TE 3 - Spill Prevention Control and Countermeasure (SPCC) Plan.pdf

SPILL PREVENTION, CONTROL, AND

COUNTERMEASURE PLAN FOR

FORT DRUM, NEW YORK

April 2023

Prepared for:

U.S. Army, Fort Drum 11042 Mt. Belvedere Blvd.

Fort Drum, NY 13602

Contract No.: W9124J21D0013 Delivery Order No.: W9124J22F0145

Prepared by:

Stell Eagleview Corporate Blvd Suite 300 Exton, PA 19341

Fort Drum Environmental Division Building 4839, Nininger Street Fort Drum, NY 13602

Fort Drum SPCC Plan Fort Drum, New York

Stell/Fort Drum Environmental ii April 2023

PROFESSIONAL ENGINEER’S CERTIFICATION

40 CFR 112.3(d)

I, James Barbis, attest by means of this certification:

That I am familiar with the requirements of 40 CFR 112;

That an agent of our company familiar with the provisions of 40 CFR 112 has visited and examined the facility;

That this Spill Prevention, Control, and Countermeasure Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and the requirements of 40

CFR 112;

That procedures for required inspections and testing have been established;

and

That this Plan is adequate for the facility.

James Barbis State of New York Professional Engineer Certificate No.

Date

Fort Drum SPCC Plan Fort Drum, NY

Stell/Fort Drum Environmental iii April 2023

TABLE OF CONTENTS

1 General Requirements for Spill Prevention, Control, & Countermeasure

Plans – 112.1, 112.3, 112.4, 112.5, and 112.7 (Subpart A)

1.1 GENERAL - 112.7(A)

1.1.1 FACILITY CONFORMANCE 112.7(A)(1)

1.1.2 EQUIVALENT ENVIRONMENTAL PROTECTION 112.7(A)(2)

1.1.3 PHYSICAL LAYOUT 112.7(A)(3)

1.1.4 PREVENTION AND COUNTERMEASURES 112.7(A) (3) (II-V)

1.1.5 RESPONSE PLANS 112.7(A) (4) AND (5)

1.2 SPILL PREDICTIONS - 112.7(B)

1.3 CONTAINMENT & DIVERSIONARY STRUCTURES 112.7(C)

1.3.1 OIL STORAGE CONTAINERS

1.3.2 LOADING/UNLOADING AREAS – GENERAL CONTAINMENT

1.3.3 BULK AVIATION FUEL SYSTEM

1.3.4 OIL-FILLED OPERATIONAL EQUIPMENT

1.3.5 MOBILE REFUELERS

1.4 IMPRACTICABILITY - 112.7(D)

1.5 INSPECTIONS, TESTS, AND RECORDS - 112.7(E)

1.5.1 INSPECTIONS

1.5.2 TESTS

1.6 PERSONNEL TRAINING & DISCHARGE PREVENTION PROCEDURES -

112.7(F)

1.6.1 TRAINING 112.7(F)(1)

1.6.2 DESIGNATED PERSON 112.7(F)(2)

1.6.3 BRIEFINGS 112.7(F)(3)

1.7 SECURITY - 112.7(G)

1.8 FACILITY TANK CAR & TANK TRUCK LOADING/UNLOADING RACK –

112.7(H)

1.8.1 DRAINAGE 112.7(H)(1)

1.8.2 WARNING OR BARRIER 112.7(H)(2)

1.8.3 INSPECTION 112.7(H)(3)

1.9 BRITTLE FRACTURE EVALUATION - 112.7(I)

1.10 STATE AND ARMY RULES, REGULATIONS, AND GUIDELINES - 112.7(J) . 12

1.11 QUALIFIED OIL-FILLED OPERATIONAL EQUIPMENT - 112.7(K)

1.11.1 HISTORY 112.7(K) (1)

1.11.2 ALTERNATIVE CONTAINMENT 112.7(K)(2)

2 Additional Specific Discharge Prevention & Containment Procedural Requirements - 112.8 (Subpart B)

2.1 GENERAL - 112.8(A)

2.2 FACILITY DRAINAGE - 112.8(B)

2.2.1 RESTRAIN DRAINAGE 112.8(B)(1)

2.2.2 VALVES 112.8(B)(2)

2.2.3 DESIGN 112.8(B)(3)

2.2.4 RETENTION 112.8(B)(4)

2.2.5 TREATMENT 112.8(B)(5)

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2.3 BULK STORAGE CONTAINERS - 112.8(C)

2.3.1 COMPATIBILITY 112.8(C)(1)

2.3.2 SECONDARY CONTAINMENT 112.8(C)(2)

2.3.3 PRECIPITATION DRAINAGE 112.8(C)(3)

2.3.4 COMPLETELY BURIED TANKS 112.8(C)(4)

2.3.5 PARTIALLY BURIED TANKS 112.8(C)(5)

2.3.6 INTEGRITY TESTS 112.8(C)(6)

2.3.7 INTERNAL HEATING COILS 112.8(C)(7)

2.3.8 OVERFILL PREVENTION 112.8(C)(8)

2.3.9 TREATMENT 112.8(C)(9)

2.3.10 VISIBLE DISCHARGES 112.8(C) (10)

2.3.11 MOBILE/PORTABLE CONTAINERS 112.8(C) (11)

2.4 FACILITY TRANSFER OPERATIONS, PUMPING, & FACILITY PROCESS -

112.8(D)

2.4.1 BURIED PIPING 112.8(D)(1)

2.4.2 OUT OF SERVICE PIPING 112.8(D) (2)

2.4.3 PIPE SUPPORTS 112.8(D)(3)

2.4.4 APPURTENANCES 112.8(D)(4)

2.4.5 WARNING 112.8(D) (5)

TABLE OF TABLES

Table 1. Inspection Information Summary

LIST OF APPENDICES

Appendix A: Petroleum Storage Tank Summary Tables

A.1 40 CFR 112 Regulated Petroleum Storage Tanks) ......................................... A-1

