TE 3.1 - Ft Buchanana SPCCP-W912C322R0002-RefuseSrvs.pdf

Fort Buchanan

Spill Prevention, Control, and Countermeasure Plan

Prepared for:

Fort Buchanan Directorate of Public Works

Environmental Division

Prepared by:

Water Resources Program U.S. Army Public Health Command

ATTN: MCHB-IP-ESW, Building E-1675 5158 Blackhawk Road

Aberdeen Proving Ground, MD 21010-5403

January 2016

January 2016 Fort Buchanan SPCC Plan i

Table of Contents Page

ENGINEER'S CERTIFICATION ........................................................................... iii

MANAGEMENT APPROVAL ............................................................................... iv

REVISION TRACKING FORM .............................................................................. v

40 CFR 112 CROSS REFERENCE TABLE ......................................................... vi

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

2.0 FACILITY DESCRIPTION ........................................................................ 2-1

2.1 General Information ........................................................................ 2-1

2.2 Containers Not Covered by this Plan .............................................. 2-2

2.3 Navigable Waters ............................................................................ 2-3

3.0 APPLICABILITY DETERMINATION ........................................................ 3-1

4.0 GENERAL PLAN REQUIREMENTS ........................................................ 4-1

4.1 Plan Review and Submittal ............................................................. 4-1

4.2 Conformance with Federal, Army, and Commonwealth of Puerto Rico

Regulations ..................................................................................... 4-2

4.3 Personnel Training .......................................................................... 4-2

4.4 Security ........................................................................................... 4-3

4.5 Recordkeeping ................................................................................ 4-3

4.6 Spill History ..................................................................................... 4-3

4.7 Spill Response ................................................................................ 4-3

4.8 Inspection and Testing .................................................................... 4-7

4.9 Mobile and Portable Container Policy ............................................. 4-9

4.10 Rainwater Inspection in Diked Areas............................................. 4-11

4.11 Undiked Areas ............................................................................... 4-11

4.12 New Construction .......................................................................... 4-11

4.13 General Product Handling ............................................................. 4-11

5.0 CONTAINER AREAS ............................................................................... 5-1

5.1 AAFES Gas Station (Building 677) .................................................. 5-2

5.2 Auto Hobby Shop (Building 159) ..................................................... 5-7

5.3 Aqua Park (Building 161) .............................................................. 5-11

5.4 Golf Course (Building 172) ............................................................ 5-14

5.5 U.S. Army Reserve OMS (Building 528) ....................................... 5-19

5.6 DPW Complex (Buildings 34, 37, and 38) ..................................... 5-23

5.7 Logistic Readiness Fuel Station (Building 613) ............................. 5-28

5.8 School Bus Storage Area (Building 566) ....................................... 5-32

5.9 Transformers ................................................................................. 5-35

5.10 Emergency Generators ................................................................. 5-38 ii

5.11 Food Grease Drums ...................................................................... 5-45

5.12 Hydraulics ...................................................................................... 5-47

5.13 Armed Forces Reserve Center (AFRC) Motor Pool (Building 615) 5-49

5.14 Quartermaster OMS (Building 609) ............................................... 5-52

5.15 National Guard Readiness Center (Buildings 545 through 549) ... 5-55

5.16 New Elementary School (Building 700) ......................................... 5-60

6.0 CORRECTIVE ACTIONS ......................................................................... 6-1

Appendix A SPCC Regulated Containers Appendix B Certification of the Applicability of the Substantial Harm Criteria Appendix C Discharge Report to US EPA Regional Administrator Appendix D Mutual Aid Agreement - Commonwealth of Puerto Rico Fire Department Appendix E Volume Calculations for Secondary Containment Dikes Appendix F Fuel Management Practices Memorandum Appendix G Inspection Checklists Appendix H Immediate Actions Appendix I Reportable Quantities Appendix J Oil Spill Response Organizations

