TE A-6.7 - Spill Prevention Control and Countermeasure Plan.docx

Final Fort Gordon Spill Prevention, Control and Countermeasure (SPCC) Plan

Version: 3 June 2019

Prepared for

Directorate of Public Works, Environmental Division, U.S. Army Garrison Fort Gordon

Prepared by

ESD – Compliance Branch US Army Environmental Command 2450 Connell Road Fort Sam Houston, Texas 78234

FOR OFFICIAL USE ONLY

Fort Gordon BASOPS Technical Exhibit A-6.7 Spill Prevention Control and Countermeasure (SPCC) Plan

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Fort Gordon SPCC Page ii June 2019

Table of Contents

Fort Gordon SPCC Page viii June 2019

LIST OF ACRONYMS

40 CFR 112 CROSS REFERENCE TABLE

Appendix C

Fort Gordon SPCC Page x June 2019

1.0 CERTIFICATIONS

1.1 PROFESSIONAL ENGINEER CERTIFICATION

Regulatory Requirement: A licensed Professional Engineer must review and certify a Spill Prevention Control and Countermeasure (SPCC) Plan for it to be effective to satisfy the requirements of Title 40, Code of Federal Regulations (CFR), Part 112.3 (40 CFR §112.3(d)).

By means of this certification, the Professional Engineer attests that:

· He is familiar with the requirements of the U.S. Environmental Protection Agency (EPA) Regulations on Oil Pollution Prevention (40 CFR 112), including amendments.

· He or his agent has visited and examined the facility.

· The SPCC Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of 40 CFR 112.

· Procedures for required inspections and testing have been established.

· The SPCC Plan is adequate for the facility.

A comprehensive site review was conducted at Fort Gordon and observed compliance deficiencies were identified in Appendix B. The following certification is contingent on timely completion of action items associated with these deficiencies in accordance with the implementation schedule that is provided in Section 4.

Ramon A. Cintron-Ocasio Certifying Professional Engineer

CINTRONOCASIO.RAM ON.A.1182677805

Digitally signed by CINTRONOCASIO.RAMON.A.1182677805 Date: 2019.06.03 08:46:46 -05'00'

Signature

3 June 2019 Seal affixed:

Date

71770

Registration Number

Texas State of Registration

Fort Gordon SPCC June 2019

1.2 APPLICABILITY OF SUBSTATIAL HARM CRITERIA

Regulatory Requirement: If the owner or operator of a facility determines that the facility will not be expected to cause substantial harm as defined by the criteria listed under Appendix C to 40 CFR 112 (decision criteria depicted in below flow chart), the owner or operator shall complete and maintain at the facility the certification form of the applicability of the substantial harm criteria, found in Section 1.2 of this Plan. (40 CFR §112.20[e])

YesHas the facility experienced a reportable oil spill in an amount greater than or equal to 10,000 gallons within the last 5 years?

Is the facility located at a distance2 such that a discharge from the facility would shut down a public drinking water intake3?

Is the facility located at a distance1 such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments2?

Within any aboveground storage tank (AST) area, does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation?

SUBMIT RESPONSE PLAN

Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons?

NoDoes the facility have a total oil storage capacity greater than or equal to 1,000,000 gallons?

Yes

No

No YesNO SUBMITTAL OF RESPONSE PLAN EXCEPT AT REGIONAL ADMINISTRATOR DISCRETION

NOTES:

1. Distance is calculated using the appropriate formula described in Attachment C-III to Appendix C of 40 CFR 112, or using a comparable formula. If a comparable formula is used, documentation of the reliability and analytical soundness of the comparable formula must be attached to certification form.

2. For further description of fish and wildlife and sensitive environments, see Appendixes I, II, and III to the Department of Commerce/National Oceanic and Atmospheric Administration’s Guidance for Facility and Vessel Response Plans: Fish and Wildlife and Sensitive Environments (59 Federal Register 14713, 29 March 1994), and the applicable Area Contingency Plan.

3. Public drinking water intakes are analogous to public water systems as defined under 40 CFR 143.2(c).

1.3 APPLICABILITY DETERMINATION

Regulatory Requirement: If the owner or operator of a facility determines that the facility will not be expected to cause substantial harm as defined by the criteria listed under Appendix C to 40 CFR 112 (decision criteria depicted in the flow chart in Section 1.3), the owner or operator shall complete and maintain at the facility the certification form of the applicability of the substantial harm criteria.