A.2 Drum Storage Areas…………………………………………………………...A-2

A.3 Mobile Re-fuelers…………………………………………………………..A-3

A.4 Used Food Grease Containments……………………………………………A-4

A.5 Elevators……………………………………………………………………….A-5

A.6 Portable Generators……………………………………………………………A-6

A.7 Stationary Generators………………………………………………………….A-7

A.8 Transformers…………………………………………………………………..A-8

A.9 UST Exempted………………………………………………………………...A-9

A.10 Oil Circuit Breakers………………………………………………………...A-10

A.11 Portable Fuel Storage Areas…………………………………………….......A-11

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Appendix B: Facility Figures

Map indexing listed on Appendix A’s inventories

Appendix C: Petroleum Storage Tank Management Plan

Appendix D: Inspection Checklists

Checklist 1 2084 Tank Containment Drain Log

Checklist 2 Bulk AST Daily Inspection

Checklist 3 UST Monthly Inspection

Checklist 4 AST Monthly Inspection

Checklist 5 Loading/Unloading Area Daily Inspection

Checklist 6 Tank Truck Daily Inspection

Checklist 7 Cathodic Protection Quarterly Inspection

Checklist 8 Aircraft Fueling Daily Inspection

Checklist 9 Stationary Generator Monthly Inspection

Checklist 10 Transformer Semiannual Inspections

Checklist 11 Oasis Pit inspections

Checklist 12 Containment Pumping Service Log

Checklist 13 HEMTT and Envirohut™ Containment Inspection

Checklist 14 FOG Inspection

Checklist 15 Monthly Monitoring Wells Inspection

Checklist 16 2086 Drain Log for Spill Events

Checklist 17 Portable Generator Monthly Report

Appendix E: Discharge Prevention Training Record

Appendix F: Fort Drum Spill History

Appendix G: Data Sheets and Photos

Appendix H: Regulations

40 CFR 112

40 CFR 280

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6 NYCRR 611 – 614

NFPA 30

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ACRONYMS AND ABBREVIATIONS

% percent AST aboveground storage tank CFR Code of Federal Regulations DOL Directorate of Logistics DOT Department of Transportation DPW Directorate of Public Works ECO Environmental Compliance Officers gpm gallons per minute HEMTTS Heavy Expanded Mobility Tactical Truck ISCP Installation Spill Contingency Plan NY New York NYCRR New York Codes, Rules and Regulations OSHA Occupational Safety and Health Administration OWS oil/water separators POL petroleum, oil, lubricant PSTMP Petroleum Storage Tank Management Plan SPCC Spill Prevention, Control, and Countermeasure STI Steel Tank Institute UST underground storage tank WSAAF Wheeler Sack Army Airfield

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APPLICABLE REQUIREMENTS FROM 40 CFR, CHAPTER I, SUBCHAPTER D,

PART 112 (OIL POLLUTION PREVENTION)

1 GENERAL REQUIREMENTS FOR SPILL PREVENTION, CONTROL,

& COUNTERMEASURE PLANS – 112.1, 112.3, 112.4, 112.5, AND 112.7

(SUBPART A)

Management Approval Fort Drum stores and uses oil, has an oil storage capacity greater than 1,320 gallons, and is located in an area where oil spills could reasonably be expected to discharge oil to navigable waters of the United States.

To address these issues, this Spill Prevention, Control, and Countermeasure (SPCC) Plan and command policy has been developed and certified by a Professional Engineer for Fort Drum, New York (NY). This SPCC Plan must be reviewed and evaluated at least once every five years or whenever a change in the facility design, construction, operation, or maintenance materially affects its discharge potential. These types of technical changes include, but are not limited to, replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of piping systems; construction or demolition that might alter secondary containment structures; changes of product or service; or revision of standard operation or maintenance procedures. Required Plan amendments must be prepared within six months of the change in operation and implemented within six months. If there are any technical amendments to the Plan, then a Professional Engineer must recertify it.

The United States Environmental Protection Agency Regional Administrator may require Fort Drum to amend the SPCC Plan if the facility has discharged more than 1,000 gallons of oil in a single discharge or discharged more than 42 gallons of oil in each of two discharges within any twelve-month period.

This SPCC Plan for Fort Drum has my full approval, and I am at a level of authority to commit the necessary resources to implement this plan as described herein.

Name Title

Signature Date

Stell/Fort Drum Environmental 2 April 2023

1.1 GENERAL - 112.7(A)

1.1.1 FACILITY CONFORMANCE 112.7(A)(1)

Fort Drum is committed to complying with applicable requirements stated in Title 40 Code of Federal Regulations Part 112 (40 CFR 112) as well as Title 6 New York Codes, Rules and Regulations, Part 613 (6 NYCRR 613). To that end, this SPCC Plan has been developed in accordance with applicable federal, state, and local regulations. The objectives of this plan are multifaceted. The first and foremost objective is to prevent oil from being released into the environment and to ensure that the existing controls and operations of oil handling and storage facilities are adequate. Second, comply with federal, state, and local government agencies to ensure public health and welfare are adequately protected from spills. Third, implement controls and countermeasures necessary to reduce adverse environmental impact and expedite cleanup activities in the event of accidental discharge. For all discharges, 911 is immediately notified to ensure rapid response. In order to accomplish all these objectives, documented revisions to procedures and facility upgrades identified in this plan are implemented as stated below:

• Mobile re-fuelers (Heavy Expanded Mobility Tactical Truck [HEMTTS], Modular Fueling Systems, etc.) that contain fuel are parked or stored in areas that would prevent a discharge of oil to the environment. This could include constructed vehicle containment areas or places with covered drains and enough absorbents and attentive personnel to prevent a discharge. Mobile re-fuelers (HEMTTS, Modular Fueling Systems, etc.) that contain de minimis volumes are stored on an impervious surface and do not require secondary containment. See Section 1.3.5 for further discussion.