LIST OF FIGURES

Figure 2.1 Fort Buchanan Containers and Drainage Map ........................................... 2-5 Figure 2.2 Fort Buchanan Overview Map .................................................................... 2-6 Figure 3.1 Substantial Harm Criteria Flowchart........................................................... 3-2 Figure 5.1.1 AAFES Gas Station (Building 677) .......................................................... 5-3 Figure 5.2.1 Auto Hobby Shop (Building 159) .............................................................. 5-8 Figure 5.3.1 Aqua Park (Building 161) ....................................................................... 5-12 Figure 5.4.1 Golf Course (Building 172) ..................................................................... 5-15 Figure 5.5.1 U.S. Army Reserve OMS (Building 528) ................................................ 5-20 Figure 5.6.1 DPW Complex (Buildings 34, 37, and 38).............................................. 5-24 Figure 5.7.1 Logistic Readiness Fuel Station (Building 613) ...................................... 5-29 Figure 5.8.1 School Bus Storage Area (Building 566) ................................................ 5-33 Figure 5.13.1 AFRC Motor Pool (Building 615) .......................................................... 5-50 Figure 5.14.1 Quartermaster OMS (Building 609) ...................................................... 5-53 Figure 5.15.1 National Guard Readiness Center (Buildings 545 through 549) .......... 5-56 Figure 5.16.1 New Elementary School (Building 700) ................................................ 5-61 iii

ENGINEER'S CERTIFICATION

I, Kevin R. Russell, attest by means of this certification:

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

That I have visited and examined the facility;

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

CFR 112;

That procedures for required inspections and testing have been established;

and

That this Plan is adequate for the facility.

Kevin R. Russell, PE Date

State of Maryland Professional Engineer Certificate No. 0028442 iv

MANAGEMENT APPROVAL

This Spill Prevention, Control, and Countermeasure Plan for Fort Buchanan has my full approval, and I am at a level of authority to commit the necessary resources to implement this plan.

MICHAEL T. HARVEY Date Colonel, U.S. Army Commander v

REVISION TRACKING FORM

Date

Revision

Number

Plan

Section Description

May 2010

Cross Ref.

Table, sections 2.1-2, 4.8-9, 5.0-2, 5.5-7, 5.9-12, 6.0, and Appendices A, E, and G

Response to EPA inspection findings, expanded cross reference table, added descriptions of secondary containment, visual overfill protection, container and piping inspections. Facility changes include removal of tanks and drum storage and movement of a tank.

Jul 2013 5.0, Appendix A

Added new emergency generators, new containers for used food grease, and storage tanks returned to active status

Dec 2013 5.0, 6.0, Appendix A Added new emergency generators and new transformer

Feb 2015 5.0, 6.0, Appendix A

Added new DPW Complex, new OMS, new transformers, new generators, and National Guard Readiness Center.

Jan 2016 5.0, 6.0, Appendices A, E, I, J

Added new Logistics Readiness Fuel Station, new elementary school, fire pump at bowling alley, sodium hypochlorite tank, new generators, and new transformers.

Added new appendices for chemical spills and cleanup contractors. Removed Former AAFES Station, substations 1 and 2, and transformers.

Note: Non-technical revisions, such as changes in contact information, do not require PE Certification.

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 Buchanan and will not amend the Plan as a result.”

Signed:

Anibal Negron, DPW Environmental Division Chief

Date:

vi

40 CFR 112 CROSS REFERENCE TABLE

Final SPCC Rule Rule Requirement

Equivalent

Section

§ 112.3(d) PE certification Engineer’s

Certification

§ 112.3(e)(1,2) Facility maintains copy of plan 1.0

§ 112.3(f) Extension of time 6.0

§ 112.4 Submittal requirements to the EPA Region II administrator

4.1

§ 112.5(a) Updating requirements 4.1

§ 112.5(b) Plan reviewed at least once every five years 4.1

§ 112.7 Cross-reference table to the parts of the regulation Cross

Reference Table

§ 112.7 Facility management approval Management

Approval

§ 112.7(a)(1,2) Conformance with the regulations, details on equivalent environmental protection

