SPILL PREVENTION AND RESPONSE PLAN

(SPRP)

USAG STUTTGART

- - - FINAL - - -

Update January 2024

USAG Stuttgart Spill Prevention and Response Plan – January 2024 Update

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APPROVALS

This Spill Prevention and Response Plan (SPRP) addresses spill prevention, control, and response specific to Petroleum, Oil, Lubricants (POL) and Hazardous Substances (HS) transport, storage, handling, and disposal at the U.S. Army Garrison (USAG) Stuttgart.

Approved By:

DateG. K

COL, FA

Commanding

Approved By:

Marisa K. Barrie Date Director of Public Works USAG Stuttgart

Approved By:

Therese Mundorff Date Spill Coordinator DPW, Environmental Division

CERTIFICATIONS

As a certified technical authority, I certify this Stuttgart Spill Prevention and Response Plan (SPRP) is prepared IAW good engineering practice and is adequate for the facility. This SPRP is prepared

IAW Chapter 18 of the German Final Governing Standards and provides measures to prevent and, to the maximum extent practicable, to remove the chances of a worst-case discharge from USAG

Stuttgart.

Technical changes (i.e., non-administrative) to the plan require recertification. This plan requires an update at least every 5 years, or within 6 months of any significant changes to operations, or if there have been two significant spills to navigable waters in any 12-month period, or when there has been a spill of 3,785 liters (1,000 gallons).

Certified By:

31 January 2024 Tanya Sagermann, PE (TN #105779) Date Tetra Tech, Inc., Rodenbach, Germany

USAG STUTTGART SPILL PREVENTION AND RESPONSE PLAN

RECORD OF REVISIONS

The SPRP must be reviewed and updated at least every 5 years or within 6 months of any significant changes in operations, or when there have been two significant spills to navigable waters in any 12-in accordance with Chapter C18.3.1.1. – C18.3.1.1.3. of the German Final Governing Standards (GFGS) Chapter 18, Spill Prevention and Response Planning. To fulfill this requirement, the following table is provided for tracking revisions to this plan.

Revision No.

Date Description Pages Affected

1 Feb 2010 Comprehensive revision of 2007 SPRP by AMEC Earth &

Environmental GmbH and DPW-ED

All

2 June 2010 DPW-ED staff revisions ii, 1-1, 1-2, 1-5 to 1-7, 2-1, 3-2, 6-1, 7-1, 4-1 to 4-3, A1-1 to A1-4

3 July 2010 DPW-ED staff revisions A7-5, A7-6, A8-5, A8-6

4 Feb 2013 DPW-ED staff revisions Approvals, ii, 1-7, 1-8, 4-1, 6-1, A4-1, A4-2, A6-4, A7-5, A7-6, A8-5, A8-6, App. 10 added

5 March 2015 DPW-ED staff revisions Approvals, A6-4, A6-5, A7-1 till A7-6, A8-1 till A8-6, A10-1

6 January

DPW-ED staff revisions Approvals, 1-5, 1-6, 7-1, A1- 1, A5-6, A6-1, A6-4, A7-5, A7-6, A8-5, A8-6, 7 May 2018 DPW-ED staff revisions A6-4, A7-5, A8-5,1-7

8 December

SPRP update by Wood with approval through DPW-ED staff

Entire document

9 February

DPW-ED staff revisions Approvals,1-7,A5-8-15, A6-6, A7-5, A8-5

10 January

SPRP updated by Tetra Tech with approval through DPW-ED staff

Approvals, 4 5, references, A1-2, A5, A6-6, A6 7, A7-2, A7-5, A7-6, A8-2, A8-5, A8-6, A10-1, Appendix 11 added i

TABLE OF CONTENTS

1 INTRODUCTION..................................................................................................................... 1-1

1.1 PURPOSE .............................................................................................................................. 1-1

1.1.1 Slug Prevention Plan ................................................................................................ 1-1

1.1.2 Hazardous Waste Contingency Plan........................................................................ 1-1

1.2 APPLICABILITY ....................................................................................................................... 1-1

1.3 RED PLAN DISTRIBUTION ........................................................................................................ 1-2

1.4 RESPONSIBILITIES.................................................................................................................. 1-2

1.4.1 Facility Incident Commander (FIC)........................................................................... 1-2

1.4.2 Facility Response Team (FRT) ................................................................................ 1-2

1.4.3 Directorate of Public Works (DPW) Responsibilities................................................ 1-2

1.4.3.1 Spill Coordinator............................................................................................................... 1-2

1.4.3.2 Hazardous Waste Emergency Coordinator ...................................................................... 1-3

1.4.4 Responsibilities at the Units ..................................................................................... 1-3

1.4.4.1 Unit Commander .............................................................................................................. 1-3

1.4.4.2 Environmental Officer (EO) .............................................................................................. 1-3

1.4.4.3 Public Affairs Office (PAO) ............................................................................................... 1-4

2 SPILL PREVENTION.............................................................................................................. 2-1

2.1 LEGAL BACKGROUND............................................................................................................. 2-1

2.2 SPILL PREVENTION STRUCTURES AND EQUIPMENT ................................................................. 2-2

2.3 MERCURY SPILL PREVENTION ................................................................................................ 2-3

2.4 INSPECTIONS......................................................................................................................... 2-4

2.4.1 Aboveground Storage Tanks (ASTs) ....................................................................... 2-4

2.4.2 Underground Storage Tanks (USTs)........................................................................ 2-5

2.4.3 All Storage Tanks (ASTs and USTs)........................................................................ 2-5

3 SPILL CONTROL AND RESPONSE...................................................................................... 3-1

3.1 INCIDENT EVALUATION ........................................................................................................... 3-1

3.2 SPILL ASSESSMENT ............................................................................................................... 3-1

3.2.1 Determine Safe Actions............................................................................................ 3-2