40 CFR 112.20(e) requires that affected facilities determine their potential to cause Substantial Harm and file a Facility Response Plan with the EPA Regional Administrator, if necessary. The questions below regarding facility processes and storage capacity aid in determining the Applicability of the Substantial Harm. Section 1.2 shows the flow chart of Criteria for Substantial Harm from 40 CFR 112.20(e). Fort Gordon does not pose a threat of substantial harm to fish and wildlife sensitive environment, or a drinking water intake.

1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons?

Yes No X

2. Does the facility have a total storage capacity greater than or equal to 1,000,000 gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation within any aboveground oil storage tank area?

Yes No X

3. Does the facility have a total oil storage capacity greater than or equal to 1,000,000 gallons and is the facility located at a distance (as calculated using the appropriate formula in 40 CFR 112, Appendix C, Attachment C-III, or comparable formula) such that a discharge from the facility would cause injury to fish and wildlife and sensitive environments?

Yes X No

4. Does the facility have a total oil storage capacity greater than or equal to 1,000,000 gallons and is the facility located at a distance (as calculated using the appropriate formula in 40 CFR 112, Appendix C, Attachment C-III, or comparable formula) such that a discharge from the facility would shut down a public drinking water intake?

Yes X No

5. Does the facility have a total oil storage capacity greater than or equal to 1,000,000 gallons and has the facility experienced a reportable oil discharge in an amount greater than or equal to 10,000 gallons within the last 5 years?

Yes No X

1.4 MANAGEMENT APPROVAL CERTIFICATION

Regulatory Requirement: The owner or operator of a facility subject to 40 CFR 112 must have full approval of management at a level of authority to commit the necessary resources to fully implement the SPCC Plan. (40 CFR §112.7)

This SPCC Plan, prepared by the U.S. Army Environmental Command, has been reviewed by personnel under my supervision in accordance with 40 CFR 112.7. I have the authority to commit the necessary resources to fully implement this SPCC Plan and action items identified in this SPCC Plan.

Garrison Commander Date Fort Gordon

2.0 AVAILABILITY OF SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN

Regulatory Requirement: The owner or operator of a facility for which a SPCC Plan is required under 40 CFR 112 must maintain a complete copy of the SPCC Plan at the facility and the SPCC Plan shall be made available upon request. (40 CFR §112.3(e))

SPCC Plans for facilities are prepared and implemented as required by the EPA regulation contained in 40 CFR 112. A non-transportation-related onshore facility4, i.e., Fort Gordon could reasonably be expected to discharge oil into or upon the navigable waters5 of the United States due to the facility’s location, and is thus subject to 40 CFR 112 when one of the following conditions are met by the facility:

The underground storage capacity6 at the facility exceeds 42,000 gallons. The total aboveground storage capacity of the facility exceeds 1,320 gallons.

The facility’s SPCC Plan is not required to be filed with EPA; however, a copy of this SPCC Plan must be available to regulatory agency personnel upon request. This document is the SPCC Plan (or Plan) for Fort Gordon. This Plan has been prepared in accordance with 40 CFR 112 as amended on 17 July 2002, 17 April 2003, 12 December 2005, 26 December 2006, and 16 May 2007.

The SPCC Program Manager in the Directorate of Public Works – Environmental Division (DPW- ED) is responsible for maintaining this Plan and for discharge prevention. A copy of this Plan is maintained onsite with DPW-ED and the Fire Department.

According to 40 CFR 112.1, Fort Gordon requires an SPCC Plan. The facility-wide aboveground oil storage capacity totals more than 1,320 gallons, and oil discharges could reach navigable waters. Army Regulation 200-1, Chapter 3, Paragraph 3.3b (1) states, “Include hazardous materials (polychlorinated biphenyls) and hazardous wastes in spill prevention control and countermeasure planning.” Hazardous materials that are stored near SPCC regulated containers are included in this SPCC Plan.

4. A non-transportation-related onshore facility is defined as a facility that is located in, on, or under land and its operations do not include the transportation of oil outside of the facility (Appendix A to 40 CFR 112.2).

5. Navigable waters include: (1) all navigable waters of the United States and tributaries of such waters as defined in the Federal Water Pollution Control Act; (2) interstate waters; (3) intrastate lakes, rivers, and streams that are utilized by intrastate travelers for recreational or other purposes; and (4) intrastate lakes, rivers, and streams from which fish or shellfish are taken and sold in interstate commerce.