• The drainage valves of all secondary containment structures are secured in the “closed” position when not in use to prevent accidental discharges.

• Secondary containment structures for mobile re-fuelers or portable storage equipment are inspected on a regular basis to ensure a discharge would not be released through cracks or construction joints in the walls, curbs, or floor.

• When 55-gallons drums are stored in buildings that do not have floor or trench drain systems that would contain a release, the drums are required to be placed on spill containment pallets.

• Fort Drum periodically evaluates consolidation and/or elimination of identical petroleum, oil, lubricant (POL) storage containers located near each other to reduce the regulatory burden (fewer monthly inspections, fewer aboveground storage tank [AST] registrations, and fewer compliance sites) while minimizing POL waste.

• Secondary containment that is provided at P-599 and at the transformer yard, which is located adjacent to the Southern Electrical Substation, is utilized to store standby transformers with greater than 55 gallons of oil (See Section 1.1.3).

1.1.2 EQUIVALENT ENVIRONMENTAL PROTECTION 112.7(A)(2)

Equivalent environmental protection measures have not been implemented at this facility.

1.1.3 PHYSICAL LAYOUT 112.7(A)(3)

Fort Drum is the largest United States (U.S.) Army installation in the Northeast United States and home to the 10th Mountain Division (Light Infantry). Fort Drum is located in Jefferson and Lewis Counties, NY, and is approximately 107,000 acres. Its mission includes command

Stell/Fort Drum Environmental 3 April 2023 of active component units and to provide mobilization, administrative, logistical, and planning support to active, reserve, and tenant units from all services training at Fort Drum.

Due to the facility’s large size (in this case, all of Fort Drum), some areas drain directly to a watercourse and not to a treatment plant. To ensure there are no illicit oil discharges from the facility into adjacent watercourses, the base operates under a general permit for stormwater discharges (MS4).

Navigable waters in the area of Fort Drum include Trout Creek, Sawyer Creek, Pleasant Creek, and Remington Pond (which flow to the Indian River and eventually the Saint Lawrence River) and the Black River, which flows to Lake Ontario. All tributaries and wetlands associated with these waters are also included in the definition of navigable waters.

All 40 CFR 112-regulated storage tanks, 55-gallon drum storage areas/buildings, and grease containers (i.e., bulk storage containers) are listed in Appendix A. A series of facility diagrams identifying oil storage locations is included in Appendix B.

It should be noted that there are several oil/water separators (OWS) associated with oil collection tanks. Since these systems (OWS and tank) are part of a water treatment process system and are not used for secondary containment, they are not considered to be regulated by 40 CFR 112 and are, therefore, not discussed within this plan. However, it is good industry practice to inspect and monitor these OWSs and ensure that they are working in accordance with their design intentions.

Fort Drum has invested significantly in both physical discharge prevention measures (containment dikes, overfill prevention devices, leak detection systems, etc.) as well as operational controls and measures (operator training, routine inspections, certified inspections, and testing events, etc.) to minimize the potential for oil discharges.

The physical discharge prevention features for all the 40 CFR 112-regulated containers, unless otherwise noted, include the following:

• Bulk storage containers with capacities equal to or greater than 55 gallons are either double-walled or are located in an area with secondary containment volume sufficient to capture the entire contents of the container plus sufficient freeboard for precipitation.

• ASTs have a mechanism (spill bucket, alarm, gauge, visual monitoring) for overfill protection.

• Spill kits are located in the immediate area where transfers occur.

• Bulk storage containers and transformers are included in an ongoing inspection program.

• ASTs have a leak detection system that is regularly inspected.

The operational controls to prevent discharges at Fort Drum include the following:

• SPCC Training

• Bulk Storage Container Inspections, Testing, and Maintenance

• Other 40 CFR 112-regulated systems (non-bulk) Inspections, Testing, and

Maintenance

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Most 55-gallon POL drums in this plan contain new products and are stored in either outdoor buildings designated for POL storage or inside buildings where there are floor drain/trench systems designed to control a spill. If 55-gallon drums are stored in buildings that do not have a floor drain/trench system that would prevent a release, the drums are placed on secondary containment pallets. Motor pool and vehicle maintenance facility tenants are typically responsible for managing their day-to-day POL storage. Environmental Compliance Officers (ECO) perform monthly inspections of POL storage areas to verify compliance. Public Works Environmental performs quarterly verification inspections of these storage areas.

Electrical transformers have limited discharge or drainage control features in place. Refer to parts 1.3.4 and 1.11.2 of this Plan for additional discharge prevention measures in place for all oil-filled electrical transformers.

1.1.4 PREVENTION AND COUNTERMEASURES 112.7(A) (3) (II-V)

If regulated containers are discovered without adequate discharge controls, they shall be immediately upgraded as required by 40 CFR 112 as well as 6 NYCRR 613. Fort Drum is required to correct the bulk storage container system deficiencies upon identification in a timely manner.

As a primary form of countermeasure, Fort Drum has an Installation Spill Contingency Plan (ISCP) in place to respond to POL and hazardous substance spills or discharges. The ISCP details Fort Drum’s plan for the discovery, reporting, response, and cleanup of petroleum spills. The ISCP also discusses Fort Drum and contractor resources available to respond to a spill. Fort Drum contracted a professional engineer to ensure the ISCP meets the minimum requirements of 40 CFR 109 as well as applicable New York State requirements.

Another form of countermeasure is Fort Drum’s active tank inspection and testing program.

This is presented in Section 3.0 of the Petroleum Storage Tank Management Plan (PSTMP) and includes periodic inspections of all bulk storage containers.