3.2.2 Stopping Spills.......................................................................................................... 3-2

3.3 SPILL CLEANUP ..................................................................................................................... 3-3

3.3.1 General Cleanup and Disposal Requirements......................................................... 3-3

3.3.2 Control and Cleanup of Mercury Spills..................................................................... 3-3

4 SPILL NOTIFICATION AND REPORTING ............................................................................ 4-1

4.1 POINTS OF CONTACT ............................................................................................................. 4-1

4.2 SIGNIFICANT SPILLS............................................................................................................... 4-1

4.3 NOTIFICATION REQUIREMENTS ............................................................................................... 4-1

4.3.1 Notification Requirements for Spills inside DoD Installations................................... 4-1 ii

4.3.2 Notification Requirements for Spills inside DoD Installations not contained within the installation............................................................................................................................. 4-2

4.3.3 Notification Requirements for Spills outside DoD Installations ................................ 4-2

4.3.4 Non-DoD Resources ................................................................................................ 4-3

4.3.5 Involvement of Public Affairs .................................................................................... 4-3

4.3.6 Documentation ......................................................................................................... 4-3

5 RECORD KEEPING................................................................................................................ 5-1

6 TRAINING ............................................................................................................................... 6-1

6.1 GENERAL .............................................................................................................................. 6-1

6.2 TRAINING REQUIREMENTS...................................................................................................... 6-1

7 REFERENCES........................................................................................................................ 7-1

APPENDICES

Appendix 1 Standard Operating Procedures to Prevent POL and HS Spills

Appendix 2 Checklists and Forms for Inspection and Surveillance

Appendix 3 Spill Prevention and Response Deficiencies and Corrective Action

Appendix 4 Maps and Corresponding Information

Appendix 5 POL and HS Facilities Inventory and Spill Prevention and Control Equipment Inventory

Appendix 6 Slug Prevention Plan

Appendix 7 Red Plan (English Version)

Appendix 8 Alarmplan (Red Plan German Version)

Appendix 9 Regulatory Host Nation Requirements

Appendix 10 Evacuation Plan Template

Appendix 11 Past Spill Reports iii

LIST OF TABLES

TABLE 1-1: SPRP REGULATORY CROSS REFERENCE MATRIX................................................... 1-5

TABLE 1-2: LOCATIONS OF SPRP COPIES ................................................................................ 1-7

TABLE 2-1: HAZARDS LEVELS BASED ON VOLUME AND WATER HAZARD CLASS........................... 2-2

TABLE 2-2: ASTS NOT LOCATED WITHIN PROTECTION ZONES OR FLOODPLAINS........................... 2-4

TABLE 2-3: ASTS LOCATED WITHIN PROTECTION ZONES OR FLOODPLAINS.................................. 2-4

TABLE A- 3.1: SPILL PREVENTION AND RESPONSE DEFICIENCIES AND CORRECTIVE ACTION FOR

USAG STUTTGART ................................................................................................ 3-1

TABLE A- 4.1: LIST OF MAPS........................................................................................................ 4-1

TABLE A- 5.1: GAS STATION TANKS AT USAG STUTTGART ........................................................... 5-1

TABLE A- 5.2: EMERGENCY GENERATOR TANKS 0.2 M3 AT USAG STUTTGART............................ 5-2

TABLE A- 5.3: HEATING OIL TANKS AT USAG STUTTGART ............................................................ 5-4

TABLE A- 5.4: WASTE OIL TANKS AT USAG STUTTGART............................................................... 5-4

TABLE A- 5.5: ACTIVE OIL-WATER SEPARATORS AT USAG STUTTGART ........................................ 5-5

TABLE A- 5.6: HWAP LOCATIONS AT USAG STUTTGART.............................................................. 5-6

TABLE A- 5.7: HWBAT LOCATIONS AT USAG STUTTGART............................................................ 5-7

TABLE A- 5.8: HWCON LOCATIONS AT USAG STUTTGART........................................................... 5-8

TABLE A- 5.9: HWSA LOCATION AT USAG STUTTGART................................................................ 5-8

TABLE A- 5.10: SPILL PREVENTION AND CONTROL EQUIPMENT AND MEASURES AT GAS STATIONS ... 5-9

TABLE A- 5.11: SPILL PREVENTION AND CONTROL EQUIPMENT AND MEASURES AT EMERGENCY

GENERATORS > 1M3............................................................................................. 5-11

TABLE A- 5.12: SPILL PREVENTION AND CONTROL EQUIPMENT AND MEASURES AT HEATING OIL TANKS

........................................................................................................................... 5-18

TABLE A- 5.13: SPILL PREVENTION AND CONTROL EQUIPMENT AND MEASURES AT WASTE OIL TANKS 5-

TABLE A- 5.14: SPILL PREVENTION AND CONTROL EQUIPMENT AND MEASURES AT OIL-WATER

SEPARATORS....................................................................................................... 5-23

TABLE A- 5.15: SPILL PREVENTION AND CONTROL EQUIPMENT AND MEASURES AT HWAPS/ HWSA .. 5-

TABLE A- 6.1: POCS FOR SLUG RELEASE SITUATIONS.................................................................. 6-6

TABLE A- 6.2: SEPARATOR SYSTEMS AT USAG STUTTGART ......................................................... 6-9

TABLE A- 7.1: POINTS OF CONTACT.............................................................................................. 7-5

TABLE A- 8.1: KONTAKTLISTE....................................................................................................... 8-5

TABLE A- 11.1: SUMMARY OF PAST SPILL EVENTS

iv

LIST OF ACRONYMS AND ABBREVIATIONS

1/10th SFG 1st Battalion, 10th Special Forces Group

7th ATC 7th Army Training Command

405th AFSB BASOPS 405th Army Field Support Brigade, Base Support Operations

405th AFSB HM 405th Army Field Support Brigade, Hazardous Material

554th MP 554th Military Police

AAFES Army & Air Force Exchange Service

AAFES CCC Army & Air Force Exchange Service Car Care Center

AST Aboveground Storage Tank

AwSV Ordinance on facilities handling water-endangering substances (Verordnung über Anlagen zum Umgang mit wassergefährdenden Stoffen)