6. The completely buried storage capacity of a facility excludes the capacity of a completely buried tank (as defined in 40 CFR 112.2), connected underground piping, underground ancillary equipment, and containment systems that are subject to the requirements of 40 CFR 280 or the requirements of a state program approved under 40 CFR 281.

Fort Gordon SPCC

3.0 AMENDMENTS TO SPCCP

3.1 AMENDMENTS BY U.S. EPA REGIONAL ADMINISTRATOR

Regulatory Requirement: EPA may require the facility to amend the SPCC Plan if it finds that the SPCC Plan does not satisfy the requirements of 40 CFR 112, or if amendment is necessary to prevent and contain discharges from the facility. A spill event to navigable waters may subject the facility to additional reporting requirements of 40 CFR 112.4. (40 CFR §112.4[d])

This SPCC Plan will be amended under the following conditions:

· The facility discharges a harmful quantity7 of more than 1,000 gallons of oil in a single discharge, or more than 42 gallons of oil in each of two discharge events within a 12- month period.

· The EPA Region IV Administrator determines that the information contained herein does not meet the requirements of 40 CFR 112.

3.2 AMENDMENTS BY OWNER/OPERATOR

Regulatory Requirement: The SPCC Plan shall be amended within 6 months of whenever there may be a change in the facility design, construction, operation, or maintenance that materially affects the facility’s potential for discharge. The amendment must be implemented as soon as possible and not later than 6 months following preparation of the amendment. (40 CFR §112.5[a])

Complete review and evaluation of the SPCC Plan must occur at least once every 5 years. The SPCC Plan shall be amended within 6 months of the review to include more effective prevention and control technology if such technology has been field-proven at the time of review and will significantly reduce the likelihood of discharge from the facility. The amendment must be implemented as soon as possible and not later than 6 months following preparation of the amendment. Review and evaluation of the SPCC Plan must be documented, including a signed statement as to whether or not the SPCC Plan will be amended. (40 CFR §112.5[d])

A Professional Engineer must certify any technical amendments to the SPCC Plan in accordance with 40 CFR 112.3. (40 CFR §112.5(e))

7. A harmful quantity is defined by 40 CFR 110 as a quantity that either: (1) exceeds applicable water quality standards, or (2) causes a film or sheen upon or discoloration of the surface of the water or adjoining shorelines or causes a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines.

Fort Gordon SPCC June 2019

This SPCC Plan will be amended when necessary, as specified in 40 CFR 112.5, and reviews or updates will be documented in Appendix A of this plan. Specifically, this Plan will be reviewed and evaluated at least once every 5 years. This Plan will also be updated whenever there is a change in the facility design, construction, operation, or maintenance that materially affects its discharge potential. Due to the amount of equipment, number of tenants and dynamic nature of operations at Fort Gordon, it may not always be possible to be aware of changes and provide an update of within 6 months. Fort Gordon DPW-ED continues to reach out to tenant organizations and purchasing activities to be notified as soon as changes are made.

Potential changes to the SPCC Plan may include:

· Commissioning or decommissioning of containers,

· Replacement, reconstruction, or movement of containers,

· Reconstruction, replacement, or installation of piping systems,

· Construction or demolition that might alter secondary containment structures,

· Changes of product or service,

· Revision of standard operation and maintenance procedures at facility.

Additionally, the owner or operator may amend the SPCC Plan with technical changes that may include changes to specific security measures and/or to prevention and control technologies.

Technical amendments made to the SPCC Plan must be certified by a Professional Engineer. Movement of containers within an area that does not increase either the likelihood or the potential severity of a discharge would not require an update to the Plan.

The current individual responsible for reviewing potential changes to this SPCC Plan is the DPW- ED Compliance Branch Chief or Storage Tank Manager. Each review and evaluation will be documented in Appendix A.

3.3 PLAN REVIEW AND SUBMITTAL

Required Plan amendments must be prepared within 6 months of the change in operation, and implemented as soon as possible, but not later than 6 months following preparation of the amendment. DPW-ED must review the Plan, and if all changes are non-technical (e.g., contact name, phone number, container identification number, etc.), indicate that no technical changes were made. If there are any technical amendments to the Plan, then a Professional Engineer must recertify it.

In accordance with 40 CFR 112.5(b), this Plan shall be reviewed at least once every five years. If there are no changes to the Plan, the DPW Environmental Division Chief will certify the following statement: "I have completed a review and evaluation of this SPCC Plan for Fort Gordon and will not amend the Plan as a result."