The fueling procedures (e.g., vehicle or aircraft refueling and transfers of fuel to ASTs, including emergency power generator tanks) are another countermeasures program. These operations represent the largest potential for discharge to the environment and, therefore, must be performed with caution, following all applicable federal and state regulations. During fuel transfer operations, fuel operations personnel shall be present for the entire duration to monitor the situation carefully. In addition to monitoring the transfer, fuel operations personnel shall be prepared to react expeditiously to a spill to prevent discharge to the environment. Fuel operations personnel shall have appropriate training to effectively respond to worst-case scenarios and expeditiously request assistance from the facility if required. In addition, response equipment spill kits shall be in close proximity to the transfer area and may include sorbent pads, booms, drain covers, and other materials deemed appropriate to prevent a discharge to the environment.

All Army fuel suppliers must meet applicable requirements and regulations for tank truck loading/unloading prior to entering the facility as defined by the U.S. Department of Transportation (DOT). The Army will confirm that the vendors are familiar with the base layout, security measures, emergency telephone numbers, loading equipment, and other activities necessary for a safe and efficient transfer of fuel. The transfer of fuel will occur only in specified and designated areas and at specified times as defined by the Army. The

Stell/Fort Drum Environmental 5 April 2023 vendors delivering POL must be properly trained with the fuel transfer protocol and must remain with the vehicle until the fuel transfer is completed. The driver must be equipped to respond to all emergencies and must be able to expeditiously report a spill and request assistance if required. The driver must be fully trained with all safety and Occupational Safety and Health Administration requirements relevant to the transport of fuel and hazardous substances.

To the extent practicable, spilled oil will be recovered and recycled. Oil-laden sorbent materials and other spill residues will be placed into DOT-approved containers, properly labeled, and temporarily stored in a secure, designated location in preparation for transportation. Disposal of all materials shall be in accordance with local, state, and federal requirements. The formal process for disposal of recovered materials and a complete list of contact personnel is addressed in the ISCP maintained by the Directorate of Public Works (DPW) Environmental Division.

1.1.5 RESPONSE PLANS 112.7(A) (4) AND (5)

The procedure that must be followed in the event of a discharge is outlined in the ISCP maintained by the Environmental Division.

1.2 SPILL PREDICTIONS - 112.7(B)

The Facility Figures in Appendix B contain contour lines, which indicate topography and allow the prediction of potential spill flow directions for all 40 CFR 112-regulated containers.

In all cases, it is assumed that the worst-case discharge would be a rupture of the storage vessel, instantaneously spilling the maximum storage capacity of the tank. This plan also assumes that the most probable discharge during receiving is an overfilling of the tank or a transfer hose failure. In the case of an overfill, it is anticipated that fuel operations personnel would be able to shut down the operation in less than one minute. Therefore, the most probable discharge scenario is for a one-minute discharge duration of a transfer operation.

1.3 CONTAINMENT & DIVERSIONARY STRUCTURES 112.7(C)

1.3.1 OIL STORAGE CONTAINERS

Oil storage containers have secondary containment or a containment or diversionary structure designed to prevent a discharge from reaching the environment in the event of an accidental leak from the primary vessel.

1.3.2 LOADING/UNLOADING AREAS – GENERAL CONTAINMENT

In addition to secondary containment structures, sorbent materials and other types of response materials are maintained in close proximity to storage areas or staged on the oil delivery/recovery truck. These spill response materials are of a sufficient quantity to contain and expeditiously clean spilled oil in order to prevent a discharge to the environment or navigable waters. This is the form of containment or diversion for most loading/unloading areas and is considered “general” containment.

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The basis for the design volume for the general containment is as follows:

• Vehicle fueling tanks: assume unloading a tanker truck to an underground storage tank

(UST) or AST at 15 gallons per minute (gpm). Since these transfers are done with personnel overseeing the entire transfer operation, it is assumed the transfer can be shut down in 15 seconds. Total potential overfill is assumed to be 4–5 gallons.

• Generator tanks: assume unloading a tanker truck to AST at 50 gpm. Since these transfers are done with personnel overseeing the entire transfer operation, it is assumed the transfer can be shut down in one minute. The total potential overfill is assumed to be 50 gallons.

• Used oil consolidation tanks: assume most average discharge from transferring used oil to a vacuum truck is a 25-gallon spill.

• OWS holding tanks (not regulated by 40 CFR 112 – so Best Management Practices only): assume most average discharge from transferring used oil to a vacuum truck is a 25-gallon spill.

In certain circumstances, more substantial containment diversionary structures are needed.

These include locations where general containment would not adequately keep a discharge from a receiving/issuing operation from reaching navigable waters. The more substantial fuel operating areas (ground fuels—truck loading/unloading racks, airfield fueling area, bulk storage tank unloading area, airfield refueler truck loading area) have engineered containment/diversionary structures designed to minimize the potential environmental impacts of a release. Individual tanks that dispense fuel have spill kits for response to spills from fueling vehicles.

Building 3829 is the major consolidation point for off-spec fuel and used oil before being taken offsite for proper disposal or refining. A vacuum truck, also regularly parked at Building 3829, is used to empty smaller used oil and off-spec fuel consolidation tanks on an as-needed basis to unload in the larger tanks at Building 3829. A catchment drain located in the center of the loading/unloading area between the seven 5,000-gallon ASTs is designed to catch any release from the vacuum truck operations, sending fluid to an OWS located approximately 25 feet behind Building 3829. The valve to this OWS is closed during loading/unloading activities as a countermeasure. This containment sump is hydrostatically tested each year.

1.3.3 BULK AVIATION FUEL SYSTEM

Fort Drum has incorporated a large-scale diversionary system to provide secondary containment at the aviation bulk storage tank loading and unloading areas (Building 2084, ASTs 870 and 871).