BTA Böblingen Training Area

COL Colonel

DeCA Defense Commissary Agency

DES Directorate of Emergency Services

DES MP Directorate of Emergency Services Military Police

DESC Defense Energy Support Center

DoD Department of Defense

DoDI Department of Defense Instruction

DoDEA Department of Defense Education Activity

DOL Directorate of Logistics

DOL/TMP Directorate of Logistics/ Transportation Motor Pool

DPTMS/IOC Directorate of Plans, Training, Mobilization and Security /Installtion Operations Center

DPW Directorate of Public Works

ED Environmental Division

EEA Environmental Executive Agent

EO Environmental Officer

FIC Facility Incident Commander

FRT Facility Response Team

GFGS German Final Governing Standards v

LIST OF ACRONYMS AND ABBREVIATIONS

GFK Glass-fiber reinforced plastic (Glasfaser verstärkter Kunststoff) gal Gallon

HAZCOM Hazard Communication

HS Hazardous Substance

HW Hazardous Waste

HWAP Hazardous Waste Accumulation Point

HWBAT Container for Collection of Household Batteries

HWCON Container for Collection of Cooking Oil

HWMP Hazardous Waste Management Plan

HWSA Hazardous Waste Storage Area

IMC Installation Management Contract

IMCOM Installation Management Command kg Kilogram

MAV TLSC-E Maintainance Activity Vilseck Theater Logistics Support Center Europe

FMWR Family and Moral, Welfare and Recreation

NSWU/2 Naval Special Warfare Unit-2

O&M Operation and Maintenance

OWS Oil Water Separator

PAIO Plans, Analysis and Integration Office

PAO Public Affairs Office

POC Point of Contact

POL Petroleum, Oil and Lubricants

PPE Personal Protective Equipment

SDS Safety Data Sheet

SOP Standard Operating Procedure

SPRP Spill Prevention and Response Plan

TÜV Technical Supervisory Association (Technischer Überwachungsverein) vi

LIST OF ACRONYMS AND ABBREVIATIONS

TLSCE-E/ MAV Det Theater Logistics Support Center – Europe Maintainance Activity Vilseck Detachment

U.S. United States

USEUCOM United States European Command

USAG United States Army Garrison

UST Underground Storage Tank

VMR SPMAGTF

C12W

Special Purpose Marine Air-Ground Task Force

WGK Water hazard class (Wassergefährdungsklasse)

1-1

1 INTRODUCTION

This Spill Prevention and Response Plan (SPRP) has been developed for the United States Army Garrison (USAG) Stuttgart. The Garrison Commander or their approved representative is responsible for the overall content and effectiveness of this plan.

1.1 PURPOSE

This SPRP satisfies the requirement to prepare, maintain and implement a Spill Prevention and Response Plan contained in German Final Government Standards (GFGS) Chapter C18.3.1., Spill Prevention Control and Reporting Plan Requirement. Each of the components of this SPRP corresponds to GFGS requirements, as documented in Table 1-1.

1.1.1 Slug Prevention Plan

Appendix 6 has been prepared to develop a Slug Prevention Plan, fulfilling the requirement of GFGS Chapter C4.3.2.3.6.

1.1.2 Hazardous Waste Contingency Plan

This SPRP contains the information required for a Hazardous Waste (HW) Contingency Plan in accordance with GFGS Chapter C6.3.6.1. The contingency plan must be maintained at the Hazardous Waste Storage Area (HWSA) and each Hazardous Waste Accumulation Point (HWAP) in accordance with GFGS Chapter C6.3.6.2.1. HWAPs need to maintain only parts of the contingency plan that are pertinent to their facilities and operation, such as the Red Plan. The Red Plan should be available in English and German (GFGS Chapter C6.3.6.2.2.).

1.2 APPLICABILITY

This SPRP applies to all installations, facilities, units, activities, and organizations associated with the USAG Stuttgart that use, transport, store, handle, or dispose of petroleum, oil and lubricants (POL) and/or hazardous substances (HS). This plan is applicable to any Garrison activities involving POL and/or HS whether these activities are executed on or off the USAG Stuttgart installations. Off-installation activities include any operations outside the Garrison or installation boundaries or on property not under U.S. control, such as off-post training activities and maneuvers. In addition, this document applies to the activities of any external organization or unit (not associated to the USAG Stuttgart) that use training areas on or otherwise operate within the Garrison’s area of responsibility.

This SPRP is applicable to the following installations of USAG Stuttgart:

Böblingen Training Area (BTA), Böblingen

Böblingen Family Housing, Böblingen

Böblingen Officers Club, Böblingen

Böblingen Range, Böblingen

Kelley Barracks, Stuttgart – Möhringen

Kornwestheim Golf Course, Kornwestheim

Panzer Kaserne, Böblingen

Patch Barracks, Stuttgart – Vaihingen

Robinson Barracks, Stuttgart (including Robinson-Grenadier Family Housing, Stuttgart Dependent School

Stuttgart Army Airfield, Echterdingen

Weilimdorf Warehouse, Stuttgart-Weilimdorf

1-2

1.3 RED PLAN DISTRIBUTION

The Red Plan must be placed at facilities where POL and/or HS are stored, used, and handled for quick reference during spill incidents. The Red Plan is available in English (Appendix 7) as well as in German (Appendix 8).