4.0 REGULATION COMPLIANCE AND ACTION ITEMS

Regulatory Requirement: If the SPCC Plan calls for additional facilities or procedures, methods, or equipment not yet fully operational, these items must be discussed in separate paragraphs and must include the details of installation and operational startup. (40 CFR §112.7)

This Plan has been developed per the requirements listed in 40 CFR 112 and Georgia regulations. This SPCC Plan includes corrective actions that require implementation. Appendix B shows the corrective actions that should be completed within 6 months. Periodic inspections, tests, and evaluations will be conducted to identify future non-compliance issues if they arise so that they may be promptly addressed and the SPCC Plan may be appropriately amended, if necessary.

The facility’s management is responsible for completing Appendix B with the date(s) that work is completed. Facilities that are unable to implement their Plan within 6 months of certification must submit a written extension request to the Regional Administrator in accordance with the requirements of 40 CFR 112.3(f). Due to the Army’s funding process, Fort Gordon may not be able to complete these changes within a 6-month time period. Fort Gordon will show a good faith effort through submittal of proper work and funding requests to address these issues. Any updates to the Plan should include these signature pages showing the implemented corrective actions. Completed action items will be removed from the list at the next SPCC Plan revision.

Fort Gordon SPCC

5.0 FACILITY DESCRIPTION AND DISCHARGE PREVENTION

Regulatory Requirement: The SPCC Plan must describe the physical layout of the facility and include a facility diagram that marks the location and contents of each fixed oil storage container and the storage areas where mobile or portable containers are located. If applicable, the facility diagram must include completely buried tanks that are otherwise exempted from the requirements under 40 CFR 112.1(d)(4). The type and volume of oil in each container that is stored at the facility must be described in the SPCC Plan.

Additionally, discharge prevention measures, secondary containment, discharge countermeasures, disposal methods, and emergency contacts must also be addressed in the SPCC Plan. (40 CFR §112.7(a)(3))

5.1 FACILITY INFORMATION

Facility Name and Address: Fort Gordon 307 Chamberlain Avenue Fort Gordon, GA 30905-5730

Facility Description: Active military installation involved in the total force and total Army training and readiness training.

Facility Owner: U.S. Army

Facility Operator: Commander, U.S. Army Garrison, Fort Gordon

Facility Tenants: Supports Army battalion and division training

Total Aboveground Storage Capacity: 551,773 gallons Total Underground Storage Capacity: 626,000 gallons

5.2 FACILITY DESCRIPTION

Fort Gordon Military Reservation is located in east central Georgia approximately 9 miles southwest of the City of Augusta, occupying approximately 56,000 acres in Columbia, Jefferson, McDuffie, and Richmond counties, where most of the property is in Richmond County. The local area is referred to as “CSRA”, which stands for the Central Savannah River Area, a group of 13 Georgia and South Carolina counties along the Savannah River that forms the state border. The Fort Gordon Military Reservation is bordered to the west by GA Highway 42, to the southwest by County Road 29/Old Warrenton Road, to the southeast by Deans Bridge Road, to the northeast by The J. Strom Thurmond/Butler/Fort Gordon Reservoir, and to the north by Gordon Highway. A majority of the structures and developed areas at Fort Gordon are located on the northeastern end of the reservation south of Gordon Highway and consists of various office buildings and training facilities, military barracks and housing, dining and entertainment facilities, a hospital complex, an elementary school, site and vehicle maintenance workshops, open equipment storage areas, the Gibson Avenue Landfill, the Gordon Lakes Golf Courses.

It should be noted that a separate SPCC plan has been prepared for the Fort Gordon Marina/Pointes West Army Resort (PWAR), which is located 21 miles north-northwest of the Fort Gordon Military Reservation. This outlying facility is used as a recreational area for military personnel, dependents, retirees and DoD civilians.

The major drainage features on Fort Gordon Military Reservation include Butler, Spirit, South Prong, Sandy Run, Boggy Gut, and Brier Creeks (these drainage features are shown on the Fort Gordon Installation Map in Appendix C. The streams are small and bordered by heavy swamps. There are multiple lakes, ponds and reservoirs on the installation (Maxwell and Scout lakes are no longer impounded).

The streams that receive storm water runoff from the developed area of the Fort Gordon Military Reservation are Butler Creek and its tributaries, as well as Spirit Creek and its tributaries including McCoys Creek. Butler Creek originates north of the installation boundary and drains to the southeast into the Savannah River. The portion of the Butler Creek Watershed that lies north of Fort Gordon covers approximately 13 square miles in Richmond and Columbia Counties. Fort Gordon owns approximately 5 to 10 percent of this portion of the watershed with the remainder owned by state and local governments and private landowners.