Building 2086 is a wastewater retention and lift station located at Wheeler Sack Army Airfield. The facility consists of several large settling/holding tanks with a collective liquid storage capacity of 730,000 gallons. The facility receives wastewater influent collected from interior building floor drains in multiple aircraft hangers and maintenance buildings, outdoor aircraft wash racks, bulk fuel loading and off-loading facilities, and secondary containment dikes for fuel storage tanks.

To aid in minimizing the amount of oil entering the holding tanks from areas that potentially may have small spills (fueling operations areas), several OWS systems treat the stormwater runoff prior to reaching the contaminated sewer holding tanks at Building 2086. This

Stell/Fort Drum Environmental 7 April 2023 significantly reduces the potential of slight sheens due to small operational spills (hose disconnection, aircraft fuel “burping,” etc.).

Tank sizes of the 2086 facility include:

• one 30,000-gallon settling/holding tank with gate valves; and

• two 350,000-gallon settling/holding tanks with gate valves.

If an accidental spill were to occur during loading or unloading activities at the bulk aviation area, the release would be collected and held in the holding tanks. The expeditious removal of the spilled product would be accomplished through the use of an approved vacuum truck for proper disposal. The total capacity of the holding tanks is approximately 730,000 gallons, and accounting for a spill during a rain event, the following calculations have been made.

• Total capacity = 730,000 gallons

• Minus estimated volume stored prior to spill - 100,000 gallons

• Total volume of spill capable of being held 630,000 gallons

(Not including stormwater run-off)

The reasonably expected maximum release would be a simultaneous spill (an unlikely event) of two tanker trucks (one loading, one off-loading) during a rainstorm.

• 10,000 gallons per commercial truck x 2 trucks 20,000 gallons spilled

• 2.1 inches per hour rain* x assumed 1 hour duration x 10,000-square-meter drainage area;

*25-year-rain event according to the New York State Department of Environmental Conservation Technical Paper 40

+ 140,000 gallons

• Total spill size to be collected = 160,000 gallons

• Available containment volume 630,000 gallons

• Total Size to be collected - 160,000 gallons

• To be prepared for this maximum spill, the collection tanks should never contain more than

= 470,000 gallons (approximately 64 percent [%] capacity)

These calculations show that the large diversionary system at Building 2086 can handle a worst-case spill from any bulk fuel operating areas at the airfield, bulk ASTs, or the re-fueler operating areas, even if spills were to happen simultaneously.

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Requirements that must be met for adequate operation of this system include:

1. The holding tanks are maintained at a volume of less than 64% capacity.

2. Inspections of the holding tanks are to be documented and kept on file, indicating no oil is being discharged to the Watertown sanitary sewer system.

3. If a spill does occur and passes through the OWS and overflow systems to enter the holding tanks, the contents are expeditiously removed and disposed of in accordance with all federal, state, and local regulations. In this case, the Watertown Water Treatment Plant will be notified as soon as possible. A drain log will be kept when a spill occurs as the discharge valve is normally left open.

The containment of the airfield refueler parking (Building 19855) consists of a 15,000-gallon emergency spill collection tank (completely buried tank). Precipitation is not an issue for this emergency collection because inlets connected to the tank are indoors.

1.3.4 OIL-FILLED OPERATIONAL EQUIPMENT

The majority of oil-filled operational equipment at Fort Drum uses the alternative containment methods described in 40 CFR 112.7(k)(2). Most active pad-mounted transformers associated with buildings and substation transformers possess a gravel area surrounded by a concrete berm to contain releases near the transformer. The gravel fill is located on soil to allow water to drain into the ground and avoid potential safety issues due to the chance of electrical shock from electrical transformers. A transformer inspection program also exists to identify leaks that would necessitate repair or replacement.

The DPW stores new transformers awaiting installation and replaced transformers awaiting proper disposal at a gravel area adjacent to the substation off Nash Boulevard.

Fort Drum also has 16 elevators across the installation that use active and passive containment measures, as provided in 40 CFR 112.7(c). The rooms in which the reservoirs are located have concrete floors with no floor drains and possess oil-sorbent materials to contain and remove small spills. Each elevator is inspected monthly by a maintenance contractor. Any discrepancies noted during the inspection are repaired by the same contractor.

1.3.5 MOBILE REFUELERS

Mobile refuelers such as HEMTTs do not require “sized” secondary containment as described in 40 CFR 112.8(c). Instead, mobile refuelers require “general” secondary containment as described in 40 CFR 112.7). Therefore, mobile refuelers that contain fuel are parked or stored in areas that would prevent a discharge of oil to the environment. This could include constructed vehicle containment areas, field fold-out units, or places with covered drains and enough absorbents and attentive personnel to prevent a discharge. Mobile/portable containers (e.g., bowsers, emergency power generators) are discussed further in section 2.3.11.

Fort Drum Regulation 420-7 generally prohibits parking vehicles and equipment containing fuels on pervious surfaces and mandates general secondary containment of mobile refuelers by means of parking on concrete or blacktop (Fort Drum 2007).

1.4 IMPRACTICABILITY - 112.7(D)

This SPCC Plan does not include any determination of impracticability. All parts of this plan are required to be implemented, including inspections, tank and tightness testing, and other preventive measures stated herein, as well as noted in the PSTMP.

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1.5 INSPECTIONS, TESTS, AND RECORDS - 112.7(E)

Inspections and tests are conducted on a regular basis in accordance with the manufacturer’s recommendations, industry standards, and state and federal regulations. The inspections and tests are conducted and reviewed by qualified personnel to ensure compliance with technical standards in the field. In addition, quality control procedures are carefully documented and adhered to during all testing events. Tests, inspections, and other appropriate documents will be kept at the DPW Environmental Department (POL Manager’s office) and the Bulk Fuel System Manager’s office, which can be readily accessed by appropriate personnel in the event that a review of such documents is required. The documents are maintained for at least three years.