1.4 RESPONSIBILITIES

1.4.1 Facility Incident Commander (FIC)

The FIC is designated in writing by the Garrison Commander. The tasks of the FIC are fulfilled by the Directorate of Emergency Services (DES). The FIC’s responsibilities include:

In case of a significant spill, the FIC will immediately notify the Spill Coordinator, the appropriate Unit Commander, the Garrison Commander, the Garrison Fire Department, the Installation Management Command, Europe Environmental Executive Agent (IMCOM EEA), and the Defense Energy Support Center (DESC), if Directorate of Logistics (DOL) -owned facilities are involved.

If the spill occurs off the installation, the nearest German fire department and German police station shall be notified. The appropriate German authority (Untere Wasserbehörde in Baden-Württemberg) will be notified by the German Fire/Police Department.

Establishing and directing the Facility Response Team (FRT).

Coordinating and directing Department of Defense (DoD) control and cleanup efforts at the scene of a POL or HS spill due to DoD activities on or near a garrison.

Mobilizing the FRT immediately after a spill is reported.

Coordinating with the FRT to accomplish any spill response actions as effectively as possible.

Directing the cleanup of the stabilized spill material or any residual contamination of soil, water, or equipment.

Determining the point at which an emergency no longer exists.

As necessary, a written report will be provided to the appropriate Unit Commander, the Garrison Commander, the IMCOM EEA, the appropriate German Federal State authority, and the Spill Coordinator.

1.4.2 Facility Response Team (FRT)

The FRT is established and directed by the FIC. The tasks of the FRT are fulfilled by the USAG Fire Department, whereby the responsibilities include:

Providing personnel and equipment for emergency situations and significant spills.

Responding to a spill incident and being responsible for controlling the spill and its cleanup.

Ensuring proper disposal of spill residue of minor spills.

Maintaining training appropriate to response levels.

Maintaining an emergency plan that includes information on the nearest German Fire Departments with spill response capability, units and facilities of German disaster protection services; and U.S. or German agencies or individuals whose expertise or advice may be helpful.

Support the FIC in developing a written report of each spill incident, as necessary.

1.4.3 Directorate of Public Works (DPW) Responsibilities

1.4.3.1 Spill Coordinator

The Spill Coordinator is the individual, at the DPW Environmental Division (ED), primarily responsible for the spill prevention and response program. Responsibilities include:

Reviewing plans and specifications presented to the DPW ED concerning spill prevention measures.

1-3

Supporting development of plans and designing standards that meet all requirements of this

SPRP.

Testing the effectiveness and responsiveness of this SPRP on an annual basis. The test should include members of the FRT.

Disseminating training information to include provisions contained within this plan.

Coordinating with the Garrison Fire Department, German Police, and appropriate members of the FRT to arrange the control and cleanup of POL and/or HS discharges or spills off-installations, which the USAG Stuttgart is responsible for.

Establishing prearranged agreements with potential German resources (e.g. German disaster protection agency, remediation contractor, etc.), so they are available if a spill exceeds the response capabilities of the installation.

Recording and evaluating spill reports.

1.4.3.2 Hazardous Waste Emergency Coordinator

Installations that store HW must designate a person or persons to act as HW Emergency Coordinator for the HWSA and the HWAPs, including the containers for collection of household batteries (HWBATs) and cooking oil (HWCONs). For the USAG Stuttgart, the Spill Coordinator is also the HW Emergency Coordinator. Responsibilities include:

Familiarity with all aspects of this SPRP.

Familiarity with all installation operations involving HW, the location of all HW records, and the layout of the HWSA and HWAPs.

Authority to commit resources for implementing the HW Contingency Plan (see Section 1.1.2, HW Contingency Plan).

1.4.4 Responsibilities at the Units

1.4.4.1 Unit Commander

Major units are 1/10th Special Forces Group, 554th Military Police, MAV TLSC-E, NSWU/2, FMWR Autoskills Center, AAFES CCC and 405th AFSB HM Reuse Center.

Responsibilities include:

Coordinating with the Garrison Commander, DPW ED, and DES as necessary to ensure effective implementation, review, and testing of this SPRP.

Coordinating with and assisting the FRT for the cleanup of POL and/or HS releases whenever the unit’s area of responsibility is involved, and ensuring that all spills are reported as per this SPRP (see notification procedures in Section 4 of this SPRP).

Ensuring that unit personnel are trained and follow procedures for POL and HS handling, emergency response, and clean up.

Appointing an Environmental Officer (EO) with direct responsibility for POL and HS management.

Reviewing unit standard operating procedures (SOPs) after a spill occurs to see if changes are needed to prevent a reoccurrence. Also, providing a written report to the Spill Coordinator if the spill meets the reporting criteria listed in Section 4.2 of this SPRP.

1.4.4.2 Environmental Officer (EO)

Responsibilities include:

Notifying the FRT if the spill is significant.

Ensuring the SPRP is available at the applicable workplaces and kept in a location easily accessible for all unit members.

Ensuring that all unit personnel receive spill response training.

Ensuring correct handling of HS and disposal of HW at unit level.

1-4

Verifying whether spill control structures are effective.

Ensuring that Spill Response Materials are available.

Maintaining an inventory and safety data sheets (SDSs) of all HS handled at the unit level.

Conducting regular inspections of the HS storage sites and promptly correcting deficiencies.

1.4.4.3 Public Affairs Office (PAO)

Responsibilities include:

Coordinating with the USAG Commander about releasing information to the public, e.g.

media or civilians.

Releasing information to the public.