5.3 FACILITY OIL STORAGE

Regulatory Requirement: The SPCC Plan must describe the type of oil in each container and its storage capacity. For mobile or portable storage containers, either provide the type of oil and storage capacity for each container or provide an estimate of the potential number of mobile or portable storage containers, the types of oil, and anticipated storage capacities. (40 CFR §112.7(a)(3)(i))

A full-size map of all POL locations is maintained at the Fort Gordon Environmental Division. Appendix C depicts a small version of the full map. Fort Gordon has approximately 100 Petroleum, Oil and Lubricants (POL) and used cooking oil storage sites located throughout the facility. All containers that hold SPCC-regulated oils and have a volume greater than 55 gallons are considered SPCC-regulated containers with the exception of regulated USTs. SPCC-regulated oils include petroleum and non-petroleum oils. The following SPCC-regulated oils are used at Fort Gordon:

· Gasoline

· Diesel Fuel/F24

· Engine Oil

· Transformer Oil

· Mineral Spirits

· Hydraulic Fluid

· Vegetable Oils and Grease

· Used oils and Sludge

These products are stored in a variety of containers including ASTs, USTs, emergency generator tanks, electrical operating equipment (transformers), hydraulic equipment, elevators, 55-gallon drums, and smaller containers. Tables listing the tank construction, contents, capacity and other information regarding these storage sites are presented in Appendix D. Storage sites include active aboveground storage tanks (Table D.1), active SPCC-regulated USTs (Table D.6), active USTs that are regulated under 40 CFR 280 (Table D.6), active integral generator ASTs (Table D.2), active mobile refuelers (Table D.3), used cooking oil containers (Table D.4), and POL drum storage areas (Table D.5). Table D.7 contains a list of ASTs and USTs which are inactive. It is recommended that these tanks be permanently closed in accordance with 40 CFR 112.2 which defines “permanently closed” as follows:

· All liquid and sludge has been removed from each container and connecting line; and

· All connecting lines and piping have been disconnected from the container and blanked off, all valves (except for ventilation valves) have been closed and locked, and conspicuous signs have been posted on each container stating that it is a permanently closed container and noting the date of closure.”

An overall diagram of the entire facility identifying all the POL and used cooking oil storage site locations is included in Appendix C, while photos for site locations are included in Appendix F.

In addition, an active Geographic Information System database is available on the shared drive of Fort Gordon. The information presented in this format is designed to let the user view information on the computer for the entire base.

All OWSs at Fort Gordon are used for wastewater treatment and are not regulated under 40 CFR 112.

Also, transformers located on Fort Gordon which are regulated by 40 CFR 112 are not included in this plan because they are addressed separately by Georgia Power Company. Georgia Power Company located in Atlanta Georgia, completed an SPCC plan that includes the transformers at Fort Gordon. Georgia Power Company’s SPCC plan addresses specific issues with regard to transformers and other oil filled electrical equipment. In addition, POL tanks and drum storage containers are included in their plan.

5.4 ABOVEGROUND STORAGE TANKS

ASTs at Fort Gordon include bulk storage tanks, dispenser tanks, used oil collection tanks, non-residential heating oil tanks, emergency power generators, and grease dumpsters.

ASTs are designed with the structural components of the storage tank above the ground, and employ a variety of design features to prevent spills, leaks, and fire hazards. The container inventory including inactive containers is presented in Appendix D.

There are a wide variety of AST designs at Fort Gordon including vertical, horizontal, rectangular, and cylindrical. ASTs are either placed directly on the ground surface or are elevated such that the bottom of the tank can be inspected. The volume, material, design, and location of ASTs at Fort Gordon typically varies depending on the mission or tenant needs. Typically, ASTs at Fort Gordon are steel, shop-constructed, horizontal, and either rectangular or cylindrical in shape, with supports elevating the tank above the ground surface. However, there are a few vertical, field constructed, bulk storage tanks used on Fort Gordon. Bulk storage tanks are located directly on the ground and are cylindrical in shape with flat tops and bottoms. Regardless of tank material or shape, ASTs usually include a shell, fill, drain, overfill protection, vent, spill boxes, valves, pumps, ladders, level sensors, and gauges.