4.2, 4.8, 4.9, 5.9

§ 112.7(a)(3)(i) Plot plan showing the location and contents of each container, exempted USTs, piping, and transfer station

Figure 2.1, Figures in Section 5

112.7(a)(3)(ii)

Discharge prevention and product handling 4.13, 5.x.2*

112.7(a)(3)(iii)

Discharge controls and secondary containment 4.7, 5.x.3*

112.7(a)(3)(iv-vi)

Discharge countermeasures, disposal, and notification

4.7

§ 112.7(b) Prediction of potential discharge (direction, rate of flow, amount)

Figure 2.1, Figure 2.2, 5.x.5*

§ 112.7(c) Secondary containment 4.11, 5.x.3*

§ 112.7(d) Contingency planning 4.7, 5.9

§ 112.7(e) Inspections, tests, and records 4.5, 4.8, 4.9, 5.x.4*

*Note that “5.x” indicates a subsection in each Container Area described under Section 5 of the Plan.

vii

40 CFR 112 CROSS REFERENCE TABLE (Continued)

Final SPCC Rule Rule Requirement

Equivalent

Section

§ 112.7(f)(1) Personnel training program requirements 4.3

§ 112.7(f)(2) Accountability for discharge prevention 1.0

§ 112.7(g) Security 4.4

§ 112.7(h) Loading/unloading 5.x.2*

§ 112.7(i) Brittle fracture evaluation requirements N/A

§ 112.7(j) Conformance with State requirements N/A

§ 112.7(k) Qualified oil-filled operational equipment 5.9, 5.12

§ 112.8(b) Facility drainage 2.3, Figure 2.1, Figure 2.2, 4.11

§ 112.8(c)(1) Compatible bulk storage containers 2.1

§ 112.8(c)(2) Bulk storage containers secondary containment 2.1, 5.x.3*

§ 112.8(c)(3) Requirements for drainage of diked areas 4.10

§ 112.8(c)(4) Cathodic protection for buried tanks N/A

§ 112.8(c)(5) Cathodic protection for partially buried tanks N/A

§ 112.8(c)(6) Inspections and integrity testing for aboveground containers

4.8, 4.9, 5.x.4*

§ 112.8(c)(7) Monitor internal heating coils N/A

§ 112.8(c)(8) High level alarm requirements 5.x.2*

§ 112.8(c)(9) Observe effluent treatment facilities N/A

§ 112.8(c)(10) Correct visible discharges 4.7

§ 112.8(c)(11) Locate mobile containers in secondary containment 4.9

§ 112.8(d) Facility transfer operations, pumping, and facility process

4.13, 4.8

§ 112.20(e) Certification of Substantial Harm Criteria 3.0, Appendix

C

*Note that “5.x” indicates a subsection in each Container Area described under Section 5 of the Plan.

1-1

1.0 INTRODUCTION

The Oil Pollution Prevention regulations, administered under the authority of the

United States Environmental Protection Agency (US EPA), require certain facilities to prepare and implement a Spill Prevention, Control, and Countermeasure (SPCC) Plan to reduce or eliminate oil discharges to navigable waters of the United States. SPCC

Plans document regulated containers at a facility and the inspection, testing, and maintenance procedures for those containers. The SPCC Plan also contains information regarding emergency response actions.

This document is the SPCC Plan (or Plan) for Fort Buchanan, located near San

Juan, Puerto Rico. This Plan has been prepared in accordance with 40 CFR 112 as amended. This Plan includes references to industry standards that apply to containers at Fort Buchanan, and has been certified by a Professional Engineer registered in the

State of Maryland.

Section 2.0 describes the installation and the surrounding area. The applicability of the SPCC regulations is described in Section 3.0. Section 4.0 contains general information required to be in any approved SPCC Plan. Facility contacts and spill response procedures are located in Section 4.7. Section 5.0 describes individual container storage areas. Section 6.0 contains the schedule for implementing any required facility changes.

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

Office. The container areas in Section 5 also have copies of their respective sections.

