 112.2, the term “mobile refueler” means a bulk storage container on board a vehicle or towed that is used solely to store and transport fuel for transfer into or from an aircraft, motor vehicle, locomotive, ground service equipment or other oil storage container. In December 2006, the EPA exempted mobile refuelers from the sized secondary containment requirements applicable to bulk storage containers; instead, the general secondary containment requirements at 40 CFR 112.7(c) apply. Specifically, active and passive measures to respond to an oil discharge may be used to comply with the general secondary containment requirement. However, note that the EPA still considers mobile refuelers to be bulk

FOR OFFICIAL USE ONLY

storage tanks and therefore, while it exempts mobile refuelers from the requirements for sized, passive secondary containment, mobile refuelers are not exempt from the inspection/testing requirements in 40 CFR 112.8(c)(6).

b. Fort Bliss maintains a fleet of approximately 450 mobile refuelers. This fleet includes 350 Heavy Expanded Mobility Tactical Trucks (HEMTTs) having a capacity of 2,500 gallons. The HEMTT refuelers are augmented by fuel tanker trucks having a capacity ranging from 1,500 gallons to 8,000 gallons and by trucks or trailers carrying 500- to 600-gallon fuel pods. Given the nature of refueling operations at Fort Bliss, the number of refuelers at a specific location will vary. Accordingly, a realistic upper limit of the number of refuelers present at a location is provided Appendices 2-8.

c. Active and passive secondary containment can be used for mobile refuelers.

On Fort Bliss, active secondary containment will be afforded by readily available 55-gallon spill kits and passive secondary containment can be afforded by concrete berms, if available, to contain a release of oil due to a typical failure mode and the most likely quantity of oil that would be released.

3. Secondary Containment for Oil-Filled Operational Equipment [40 CFR 112.7(c)]

a. Oil-filled operational equipment is defined as equipment that includes an oil storage container (or multiple containers) in which the oil is present solely to support the function of the apparatus or the device. Oil-filled operational equipment used at Fort Bliss subject to the SPCC rules include elevators and transformers. Active secondary containment is allowed to be used for this equipment.