5.5 OIL-FILLED OPERATIONAL EQUIPMENT

Oil-filled operational equipment is equipment that includes an oil storage container (or multiple containers and associated piping intrinsic to the operation of the equipment) in which the oil is present solely to support the function of the apparatus or the device. This type of equipment is not considered a bulk storage container.

Some examples include, but are not limited to hydraulic systems, lubricating systems, machining coolant systems, heat transfer systems, transformers, circuit breakers, electrical switches, and other systems containing oil solely to enable the operation of the device.

Although oil-filled operational equipment is regulated under the SPCC Rule and included in the facility’s total oil storage capacity, they are not required to follow specific requirements that pertain to bulk storage containers (e.g., secondary containment, overfill alarms, etc.). The following oil-filled operational equipment has been identified at Fort Gordon:

· Transformers containing dielectric fluid located outdoors at substations throughout the facility,

· Hydraulic systems for elevators (passenger and freight) and vehicle lifts located indoors throughout garrison.

Appendix D provides an inventory of the equipment. As previously stated, Fort Gordon has a variety of tenants with various operational requirements; therefore, oil-filled operational equipment is frequently added or removed from the garrison without notification.

5.6 DRUMS

There are multiple drum storage areas located throughout the garrison. A number of the drum storage locations have been identified in Table D.4. However, the number of drums stored onsite in each area varies depending on operational and mission needs and frequently changes.

5.7 DISCHARGE PREVENTION MEASURES

Regulatory Requirement: The SPCC Plan must describe discharge prevention measures including procedures for routine handling of products (loading, unloading, and facility transfers, etc.). (40 CFR §112.7(a)(3)(ii))

The SPCC Plan should also describe discharge or drainage controls such as secondary containment around containers and other structures, equipment, and procedures for discharge control. (40 CFR §112.7(a)(3)(iii))

The ASTs at Fort Gordon are equipped with a mechanical visual and/or automatic tank gauging system. The tank gauges can be used to prevent discharges during product handling. At a minimum, the automatic tank gauging systems detect product level.

Product level measurements combined with the traditional “sticking” method can provide the fuel delivery truck operator with assurance to the inventory of the AST, and prevent overfills. Appendix D contains a description of each tank system at Fort Gordon; additional discharge information is included in the Fort Gordon FRP.

Currently, the predominant method of discharge detection would occur through visual inspection by Fort Gordon personnel. At a minimum, visual inspections are conducted on a monthly basis as part of Fort Gordon’s SPCC Plan compliance program.

5.8 DISCHARGE PREVENTION AT FUEL DELIVERY LOCATIONS

Tanks that are properly maintained and inspected can still be at risk for spills and leaks when the stored material is replenished through refueling operations. During oil delivery operations, a higher potential exists for a release of oil through equipment failure or operator error.

Drivers operating a truck tank or transport for oil delivery at Fort Gordon shall comply with the following requirements:

· National Fire Protection Association Standard 385 Tank Vehicles for Flammable and Combustible Liquids, 2000;

· Shall be 21 years old or older;

· Shall load or unload in approved locations only;

· Shall ensure that all drainage valves are properly closed on secondary containment units;

· Shall remain within 10 feet and in full and immediate control of the nozzle, shut-off valves, pumps, and emergency operating mechanism for the discharge control valve at all times when loading or unloading oil, and shall stand in a position so as to have the loading or delivery receptacle in full view;

· Shall remain alert while the transfer is in progress and shall report immediately any unusual condition involving the transfer operation, such as spills, any obvious discrepancies between the quantities delivered and received, or the existence of any equipment defects or unsafe delivery conditions;

· Shall use proper hoses and fittings and ensure hose connections are tight;

· Shall ensure the volume to be delivered can be properly contained.

Within the garrison, the driver of the fuel delivery truck is responsible for properly checking the tank and existing oil volume prior to beginning refueling operations. Prior to refueling oil into an AST, the liquid level shall be gauged, and the measurement shall be recorded in writing. This gauging prevents overfilling and spills. The tank volume can be verified in a number of ways including the following:

· Gauging the tank;

· Using a functional vent whistle;

· Inquiring of the capacity and contents from the tank owner or operator using an approved overfill alarm;

· Using a method approved by State regulators.

5.9 CONTAINERS NOT COVERED BY THIS PLAN

Containers owned and operated by contractors temporarily working on Fort Gordon property are not covered by this Plan. Such containers may include fuel tanker trucks or temporary ASTs. Each contractor is responsible for determining SPCC applicability and developing a site-specific Plan, if necessary.