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2.0 FACILITY DESCRIPTION

2.1 General Information

Fort Buchanan was established in 1923 as Camp Buchanan on a 300-acre plot.

Camp Buchanan was used as a maneuver training area and range by the Army and

National Guard until it was expanded (to 4,500 acres) and designated Fort Buchanan in

May of 1940. After World War II, Fort Buchanan was gradually reduced in size to its present 746 acres. From 1966 to 1971, Fort Buchanan was under the command of the

U.S. Navy. In 1972, the Army resumed command and placed the U.S. Army Garrison, Fort Buchanan under the control of U.S. Army Forces Command. On October 1st, 2005

Fort Buchanan began a one year transition into the U.S. Army Reserve in accordance with the Puerto Rico Island-Wide Garrison Concept Plan of 12 May 2004.

Fort Buchanan’s primary mission is to Our mission is to provide standardized services and sustainable infrastructure in support of the Armed Forces and the diverse Fort

Buchanan community.provide base support services to all U.S Army Reserve units in Puerto

Rico and the U.S Virgin Islands. Fort Buchanan also is a Power Support Platform and plans, prepares, develops and executes contingency plans; supports U.S Forces operating in the Caribbean and Central and South America; executes oversight for the

Army’s Anti-Terrorism / Force Protection program; and serves as a Base Support

Installation for the conduct of Military Support to Civil Authorities. Fort Buchanan also supports tenant activities such as the Puerto Rico National Guard, Army Air Force

Exchange Service (AAFES), Department of Defense Domestic Dependents Elementary and Secondary Schools, and the Defense Commissary Agency, and provides housing for Department of Defense (DoD) personnel.

Fort Buchanan is located in Guaynabo County, near San Juan, Puerto Rico, at

18° 24’ 50” North latitude; 66° 7’ 50” West longitude.

The following SPCC-regulated oils are used on Fort Buchanan:

Gasoline

Diesel

Engine Oil

Hydraulic Oil

Grease

Mineral Oil

Vegetable Oil and Grease

Used Oils and Sludges

2-2

These products are stored in a variety of containers including underground storage tanks (USTs), aboveground storage tanks (ASTs), electrical operating equipment, emergency generator day tanks, 55-gallon drums, and smaller containers.

All containers that hold 55-gallons or more of SPCC-regulated oils are considered

SPCC-regulated containers with the exception of regulated USTs, see section 2.2 below. Appendix A lists specific information for the SPCC regulated containers at Fort

Buchanan. All of the regulated containers are designed to be compatible with the materials stored and operate at ambient temperatures and pressures. Secondary containment structures are sufficiently impervious to the oils they are intended to contain. No containers use internal heating coils. Fort Buchanan does not have a tank car or tank truck loading/unloading rack, pipeline, or any field-constructed tanks. Fort

Buchanan is not a RCRA large quantity generator and, therefore, does not require a

RCRA contingency plan. Also, there are no polychlorinated biphenyl (PCB) oil storage containers or PCB-containing devices (transformers, ballasts, etc.) onsite.

2.2 Containers Not Covered By this Plan

Containers owned and operated by contractors temporarily working on Fort

Buchanan property are not covered by this Plan. Such containers may include fuel tanker trucks or ASTs temporarily brought onto Fort Buchanan. Each contractor is responsible for determining SPCC applicability and developing a site-specific Plan if necessary. Although not included in the SPCC Plan, related spill response activities may still involve Fort Buchanan personnel.

USTs subject to all the technical requirements of 40 CFR 280 are exempt from all SPCC requirements. However, they must be shown on the Containers and Drainage

Map (Figure 2.1). Fort Buchanan has 6 USTs subject to the requirements of 40 CFR

280 (see Table 2.1).