1.5.1 INSPECTIONS

All 40 CFR 112-regulated bulk storage containers (including containment systems) will undergo the inspections detailed in Sections 3.2 through 3.4 of the PSTMP and utilize the inspection forms (or similar) in Appendix D of this Plan. Inspection records are signed by an appropriate inspector and kept for at least three years. Alternative forms of these checklists (logbooks, spreadsheets, etc.) may be used if all applicable information is captured and retained for the period stated above. The table below summarizes the inspection information.

Table 1. Inspection Information Summary

TYPE

(FREQUENCY)

CHECKLIST

(SEE

APPENDIX D)

LOCATION

RECORDS KEPT PERFORMED BY

Bulk Storage Container Diked Area Accumulated Rainwater

(before draining)

DPW Environmental POL Manager

(to be implemented)

DPW – Environmental/ DPTMS Airfield

Bulk Storage Containers / Drum Storage Areas Inspections / Portable

Generators (Monthly) 2, 4

DPW Environmental POL Manager

(to be implemented)

DPTMS/ Tenant Units/

DPW—

Environmental/Utilities

UST Inspections 3 DPW Environmental POL Manager AAFES Managers

Loading/Unloading Areas / Tank Truck / Aircraft Fueling Daily

Inspections 5, 6, 8 DPW Environmental

POL Manager Fuel Facility Manager(s)

Cathodic Protection Inspections 7 DPW Environmental POL Manager Contractor

Emergency Generator-Integral Tank Inspections

(Monthly) 9 Monthly Excel Sheet sent by Utilities DPW– Environmental

Transformer Inspections (Annual) 10 DPW Environmental

POL Manager DPW - Environmental

Note:

AAFES = The Army and Air Force Exchange Service DPTMS = Directorate of Plans, Training, Mobilization, and Security

Stell/Fort Drum Environmental 10 April 2023

Fort Drum Environmental performs quarterly inspections to verify that the motor pool and vehicle maintenance facility tenant ECO are performing the monthly POL inspections.

1.5.2 TESTS

All 40 CFR 112-regulated storage tanks will undergo the tests detailed in Section 3.5 of the PSTMP during their monthly inspections.

1.6 PERSONNEL TRAINING & DISCHARGE PREVENTION PROCEDURES -

112.7(F)

1.6.1 TRAINING 112.7(F)(1)

Fort Drum provides site-specific SPCC training on a regular basis to personnel (military and/or civilian) involved with handling oil (e.g., transfers, storage tanks) or responding to oil spill events. This training will focus on ensuring personnel have a comprehensive understanding of appropriate local, state, and federal regulations and the SPCC Plan for this facility. This training occurs at least once a year but may occur more frequently, such as when a new environmental officer is assigned to a specific organization.

As an example, each motor pool has an ECO who is required to attend an ECO course. The ECO course is given twice a month throughout the year and covers a wide range of environmental subjects, including SPCC regulations and spill response, meeting the annual SPCC training requirement. A record of certificates as well as discharge prevention training, is maintained by all departments as part of SPCC plan requirements. The Discharge Prevention Training Log (or similar) in Appendix E can be used to document discharge prevention meetings.

1.6.2 DESIGNATED PERSON 112.7(F)(2)

The POL Manager within the DPW Environmental Division is responsible for discharge prevention for all of Fort Drum. This position reports directly to facility management (DPW Environmental Compliance Branch Chief). The POL Manager may identify competent and trained personnel (e.g., motor pool ECOs) at various locations to monitor the daily POL activities.

During construction and remediation activities at Fort Drum, contractor-managed and operated petroleum storage equipment are located on the installation. Equipment shall be operated by the contractor in accordance with the requirements of this Plan to prevent discharges. The contractor will assign one or more persons overseeing the activities to be the person responsible for discharge prevention and provide their contact information to the POL Manager.

1.6.3 BRIEFINGS 112.7(F)(3)

Fort Drum conducts an annual (at minimum) discharge prevention training briefing for personnel involved with the handling of POL. The objective of the briefing is to focus on prevention techniques and methodologies and learn from prior mishaps. The training is conducted by qualified personnel with knowledge of the Fort Drum SPCC Plan and relevant regulatory issues. The SPCC Plan Training Log (or similar) in Appendix E shall be used to document discharge prevention briefings.

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1.7 SECURITY - 112.7(G)

Fort Drum is well protected because it is a military installation, and access is not easily available to personnel without official business. The entire installation is secured by a perimeter fence and is well-lighted in the areas where POL is used. An active security force patrols the entire facility throughout the day and evening hours seven days a week. In addition, most tanks are located inside secured compounds with additional fencing or inside buildings and are monitored by authorized personnel. The threat of vandalism or other subversive actions to the POL facilities is minimal.

During the routine tank inspections, detailed in Section 3.4 of the PSTMP, all valves that could directly empty a tank or containment structure are inspected to confirm they are secured in a “closed” position.

Pump controls are deactivated (e.g., secured in the “off” position) until ready to be used for fuel transfer operations. This requirement mainly applies to the bulk fuel system loading/unloading at Building 2084. The pump starter control is located in a locked pump house that is only accessible to authorized fuel system operators.

Vehicle fuel dispensing tanks are controlled through a fuel management system (Fuel Master or similar). These systems will not allow the pump to be operated without some form of authorization (key card, credit card, etc.). These dispensing systems rely on these electronic systems to “lock out” unauthorized dispensing from the tanks.

1.8 FACILITY TANK CAR & TANK TRUCK LOADING/UNLOADING RACK –

112.7(H)

1.8.1 DRAINAGE 112.7(H)(1)

There is one loading rack (two positions) and one unloading header (two positions) located at the bulk aviation fuels area adjacent to ASTs 870 and 871. The loading racks and unloading headers all utilize the Oasis Sewage Lift Station (contaminated sewer) as a discharge containment/diversionary structure, as detailed in Section 1.3.3. This diversionary structure is capable of containing the maximum capacity of the largest single compartment on a truck filled or unloaded in these areas.