1-5

Table 1-1: SPRP Regulatory Cross Reference Matrix

GFGS

Chapter

Description Applicable SPRP Section Remarks

C4.3.2.3.6 Slug Prevention Plan Appendix 6

C5.3.4 Master Listing and Inventory Appendix 5

C5.3.14.3. Inspections for ASTs containing Water Endangering Substances

A1.3

C6.3.6 Contingency Plan 1.1.2/ Appendix 7/ Appendix 8

C9.3.2 POL storage tanks A1.3

C9.3.5.2 POL pipelines A1.3

C9.3.5.3 POL storage facility A1.3

C11.3.1.4 Pesticides A1.4

C18.3.2.1 Facility Incident Commander (FIC) 1.4.1/ Appendix 7/ Appendix 8

C18.3.2.2 General Installation Information Appendix 4

C18.3.2.3 Inventory of Potential Spill Sites Appendix 5

C18.3.2.4 POL and HS Inventory Appendix 5

C18.3.2.7 Emergency Services Arrangements 4.3/ Appendix 7/ Appendix 8

C18.3.2.8 Emergency Services Contact List Appendix 7/ Appendix 8

C18.3.2.9 Spill Prevention Control Equipment Appendix 5

C18.3.2.11 Emergency Equipment Appendix 5

C18.3.2.13 Spill Prevention Deficiencies Appendix 3

C18.3.2.14.1 Operations to Preclude Spills Appendix 1

C18.3.2.14.2 Inspections 2.4/ Appendix 2

C18.3.2.14.3 Record-keeping 5

C18.3.3.1 Responsibilities 1.4

C18.3.3.2 Immediate Response Actions 3.1/ Appendix 7/ Appendix 8

C18.3.3.3 Facility Response Team (FRT) 1.4.2/ 6.2

C18.3.3.6 Procedures for Public Affairs Involvement 4.3.5

C18.3.3.5 Emergency Contact List Appendix 7/ Appendix 8

C18.3.3.7 Notification of FIC, Commander and Local Authorities

4.3/ Appendix 7/ Appendix 8

C18.3.3.8 Notification Responsibilities 1.4/ Appendix 7/ Appendix 8

C18.3.3.9 Surveillance Procedures Appendix 2

C18.3.3.10 Prioritized List of Critical Resources Appendix 4

C18.3.3.11 Other Resources 4.3

1-6

GFGS

Chapter

Description Applicable SPRP Section Remarks

C18.3.3.12 Cleanup Methods 3.3

C18.3.3.13 Procedures for Reuse and Disposal 3.3.1

C18.3.3.14 Health, Safety, and Fire Prevention 3

C18.3.3.15 Releasing Information 4.3.5

C18.2.11 Significant Spill 4.2

C18.3.4 Notification requirements 4.3/ Appendix 7/ Appendix 8

C18.3.4.3 Spills inside DoD installation 4.3.1/ Appendix 7/ Appendix 8

C18.3.4.4 Spills inside DoD- inst. not contained 4.3.2/ Appendix 7/ Appendix 8

C18.3.4.5 Spill outside DoD-installation 4.3.3/ Appendix 7/ Appendix 8

C18.3.5 Training and Response Drills 6

C18.3.6 Removal/Management of Contaminated Soil

3.3.1

C19.3 UST Systems 2.4/ A1.5

1-7

Table 1-2: Locations of SPRP Copies

Installation Name Facility Name/Unit Building No. Person Responsible for Plan

BTA 7th ATC 3000 EO/Manager

Kelley Barracks AAFES Gas Station 3325 Manager

Kelley Barracks DeCA Commissary 3317 Manager

Kelley Barracks 405th AFSB BASOPS 3320 EO/Manager

Kelley Barracks FMWR Arts & Crafts 3319 EO/Manager

Kelley Barracks O&M 3360 Roads and Grounds Chief

Kelley Barracks DPW Shops 3318 Supervisor

Panzer Kaserne Panzer Main Exchange, PX 2903 Manager

Panzer Kaserne AAFES CCC Shop 2935A EO/Manager

Panzer Kaserne AAFES CCC 2935A Director

Panzer Kaserne DeCA Commissary 2957 Manager

Panzer Kaserne 405th AFSB Logistic 2953 Director

Panzer Kaserne 405th AFSB HM- Reuse Center

2956 EO/Manager

Panzer Kaserne DPW 2941 Panzer IC

Panzer Kaserne FMWR Auto Skills Ctr.

2929 HWAP/

2930 Shop

Unit EO

Panzer Kaserne FMWR Bowling Ctr. 2988 Manager

Panzer Kaserne NSWU/2 Motorpool 2970 Unit EO

Panzer Kaserne PAO 2949 Manager

Panzer Kaserne Safety Office 2948 Manager

Panzer Kaserne Industrial Hygiene 2948 Chief

Panzer Kaserne TLSC-E/MAV Det. 2935B EO/Supervisor

Panzer Kaserne 1/10th SFG Motorpool 2969 Unit EO

Panzer Kaserne 554th MP Motorpool 2958 Unit EO

Panzer Kaserne Veterinary Clinic 2996 Unit EO

Panzer Kaserne Dental Clinic 2996 Unit EO

Panzer Kaserne DoDEA High School 3081 Principal

Patch Barracks AAFES Gas Station 2349 Manager

Patch Barracks DES MP Desk 2307 Chief

Patch Barracks Garrison Contractor 2333 Centerra

Patch Barracks DPW 2316 Patch IC

Patch Barracks DES Fire Dep. 2307 Chief

Patch Barracks Health Clinic 2300 Unit EO

Patch Barracks DeCA Commissary 2350 Manager

Patch Barracks FMWR Arts & Crafts 2329 EO/Manager

Robinson Barracks DPW 196 RB IC

Robinson Barracks DeCA Commissary 146 Manager

Stuttgart Army Airfield DOL/TMP 3241 Manager

Stuttgart Army Airfield Airfield Command 3255 Manager

Stuttgart Army Airfield Fire Department 3219/3254 Fire Station

Stuttgart Army Airfield VMR SPMAGTF C12W 3220 Unit EO

Stuttgart Army Airfield Transient Alert 3227 Unit EO

Stuttgart Weilimdorf Warehouse 5376 Manager

2-1

2 SPILL PREVENTION

This chapter of the SPRP provides procedures for the prevention of POL and HS spills within the USAG Stuttgart area of control whether on or off-installation. Maps providing water protection areas, etc. along with other pertinent information are included in Appendix 4. SOPs (Appendix 1) have been implemented to reduce the risk of spills by establishing consistent practices that are less likely to result in the uncontrolled release of POL and HS. Employees that work with POL and HS shall be familiar with the Evacuation Plan and inspection and surveillance procedures for POL and HS operations (Appendix 2).