Table 2.1 SPCC-Exempt USTs Subject to 40 CFR 280

Container ID Type

Capacity

(Gallons)

Material of

Construction

Contents

546D UST 200 Steel Inner / FRP Outer Used Oil

546E UST 200 Steel Inner / FRP Outer Used Oil

546F UST 200 Steel Inner / FRP Outer Used Oil

677A UST 20,000 FRP Gasoline

677B UST 20,000 FRP Gasoline

677E UST 260 Concrete Used Oil

2-3

There are eleven oil/water (O/W) separators on Fort Buchanan. Four O/W separators are slow flow, gravity separation chambers used for primary treatment of industrial wastewater to remove free oil, grease and fuel. Treated effluent discharges to the sanitary sewer system. Another treats storm water discharges from the Puerto

Rico National Guard Joint Forces Headquarters. The collected oil is periodically removed by a contractor. DPW personnel conduct periodic inspections and maintenance on the O/W separators to ensure proper operation. These five O/W separators are exclusively used for wastewater treatment and are excluded from regulation by 40 CFR 112. There are two O/W separators at the AAFES gas station.

One separates oil from the maintenance bay floor drains. Skimmed oil is stored in a separate UST (677E in Table 2.1). The other O/W separator at the AAFES gas station is a flow-through water treatment device, but it also serves as additional secondary containment for the pump area (see Section 5.1 for information). The eighth O/W separator is at the golf course and is described in Section 5.4. The remaining three

O/W separators are at the National Guard Readiness Center. Each stores separated oil in a designated UST (546E, 546F, and 546G in Table 2.1).

Amendments to 40 CFR 112 (from 26 December 2006) exempt all “motive power” containers (such as vehicle gas tanks) from SPCC Plan requirements. DoD recommends that the containment methods listed under 40 CFR 112.7(c) be employed as much as practicable for vehicle gas tanks and other such tanks over the 55-gallon threshold. Spills from these types of sources can be addressed under the description of undiked areas. Fort Buchanan operates equipment affected by this guidance including tactical vehicles, construction vehicles, and tractor-trailer trucks. (See Section

4.11 for more details regarding Undiked Areas).

2.3 Navigable Waters

Most of Fort Buchanan’s drainage discharges to El Toro Creek (known as

Quebrada Santa Catalina outside of Fort Buchanan), which flows to the northwest into the Malaria Control Canal and eventually discharges to San Juan Bay on the Atlantic

Ocean. El Toro Creek is a concrete lined ditch for much of its path through Fort

Buchanan. The town of Tintillo in Guaynabo County, where Quebrada Santa Catalina originates, discharges municipal storm water to El Toro Creek upstream of the southern forested area of Fort Buchanan. The northeastern portion of Fort Buchanan (the 600-area) drains via ditches directly to the Malaria Control Canal. An industrial park located off-post, just south of the 600-area also discharges via the same drainage ditches, upstream of the Fort Buchanan discharges. CEMEX, a cement company, owns a small man-made lake located on Fort Buchanan. CEMEX does not use the lake, although it is commonly known as CEMEX Lake. A small area occupied by Building 379 and the

2-4 back of the Middle School drains to CEMEX Lake, which has a flood-control overflow, via the Fort Buchanan storm water piping system, to El Toro Creek. CEMEX Lake is not owned or maintained by Fort Buchanan. The farthest eastern portion of Fort

Buchanan, including about half of the Golf Course, drains via Rio Puerto Nuevo into

San Juan Bay on the Atlantic Ocean. See Fort Buchanan Overview Map, Figure 2.2 for details.

2-5

Figure 2.1 Fort Buchanan Containers and Drainage Map

2-6

Figure 2.2 Fort Buchanan Overview Map

3-1

3.0 APPLICABILITY DETERMINATION

According to 40 CFR 112.1, Fort Buchanan requires an SPCC Plan. The facility-wide aboveground oil storage capacity totals more than 1,320 gallons, and oil discharges could reach navigable waters.

AR 200-1, chapter 11, paragraph 11-4b(2) states, “Ensure that the SPCC Plan addresses secondary containment (or lack thereof) at oil and hazardous material storage facilities.” This Plan includes hazardous materials storage sites.