Another loading/unloading rack in the center of the airfield was put into service in August 2013. This new loading/unloading rack serves two 30,000-gallon ASTs, which provide fuel directly to the flight line. The rack has concrete containment capable of holding the entire contents of a HEMTT tanker (2,500 gallons). The new procedure will have HEMTTs filled at ASTs 870 and 871 and then driven out to fill the new ASTs in the center of the airfield for distribution to aircraft.

Another large transfer (loading and unloading) area at Fort Drum is located at the Army Field Support Battalion (AFSBn) Fuel Station (Building 1490). The AFSBn Fuel Station contains five 12,000-gallon ASTs (two JP-8, two diesel, and one gasoline), which are regularly used for fueling ground vehicles. The north transfer area adjacent to these ASTs is secondarily contained by curbs on the north and south sides, and roll-over berms at the east and west ends.

The transfer area is designed to direct a spill toward an inlet in the pavement near the north-central edge (in front of AST 180R). The trench extends to a stormwater retention pond adjacent to the north side of the transfer area. A valve located at the end of the trench remains

Stell/Fort Drum Environmental 12 April 2023 open at times when no transfer activities are being conducted and is securely closed during transfer operations. Spill kits are located near each AST.

1.8.2 WARNING OR BARRIER 112.7(H)(2)

During loading rack-related transfer operations, wheel chocks or vehicle break interlock systems are used to prevent vehicles from departing before the complete disconnection of flexible or fixed lines is completed. The entire process is carefully monitored by personnel on site for the entire duration of the fueling operation.

1.8.3 INSPECTION 112.7(H)(3)

Tank trucks are inspected prior to filling and departure to ensure all drains and outlets are in a secure position that would prevent a release. All operators of tank trucks involved in fueling activities at Fort Drum are aware of the procedures associated with their specific fueling activities and the vehicles in which they operate.

1.9 BRITTLE FRACTURE EVALUATION - 112.7(I)

The Bulk Aviation Fuel Storage Tanks AST 870 and 871 are the only two field-constructed ASTs on Fort Drum and, therefore, the only ASTs that require brittle fracture evaluation.

Each underwent API 653 construction repairs, mechanical upgrades, and coating repairs in 2009–2010. Upon completion of the repairs, each system was performance tested. The testing indicated that the systems were operating properly and were placed back in service. Details of the repairs and upgrades can be found in the Final Completion Report for API 653, Tank Construction Repairs and Coating Construction Group #1 prepared by Cape, dated April 2010.

1.10 STATE AND ARMY RULES, REGULATIONS, AND GUIDELINES - 112.7(J)

In addition to complying with the criteria stated in the SPCC Plan, state rules and regulations will also be complied with as well. The requirements of 6 NYCRR 613 are discussed in detail in Section 2.3 of the PSTMP. New York State rules and criteria that are as stringent as or more stringent than Federal rules shall be used to govern this plan. This SPCC Plan also meets the requirements of Army Regulation 200-1.

1.11 QUALIFIED OIL-FILLED OPERATIONAL EQUIPMENT - 112.7(K)

Since Fort Drum meets the requirements of 112.7 (k)(1), it is the intent of this plan to implement the requirements described in Section 1.11.2 in lieu of general secondary containment for oil-filled operational equipment. See Section 1.11.2 for details of that implementation.

1.11.1 HISTORY 112.7(K) (1)

Fort Drum has not had a single discharge from oil-filled operating equipment greater than 1,000 gallons or two discharges greater than 42 gallons within the last three years. A listing of all oil discharges/spills at Fort Drum is included as Appendix F.

1.11.2 ALTERNATIVE CONTAINMENT 112.7(K)(2)

Fort Drum does not intend to construct permanent secondary containment for all existing oil-filled operational equipment, however, construction contracts have been updated to include

Stell/Fort Drum Environmental 13 April 2023 an oil containment curb surrounding new transformer pads. The facility will also provide alternate secondary containment per the requirements of 40 CFR 112.7 (K) (2) as follows:

1. The facility will conduct routine visual inspections of all oil-filled equipment. These inspections will be documented on the “Transformer Semiannual Inspection Checklist” (or similar) provided in Appendix D. These completed checklists will be kept on file in the DPW Environmental POL manager’s office for at least five years.

2. The facility will rely on the ISCP, which is maintained by the DPW Environmental Division.

3. Within the ISCP is a written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful.

In addition to inspecting the transformers located throughout Fort Drum, inspections shall also be performed at the two electrical substations. Substation A is south of Nash Boulevard, and Substation B is north of Iraqi Freedom Drive. Each substation consists of two transformers that each contain approximately 3,400 gallons of mineral oil and two oil circuit breakers that each contain 763 gallons of mineral oil. Both substations shall be inspected on a regular basis for spill prevention as well as electrical hazard safety.

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2 2ADDITIONAL SPECIFIC DISCHARGE PREVENTION &

CONTAINMENT PROCEDURAL REQUIREMENTS - 112.8

(SUBPART B)

2.1 GENERAL - 112.8(A)

This SPCC plan meets the general requirements for the Plan listed under 112.7 and the specific discharge prevention and containment procedures listed in 40 CFR 112.8.

2.2 FACILITY DRAINAGE - 112.8(B)

2.2.1 RESTRAIN DRAINAGE 112.8(B)(1)

Small, diked areas utilize valves or threaded pipe caps to control discharge for the containment areas. The diversionary structures for the airfield, bulk fuel, and used fuel/oil operations utilize valves to prevent a discharge from releasing outside the diked area. A visual inspection of accumulated liquid from precipitation events is performed prior to any releases to ensure no oil is discharged.