All field operations, maneuvers, and exercises, whether on- or off-installations, must be performed in compliance with this SPRP. The spill prevention and response procedures in this plan also apply to activities at local training areas, major training areas, and maneuver rights areas. Many of the spill prevention and response procedures are modified for field conditions and the temporary nature of operations (e.g., portable secondary containment systems).

2.1 LEGAL BACKGROUND

USAG Stuttgart operates several Aboveground Storage Tanks (ASTs) and Underground Storage Tanks (USTs), mainly for the storage of diesel and heating oil, several Hazardous Waste Accumulation Points (HWAPs), e.g. at maintenance shops, motor pools, repair facilities, one Hazardous Waste Storage Area (HWSA) to which Hazardous Waste (HW) is conveyed to from the individual HWAPs. Several containers for the collection of waste household batteries (HWBATs) and for the collection of waste cooking oils at mess halls, cafeterias, and restaurants (HWCONs) are available. Furthermore, USAG Stuttgart operates an airfield, several gas stations and numerous oil/water separators (OWSs).

HS & POL storage and management requirements for all Department of Defense (DoD) installations in Germany are comprehensively regulated by the German Final Governing Standards (GFGS). The GFGS were developed by comparing and adopting the more protective criteria of the Overseas Environmental Baseline Guidance Document (OEBGD), applicable German national and state environmental laws and regulations and applicable international agreements. This document refers to the most current officially released version of the GFGS from December 2019.

The ordinance on facilities handling water-endangering substances (AwSV - Verordnung über Anlagen zum Umgang mit wassergefährdenden Stoffen) came into force in August 2017 to harmonize and replace the 16 state-individual regulations named “VAwS” (Verordnung über Anlagen zum Umgang mit wassergefährdenden Stoffen) under one national ordinance that is applicable in all German federal states. The ordinance replaces also the General Administrative Regulation under the Federal Water Act on the Classification of Substances Hazardous to Water in Water Hazard Classes (Verwaltungsvorschrift wassergefährdende Stoffe (VwVwS)).

The general purpose of the AwSV is to protect water bodies from negative impacts caused by release of substances hazardous to water.

The AwSV applies to stationary installations that handle, load, operate or store hazardous substances.

It does not apply to mobile facilities such as motor vehicles but, for example, to installations for refueling them with solid, liquid or gaseous substances or mixtures thereof that are hazardous to water.

The technical and organizational requirements of Chapter 3 of the AwSV do not apply to:

Facilities for storing household waste and similar waste;

Facilities for storing and treating biowaste within the framework of home composting in the private sector;

Facilities for storing solid commercial waste and solid commercial waste to which substances that are hazardous to water adhere, if

a) the volume of the storage tank does not exceed 1.25 m³, 2-2

b) the storage tank is leakproof,

c) the area on which the storage tank is installed is designed in such a manner that substances that are hazardous to water cannot reach a water body in the event of operational malfunctions, and

d) an absorbent suitable for operational malfunctions is kept on hand.

Facilities for storing solid mixtures that accumulate on the building site directly as a result of construction work.

Appendix 9 provides short excerpts of the most relevant paragraphs of the AwSV. The following two paragraphs with very important information are presented as examples.

§39 Hazard levels of facilities

(1) Operators must assign a hazard level to facilities according to the table below. In the case of liquid substances, the decisive volume for the facility in question should be taken as the basis, while the decisive mass for the facility in question should be taken as the basis in the case of gaseous and solid substances.

Table 2-1: Hazards levels based on volume and Water Hazard Class

Determination of the hazard levels (A, B, C, D) Water hazard class (WGK)

Volumes in cubic meters (m3) or mass in tons (t) 1 2 3

3 or 0.2 t Level A Level A Level A

> 0.22 m3 Level A Level A Level B

Level A Level B Level C

Level A Level C Level D

Level B Level D Level D

> 1000 Level C Level D Level D

More details to this table are described in sections (2) to (11) of §39 AwSV

§43 Documentation relating to the facility

(1) The operator shall keep documentation relating to the facility, which includes the key information pertaining to it. This includes, in particular, information on the layout and demarcation of the facility, on the substances used, the design, the materials used in the individual parts of the facility, on safety devices and safeguards, fire water retention and stability. In the event of a change of operator, the documentation must be handed over to the new operator.

More details are described in sections (2) to (3) of §43 AwSV.

2.2 SPILL PREVENTION STRUCTURES AND EQUIPMENT

POL and HS storage containers and devices must be constructed of materials that are compatible with the liquids they contain and the conditions in which they are maintained. The containers must be protective of human health and the environment (including water and groundwater).

Flammable/corrosive material storage lockers and buildings are used to store liquid POL and HS. Both devices have been constructed to contain spills on shelves or in a sump built into the device. Storage lockers for corrosives typically have plastic-lined shelves to contain the release of corrosive liquids.

Flammable/corrosive material storage lockers must be closed and locked when not in use to prevent unauthorized transfer of materials. These lockers are located on portions of the Garrison that are neither subject to flooding nor located in Water Protection Zones I or II.

Secondary containment systems (such as spill pallets, berms, and sumps) must be sufficiently impervious to retain substances released. They must be capable of retaining the entire volume of the

2-3 storage container. In case multiple containers are stored on one single secondary containment system, it must have the capacity to retain 100 % of the volume of the largest container, and at least 10 % of the total storage volume (see GFGS, Chapter C5.A5.1.1.5.). Open outdoor secondary containment systems shall contain sufficient freeboard for precipitation and product expansion.