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. Figure 3.1 shows the Flowchart of Criteria for Substantial

Harm from Attachment C-1, Appendix C, 40 CFR 112. This flowchart asks several questions regarding facility processes and storage capacity. As required by 40 CFR

112.20(e), the Certification of the Applicability of the Substantial Harm Criteria is included in Appendix B of this Plan. Fort Buchanan has less than one million gallons of oil storage capacity and does not transfer oil over water to/from vessels and does not pose a threat of substantial harm to fish and wildlife, a sensitive environment, or a drinking water intake. Therefore, a Facility Response Plan is not required.

3-2

SUBMIT RESPONSE PLAN

YES 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?

Does the facility have a total oil storage capacity greater than or equal to 1 million gallons?

NO SUBMITTAL OF RESPONSE PLAN

EXCEPT AT RA DISCRETION

Within any aboveground storage tank 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?

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

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

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

NO

NO

NO

NO

YES

NO

NO

YES

YES

YES

YES

Figure 3.1 Substantial Harm Criteria Flowchart

4-1

4.0 GENERAL PLAN REQUIREMENTS

4.1 Plan Review and Submittal

This Plan must be reviewed and evaluated at least once every five years. This

Plan must be amended within six months of the review if more effective, field-proven prevention and control technologies that would significantly reduce the likelihood of a discharge are available at the time of the review. If there are any technical amendments to the Plan, then a Professional Engineer must recertify it. Technical amendments include physical modifications, or changes in facility procedures. If all changes are non-technical (e.g., contact name, phone number, container identification number, etc.), DPW Environmental personnel can review the Plan and sign the revision tracking form on page v.

This Plan must also be updated whenever there is a change in the facility design, construction, operation, or maintenance that materially affects its discharge potential.

These types of changes include, but are not limited to, commissioning or decommissioning 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; or revision of standard operation or maintenance procedures. 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.

Required Plan amendments must be prepared within six months of the change in operation, and implemented as soon as possible, but not later than six months following preparation of the amendment. The revisions page at the beginning of this Plan must be updated to include all technical and non-technical changes to the Plan.

A report must be submitted to the US EPA Regional Administrator only if Fort

Buchanan has:

Discharged more than 1,000 gallons of oil in a single discharge or

Discharged more than 42 gallons of oil in each of two discharges, occurring within any twelve-month period.

40 CFR 112.4(a) lists the information that must be submitted to the US EPA

Regional Administrator no more than 60 days from the date of the discharge that required the submittal. This required information is also presented in Appendix C. The

Regional Administrator may also require that the SPCC Plan be submitted for review.

4-2

4.2 Conformance with Federal, Army, and Commonwealth of Puerto Rico

Regulations

The main purpose of this Plan is to comply with the requirements of 40 CFR 112.

However, Army Regulation (AR) 200-1, chapter 11, paragraph 11-4b(2) states, “Ensure that the SPCC Plan addresses secondary containment (or lack thereof) at oil and hazardous material storage facilities.” So this Plan also includes hazardous material storage sites. The Puerto Rico Emergency Response Commission indicates that there are no local or Commonwealth of Puerto Rico requirements more stringent than the

Federal requirements in regards to SPCC Plans.

4.3 Personnel Training

As required by 40 CFR 112.7(f)(1 and 3), oil handling personnel are trained to prevent discharges. Fort Buchanan conducts SPCC Plan training on an annual basis for all oil-handling personnel. This training includes a review of this SPCC Plan, applicable pollution control laws, spill response procedures, inspection and recordkeeping requirements, and the spill history for Fort Buchanan. Personnel also receive specific training in petroleum product handling procedures and equipment maintenance and operation. Fort Buchanan Directorate of Logistics (DOL) personnel responsible for fuel transfers receive additional training commensurate with their specific job requirements. The additional training may include:

Occupational Safety and Health Administration (OSHA) Hazardous Waste

Operations and Emergency Response (29 CFR 1910.120), OSHA Hazard Communication Standard (29 CFR 1910.1200), OSHA Process Safety Standard (29 CFR 1910.119), Resource Conservation and Recovery Act (RCRA) Personnel Training (40 CFR

265.16), RCRA Waste Handling / Emergency Procedures (40 CFR 262.34(d)), and

Department of Transportation Hazardous Materials Training (49 CFR 172, Subpart H).