2.2.2 VALVES 112.8(B)(2)

No valves associated with secondary containment systems located at the facility are of the “flapper” design. Valves are manually operated.

2.2.3 DESIGN 112.8(B)(3)

The facility drainage systems at undiked areas with the potential for a discharge are designed to flow into a catchment basin or retention pond. Spill response procedures for these areas are presented in the updated Fort Drum ISCP.

2.2.4 RETENTION 112.8(B)(4)

Since the undiked areas of concern are equipped with a diversionary structure, no additional diversion system is required.

2.2.5 TREATMENT 112.8(B)(5)

Stormwater is not treated on Fort Drum prior to discharge. The stormwater collected at the Oasis Sewer Lift Station (contaminated sewer) is inspected and will be collected, removed, and transported to an authorized treatment facility if determined to contain oil. Such an operation would be fully documented and kept for recordkeeping at the DPW Environmental office.

2.3 BULK STORAGE CONTAINERS - 112.8(C)

2.3.1 COMPATIBILITY 112.8(C)(1)

Oil is stored in appropriately designed and compatible container tanks at Fort Drum. The containers are capable of handling the pressure and temperature differential requirements in accordance with appropriate industry standards.

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2.3.2 SECONDARY CONTAINMENT 112.8(C)(2)

2.3.2.1 ASTS

ASTs used to store oil and petroleum are equipped with appropriately sized containment. The majority of ASTs at the facility are double-walled. The two single-walled ASTs are located within secondary containment systems that are sufficiently impervious and have the required capacity to contain the entire contents of the tank, plus sufficient freeboard for precipitation.

2.3.2.2 DRUM STORAGE

Drums are stored in secondary containment systems which are large enough to contain the entire volume of the largest container stored. Drums are stored in either hazardous material lockers, buildings/covered devices designated for POL storage (including used cooking oil [40 CFR 112.12(c)(2)] from food preparation facilities), or inside buildings where the floor drain/trench systems are designed to control/recover a spill. In cases where 55-gallon drums are stored in buildings that do not have a floor drain/trench system that would prevent a release, the drums are placed on secondary containment pallets.

POL-containing 55-gallon drums not specifically identified in this Plan (due to their transitory operational nature) that are without adequate discharge controls shall be provided appropriate secondary containment or relocated as required to meet applicable requirements.

2.3.3 PRECIPITATION DRAINAGE 112.8(C)(3)

Secondary containment systems for bulk storage containers that have precipitation drainage valves shall be kept in a closed and secure position at all times. Rainwater accumulated in these systems is inspected by a responsible supervisor to ensure there is no evidence of harmful quantities of oil as described in 40 CFR 110. Adequate records of such inspections and discharge events shall be kept on file.

2.3.4 COMPLETELY BURIED TANKS 112.8(C)(4)

Eight USTs containing gasoline for civilian vehicles at Fort Drum are fully regulated by 40 CFR 280 and thus excluded from regulation by 40 CFR 112. However, 6 NYCRR 613 applies to these USTs. They are shown on the maps in Appendix B.

2.3.5 PARTIALLY BURIED TANKS 112.8(C)(5)

There are no partially buried tanks on Fort Drum.

2.3.6 INTEGRITY TESTS 112.8(C)(6)

Storage tanks and other oil-containing storage and operating equipment are subject to routine visual inspections as described in Section 3.0 of the PSTMP. As a general directive, all storage tanks are either constructed with continuous leak detection monitoring systems or subject to routinely scheduled integrity testing. The details and schedules for this testing are provided in Section 3.0 of the PSTMP.

Additionally, ASTs will be formally evaluated for integrity on a routine basis according to the following standards:

• Bulk field-constructed ASTs – API 653 (certified inspector required every 10–20 years)

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• Shop-fabricated ASTs – STI SP001 sixth edition (certified inspector required every 10–20 years, for Category 1 tanks over 5,000 gallons only)

• 40 CFR 112-regulated completely buried storage tanks will rely on permanent leak detection systems or routinely scheduled integrity testing.

The details and schedules for these formal tank evaluations are kept in the DPW Environmental POL Manager’s office for the lifetime of the tank.

2.3.6.1 DRUMS (REVISED MARCH 2016 TO REPLACE PREVIOUS VERSION FROM AUGUST

2013) Mobile and portable tank (including 55-gallon drum) inspection and testing requirements are contained in Steel Tank Institute (STI) Standard SP001 sixth edition (January 2018 revision).

This standard requires periodic inspections by owners and recertification to DOT standards at varying intervals, depending on the material of construction, as identified below:

• Plastic portable container - every 7 years

• Steel portable container - every 12 years

• Stainless steel portable container - every 17 years

Fort Drum uses visual inspection standards for monthly inspections at the Hazardous Materials Center, which stores a large number of drums. Other drum storage areas hold only a few drums at a time. These areas use the products in drums relatively quickly, so drums are usually stored for only about a month, greatly reducing the likelihood of corrosion. These drum storage areas are inspected monthly by the appropriate military unit Environmental Officer. The DPW Environmental Division also inspects these facilities at least quarterly. The low number of drums and low corrosion potential allow this hybrid program of monthly inspections and quarterly follow-up inspections to provide equivalent environmental protection as allowed by 40 CFR 112.7(a) (2).

2.3.7 INTERNAL HEATING COILS 112.8(C)(7)

Fort Drum does not have any tanks equipped with internal heating coil systems; therefore, this requirement is not applicable.

2.3.8 OVERFILL PREVENTION 112.8(C)(8)

Storage tanks are equipped with direct reading visual gauges or high-level alarms to prevent overfills. Gauges are monitored during fuel transfers to prevent overfilling. Liquid-level sensing devices and discharge control devices (automatic tank gauges, high-level alarms, mechanical gauges, etc.) associated with petroleum storage equipment are tested annually.

This is detailed in Section 3.5.1.7 of the PSTMP.