Secondary containment systems may be equipped with control components, such as manual valves or drain plugs that are closed and locked when not in use to prevent accidental releases such as leaks from leaving the system.

To be effective, secondary containment systems need to be empty. Otherwise, the retention volume is reduced. Procedures for periodic inspections of all secondary containment systems, as well as above-ground tanks, valves, piping etc., must be included in the regular inspection schedule. If secondary containment systems are not empty, the contained material (liquids or solids) should be removed as hazardous waste, unless it is tested to be non-hazardous.

A spill response kit must be readily available at all work centers storing HS or POL.

At USAG Stuttgart several OWS are installed to separate POL from water that is discharged to the sewer system.

Separator Systems

OWS are used to separate free oil, and entrained oil droplets from water by intercepting these substances on top and allowing clean water to underflow. Emulsified oils may not be separated, as well as transformer fluids, other synthetic oils, and many other commonly used hazardous substances (such as antifreeze, solvents, or pesticides). Therefore, these substances must be prevented from entering POL separators.

The operation of an OWS requires frequent inspection and maintenance since the accumulation of oil and sludge can result in the undesired discharge of oil.

Note: To ensure proper functioning of the OWSs, high-pressure cleaning equipment may not be used with chemical agents and hot water should be avoided. Otherwise stabile emulsions may be generated that cannot be separated by the OWS.

2.3 MERCURY SPILL PREVENTION

Mercury is, for example, contained in compact fluorescent lights (energy-saving lamps) and fluorescent tubes. Furthermore, it is found in thermometers, barometers, certain batteries etc. In dental clinics, mercury-containing amalgam waste may occur.

Batteries containing mercury will be managed as HW regardless of whether they are to be recycled or disposed of permanently.

Mercury is not released during the intended use of illuminants or thermometers. Exposure can occur when lamps break e.g. during the replacement of lamps or during handling at waste collection points or storage areas (transport, loading and unloading activities). In case of lamp breakages, mercury can be released to the ambient air. The main health risk during a mercury spill is vapor inhalation.

Prevention measures

Fluorescent lights Do not replace defect lamps when they are still hot. A greater amount of mercury is released when a hot lamp breaks than when it is cold.

Defect illuminants are electronic scrap and must be disposed of as such. Bring them to your HWSA.

Illuminants shall be stored at locations with adequate ventilation, e.g. outside.

Store illuminants in a manner that will avoid breakage.

Avoid breaking illuminants during loading or transport of collection containers.

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Mercury-containing batteries Bring empty batteries to battery collection points or the HWSA.

Batteries containing mercury will be managed as HW (EWL Code 160603 “mercury-containing batteries”) regardless of whether they are to be recycled or disposed of permanently.

Amalgam Amalgam waste from dental care (amalgam from amalgam separators, amalgam residual, extracted teeth containing amalgam) must be collected separately and periodically disposed of (EWL Code 180110 “amalgam waste from dental care”).

Amalgam waste shall be segregated and securely stored in appropriate containers at the dental practice. The containers shall not be stored near heat sources or exposed to direct sunlight.

The amalgam in the containers shall be covered with water and the containers always kept closed.

2.4 INSPECTIONS

2.4.1 Aboveground Storage Tanks (ASTs)

Government-owned aboveground storage tanks (ASTs) > 1 m3, containing HS with water hazard class WGK (Wassergefährdungsklasse) 3 (e.g. waste oil) or ASTs > 10 m3 containing HS with WGK 2 (e.g.

diesel or heating oil) must be inspected every 5 years by an authorized expert (GFGS Chapter C5.3.14.3.1.3.1, and C5.3.14.3.1.7.1.)

The following tank-specific requirements must be verified during the inspection according to the regulatory requirements and as appropriate for the substance stored in the tank:

Tank specifications, such as size, contents, and construction type, are clearly indicated on each

AST.

Tank storage areas have secondary containment systems that are sufficiently impervious or capable of holding and containing leaks and spills of liquid or solid hazardous waste.

In addition to the aforementioned, all requirements outlined in Section 3.1 apply to tank systems storing hazardous waste.

According to the German ordinance on facilities handling water-endangering substances - AwSV the following inspection times and intervals apply to ASTs containing liquid or gaseous substances that are hazardous to waters, including heating oil tanks. Inspections must be conducted by authorized experts (zugelassene Sachverständige).

Table 2-2: ASTs not located within protection zones or floodplains

Before initial use and after substantial modification

Regular inspection:

Every 5 years

Upon decommission

WGK 3: ASTs >0.22 m3

WGK 2: ASTs >1 m3

WGK 3: ASTs >1 m3

WGK 2: ASTs >10 m3

WGK 3: ASTs >1 m3

WGK 2: ASTs >10 m3

Table 2-3: ASTs located within protection zones or floodplains

Before initial use and after substantial modification

Regular inspection:

Every 5 years

At closedown

WGK 3: ASTs >0.22 m3

WGK 2: ASTs >1 m3

WGK 3: ASTs >0.22 m3

WGK 2: ASTs >1 m3

WGK 3: ASTs >0.22 m3

WGK 2: ASTs >1 m32

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2.4.2 Underground Storage Tanks (USTs)

All USTs that store water-endangering substances must be inspected by an authorized expert (zugelassener Sachverständiger in accordance with AwSV) before their initial use, and each tank system must be inspected every 5 years, after the initial inspection, during the facility’s normal usage. For USTs in water protection areas, the inspection must be conducted at the latest 2.5 years after the last inspection (GFGS Chapter C5.3.14.3.). Inspection before the initial use of USTs and regular inspection intervals for USTs as stated above are the same according to GFGS and AwSV. At USAG Stuttgart, a water protection zone is located in parts of Patch Barracks and Mineral Spring Protection Areas cover the entire installations of Robinson Barracks, Boeblingen Officers Club, and Boeblingen Family Housing.