Contractor-related spill response activities may and frequently do still involve Fort Gordon personnel. Contractors should be provided with a copy of the emergency response procedures, which states immediate actions to take in the case of an emergency.

USTs subject to the technical requirements of 40 CFR 280 are exempted from all SPCC requirements (40 CFR 112.1(d)(2)(i). However, they must be shown on the facility maps. Fort Gordon owns and operates USTs with a total underground storage capacity of

626,000 gallons that are subject to this exemption.

EPA did not intend to regulate fuel tanks with greater than a 55-gallon capacity that provide motive power for large trucks, earthmovers, recreational vehicles, and other such equipment and as such are not included in this Plan. Amendments to 40 CFR 112 exempt all “motive power” containers (i.e., vehicle gas tanks) from SPCC plan requirements.

6.0 SPILL REPORTING

Regulatory Requirement: Unless the facility has submitted a response plan under 40 CFR 112.20, the SPCC Plan must provide information and procedures to enable a person reporting a discharge to relate information required under 40 CFR 112.7(a)(4). (40 CFR §112.7(a)(4))

Portions of the SPCC Plan should be organized to describe procedures that will be used when a discharge occurs in a way that will make them readily usable in an emergency, and should also include appropriate supporting material as appendices. (40 CFR §112.7(a)(5))

All persons at Fort Gordon have been instructed to immediately contact the Fire Department for spill response initiation or in the event of an emergency. As an active military installation, Fort Gordon has a variety of hazards, including chemical, biological, and explosives that should only be responded to by trained personnel. Those responding to an oil release or spill must be properly trained in the emergency response procedures and the unique hazards associated with Fort Gordon. In the event that a spill cannot be contained by area personnel or the Fort Gordon Fire Department, the appropriate outside emergency response contractor should be contacted immediately. The information contained in the Spill Response Notification Form (Appendix J) should be given to the responder when reporting a spill.

Oil spills to navigable waters in harmful quantities, as defined in 40 CFR 110, must be reported to federal, state, and local agencies. Any quantity of oil released that reaches storm sewers or surface water should be reported to the appropriate agency contacts listed in the following sections. Upon immediate detection of a discharge and prior to reporting a spill, the Spill Response Notification Forms provided in Appendix J will be completed to help facilitate reporting to the appropriate agencies.

6.1 REPORTING SPILLS TO STATE AGENCY

DPW-ED is responsible for reporting in connection with spills of oil, fuel, hazardous and toxic materials, and waste. DPW-ED will ensure that reportable release are reported to federal and state agencies, as required.

6.2 REPORTING SPILLS TO FEDERAL AGENCY (40 CFR 112.4)

The facility owner or operator must notify the EPA Region IV Regional Administrator if the facility discharges a harmful quantity of more than 1,000 gallons of oil in a single discharge, or more than 42 gallons of oil in each of two discharge events within a 12- month period. The facility owner or operator must notify the National Response Center immediately after he or she has knowledge of a discharge of harmful quantity (i.e., “harmful quantity” of oil is discharged to navigable waters). Discharges that are reported to the National Response Center are also required to be reported to EPA (Appendix J). Spill information must be reported to EPA within 60 days of the incident. The spill report form that is used to notify Georgia EPD can also be submitted to EPA.

6.3 SPILL RESPONSE

If a spill occurs, garrison personnel follow appropriate response and reporting procedures. If the individual is from the organization where the spill occurred and is capable of beginning the initial response actions to the spill, then the spill response may be initiated. However, if the individual is not from the organization or is incapable of initiating spill response, then the individual is responsible for assisting the first responder in providing details about the spill discovery.

The DPW Base Ops Spill Team is the primary spill responder and can be reached from any garrison phone by dialing 911. Appendix H lists agencies that the DPW Environmental may need to contact to report a spill. The DPW Environmental is responsible for reporting spills to other agencies.

Spill reporting may include notifications to the National Response Center. EPA does not distinguish between types of oil, and any spill that causes a sheen upon “navigable waters” or that violates applicable water quality standards must be reported to the National Response Center (40 CFR 110.6).

Fort Gordon emergency equipment storage area contains sufficient materials to respond to, safely contain, and clean up a variety of spill types and volumes. There are fully encapsulating protective suits, overpack drums, disposable shower, sodium bicarbonate, lime, oil absorbent booms, sheets, pads, granular materials, and socks. For larger spills, DPW has tools (shovels, rakes, picks, etc.) and earthmoving equipment (bulldozers, backhoes, excavators, etc.) to control and contain spills until full cleanup and removal can occur. Recovered oils will either be handled as used oil or as Resource Conservation and Recovery Act (RCRA) hazardous waste depending on the type of oil and presence of contamination (other chemicals, dirt, water, etc.). Spills that exceed the capabilities of the Fire Department will be responded to by an outside contractor.