In addition, Panzer Kaserne is located within a Mineral Spring Protection Area, but there is an agreement with German authorities existing which exempts USTs at Robinson Barracks from this regulation, so an inspection interval of 5 years applies here.

Additionally, expert inspections will be conducted under the following conditions:

When significant modifications to the facilities are made, If the competent German authority issues an inspection request due to a suspected threat to water bodies, After decommissioning a facility, After the re-commissioning or re-opening of a facility that has been closed for more than one year.

2.4.3 All Storage Tanks (ASTs and USTs)

All ASTs and USTs must be inspected by a certified expert (Fachfirma) at least once a year and include a review of the operating and leak detection systems. The expert must provide inspection reports to DPW ED. Currently, USAG Stuttgart has contracted Centerra as the certified expert via Installation Management Contract (IMC).

Internal inspections on ASTs containing HS will be conducted based on applicable requirements defined by current SOPs, GFGS, AER 200-1 or other US Army procedures (see Appendix 2 for example checklists).

Problems identified by any tank inspection need to be appropriately addressed. Problems that are imminently dangerous to human health and the environment (such as leaking containers) must be remedied immediately (Appendix 4 presents areas that are prone to spills).

Records of the inspections must be entered to the tanks logbook and maintained for at least three years at the ED. Additionally, the results shall be entered into the applicable Database of the ED.

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3 SPILL CONTROL AND RESPONSE

This section of the SPRP describes the specific actions that are performed following a POL and/or HS spill within the USAG Stuttgart area of control, whether on or off the installations.

Initial spill action procedures are addressed in Figure 1 of the Red Plan (Appendix 7 and Appendix 8). The specific response to a spill also depends on site- and incident-specific variables, including the type and volume of the substance released, the media into which the material is released, the weather conditions during the release, and the environment where the material is released. If the identity of the spilled material is known, the SDSs (readily available in the vicinity of the storage area) will be immediately consulted and checked for specific information, including physical/chemical properties, health hazards, and spill response and cleanup procedures.

3.1 INCIDENT EVALUATION

The incident shall first be evaluated to identify actual or potential threats to life or human health, but also to identify risks to the environment. All fire, explosions, or threats thereof, are considered threats to life, human health, and the environment. If an actual or potential threat to life or human health is identified, an evacuation shall be initiated. The incident shall be immediately reported to points of contact (POCs) contained in Table A- 7.1 (Appendix 7, Red Plan) and Table A- 8.1 (Appendix 8, Red Plan German).

Actual and potential fires and/or explosions shall be eliminated before any other action related to the incident is initiated. Fire/explosion suppression activities will continue throughout the emergency response as determined by DES.

Fire suppression water and other runoff from burning POL and HS must be immediately controlled.

Prevent the spread of these liquids by blocking floor drains, damming flow, or by other means.

Collected runoff water must be tested and treated if required.

If the incident does not pose a threat to life or human health, the spill component of the incident shall be evaluated. If the spill cleanup is beyond the capability of the person(s) identifying the incident, Figure 1 in the Red Plan (Appendix 7 and Appendix 8) provides information on immediate response actions.

Spills that are minor (small) and of a known substance will be cleaned up by trained personnel immediately. SDSs will be referenced to identify proper containment, recovery, and storage procedures. Waste materials shall be containerized for future disposal. An incident summary shall be prepared and maintained by the EO.

3.2 SPILL ASSESSMENT

The FRT shall assess the spill to identify the need for immediate government agency notifications (i.e., if a significant spill has occurred) and potential future evacuation conditions; and to formulate a control, containment, and recovery plan. If the spill requires resources beyond those possessed by the FRT, then outside government agencies identified in Table A- 7.1 (Appendix 7, Red Plan) and Table A- 8.1 (Appendix 8, Red Plan German) shall be contacted. Access to the spill area shall be immediately limited to authorized personnel, managed by the Military Police.

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3.2.1 Determine Safe Actions

Knowledge of the spilled material properties and the prevailing weather conditions are critical components in the determination of safe actions. Any information related to the spilled materials (especially SDSs) will be reviewed to identify chemical and physical properties, exposure potential, and spill response procedures. The following additional information will be evaluated:

A safe way to approach the spill and stage response equipment, vehicles, and personnel.

Personal protective equipment (PPE), including respiratory protection, appropriate to potential exposure risks.

Methods to monitor and mitigate any fire and safety hazards to response personnel or neighboring communities from vapors, gases, dust, or free product throughout the entire response. This may include the use of explosion-proof pumps and non-sparking recovery equipment.

Areas to be secured, as well as decontamination areas for personnel and equipment.

Potential medical needs. Identify hospital(s) needed to assist with medical emergencies during a response.

3.2.2 Stopping Spills

Once a safe course of action has been identified, the spill and spread of materials shall be stopped or slowed down. The method used to stop the spill source will be determined by the physical conditions causing the spill. This may involve closing a valve, deactivating a pump, up-righting an overturned container, plugging a leaking container, or transferring a container’s contents to another container.

Depending on the availability of personnel, spill containment activities will either be performed during or following actions to stop the spill source. Containment activities will be prioritized according to potentially impacted resources, based partially on the following ordered list:

1. Drinking water sources

2. Storm water structures

3. Wastewater treatment plants (see Appendix 6)

4. Water or other habitats designated as sensitive or ecologically critical (consult Appendix 4 to identify critical water resources and other special areas of concern that must be protected in the event of a spill)

5. Other surface waters (see Appendix 4)

6. Soil

7. Air

Spill containment actions will be dictated by the surface upon which the material has been spilled.

On paved or other hardened surfaces, booms and/or berms shall be placed at the leading edge of the spill to attempt to stop or delay the spill advance.