6.4 RECORDKEEPING

DPW-ED maintains regular inspection and test records for all tanks in accordance with 40 CFR 112.7(e); these records are maintained for a minimum of 3 years. DPW maintains inspection and testing records for certified inspections (where required) for the life of the container. General inspection and testing procedures for containers are described in more detail in Section 8. The spill history documentation should be maintained onsite in a single location to ensure efficient and complete recordkeeping.

6.5 SPILL HISTORY

The Fort Gordon Fire Department maintains a spill history log for spills at Fort Gordon to which the Fire Department responds. The spill history in Appendix E shows dates, quantities, and causes for all spills at Fort Gordon for the last 3 years. Reports of all spills over 6 gallons are maintained with the Fort Gordon Fire Department. Spill logs are also maintained by some of the tenant organizations and are available upon request.

7.0 DESCRIPTION OF POTENTIAL DISCHARGES

Regulatory Requirement: Where experience indicates a reasonable potential for equipment failure (such as loading or unloading equipment, tank overflow, rupture, leakage, or any other equipment known to be a discharge source), include in the SPCC Plan a prediction of the direction, rate of flow, and total quantity of oil which could be discharged from the facility as a result of each type of major equipment failure. (40 CFR §112.7(b))

Discharges of oil can potentially occur due to equipment malfunction or tank loading and unloading operations. In the event of a release, potential discharge directions, rates, and volumes for ASTs are described in Appendix D and Table 7.1. Possible spill directions are listed in Appendix I. The likelihood of a spill from each storage site reaching a surface water body is listed in the Appendix D. The Tables also list the surface water body when the likelihood of reaching a surface water body is high. Any spills that have been reported to the Fort Gordon Environmental and Natural Resources Management Office (ENRMO) during the past 3 years are kept electronically along with copies of the spill reports.

Additional information on discharge scenarios is contained within the Fort Gordon FRP.

An overflow of the tanks or equipment could potentially occur during tank loading and unloading operations. The majority of tanks Fort Gordon are equipped with tank gauges to prevent overflows during refueling. Leakage from containers and oil-containing mechanical equipment can also potentially occur from worn out or corroded seals, valves, fittings, or walls; therefore, visual inspections on ASTs and associated piping are conducted to assess integrity and identify visible corrosion, as discussed in Section 9.

7.1 Building 302 Area

The 15,000-gallon fuel oil AST provides fuel to an emergency power generator for the Eisenhower Regional Medical Center (Building 300) on the installation. The AST is a shop- built double-walled tank. A spill within the inner wall would be detected through an interstitial monitoring system, and would remain until removal by a local third party contractor. Product released outside the double wall (including from the transfer area north or east of the AST) would flow north, over the asphalt parking lot northwest of the hospital building, and into a storm water curb inlet. The inlet is connected to an underground drainage system that discharges into Welch’s Creek. Welch’s Creek flows east and discharges to Butler Creek and the Butler Reservoir.

7.2 Building 310 Area

The two (2) 12,000-gallon fuel oil ASTs provide fuel to an emergency power generator inside Building 310. The ASTs are shop-built double-walled tanks. A spill within the inner walls would be detected through an interstitial monitoring system, and would remain until removal by a local third party contractor. Product released outside the double wall would flow north towards a storm water inlet in the concrete pavement. The inlet is connected to a discharge point on a grassy slope west of the pavement. Product released outside the concrete containment surrounding the transfer piping south of the ASTs would flow down the same grassy slope to the northwest. Another storm water inlet is located at the bottom of the slope. This inlet is connected to an underground drainage system that discharges into Welch’s Creek. Welch’s Creek flows east and discharges to Butler Creek and the Butler Reservoir.

TABLE 7.1 – POTENTIAL EQUIPMENT FAILURES

Maps-Appendix I) Potential Volume (gallons) Spill Rate (gallons/minute)

7.3 Building 29510 Area

The four (4) 15,000-gallon fuel oil ASTs provide fuel to emergency power generators located west of Building 29510. The ASTs are shop-built single-walled tanks attached to integral steel containment system protected by rain shields. A spill from the inner walls would be detected through periodic visual inspections, and would remain until removal by a local third party contractor.