Records of training for the Hazardous Materials Handlers Course are maintained by the Directorate of Planning, Training, Mobilization, & Security. Records of additional training are maintained by individual units or activities.

4-3

4.4 Security

Fort Buchanan is a fenced military installation. Access requires positive identification and all vehicles are subject to random searches. This level of security helps ensure that oil storage areas are only accessed by authorized personnel. In addition, military police conduct roving patrols throughout the installation. All pump starter controls are locked off when not in use and are only accessible to authorized personnel. Outdoor fuel dispensers are disabled after operating hours. All container areas have adequate facility lighting.

4.5 Recordkeeping

DPW Environmental maintains regular inspection and test records in accordance with 40 CFR 112.7(e); these records are maintained for a minimum of three years.

DPW Environmental also maintains inspection and testing records for certified inspections for the life of the container. General inspection and testing procedures for containers are described in more detail in Sections 4.8 and 4.9. Exceptions to the general procedures are identified in individual container area descriptions in Section 5 of this Plan.

4.6 Spill History

The Fort Buchanan spill history is maintained by DPW Environmental with dates, quantities, and corrective actions for all spills during the last five years. Records of all spills over 5 gallons, whether they are a reportable quantity or not, are maintained in the spill log.

4.7 Spill Response

If a spill occurs, installation personnel follow the response, reporting, and cleanup procedures appropriate to the level of spill. Personnel, if properly trained and equipped to do so safely, will promptly correct and cleanup (using available absorbents or spill kits) any visible POL discharges less than 5 gallons which are still on an impervious surface. All POL spills of any size that contact the ground or surface water, POL spills greater than 5 gallons, or any size spills of a hazardous material (even on impervious surfaces) are called in to the Fort Buchanan Fire Department immediately.

Table 4.1 indicates the response for various spills. The Fort Buchanan Fire Department is the primary spill responder and can be reached on any installation phone at 4911 or

5911.

Spill reporting may include notifications to the National Response Center (NRC), the Puerto Rico Environmental Quality Board (EQB), the Puerto Rico Emergency

4-4

Response Commission, and Installation Management Command - Southeast (IMCOM-

SE). The US 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 NRC (40 CFR 110.6). DPW Environmental is responsible for all reporting to external agencies. For Fort Buchanan, this means that the NRC must be called if an oil spill reaches El Toro Creek, the Malaria Control Canal, Rio Puerto

Nuevo, or their tributaries as shown on Figures 2.1 and 2.2.

Hazardous materials used at Fort Buchanan are listed in Appendix I. Their reportable quantities (RQs) and largest container sizes are also listed. Only sodium hypochlorite solution (used for drinking water disinfection at the golf course wellhouse) is stored in a large enough container to potentially require reporting. It should be noted that there are also some hazardous materials that may not have RQs established, and spills below the RQ for some hazardous materials could still cause environmental harm if spilled.

Table 4.1a Spill Response and Reporting Procedures

Spill Volume Response Reporting

Hazardous Material

Less than RQ or still on impervious surface within containment

Fire Department DPW Environmental

Hazardous Material

Greater than RQ that leaves containment

Fire Department

NRC, Puerto Rico EQB, Puerto Rico Emergency Response Commission, IMCOM-SE, DPW Environmental

Less than 5 gallons of POL contained on impervious surface Onsite Personnel None

Greater than 5 gallons of POL contained on impervious surface

Onsite Personnel and/or Fire Department

DPW Environmental

Any amount of POL that reaches ground surface

Fire Department DPW Environmental

Any amount of POL that reaches a navigable water

Fire Department NRC, Puerto Rico EQB, DPW Environmental

Greater than 25 gallons of POL in a single event

Fire Department NRC, Puerto Rico EQB, DPW Environmental

4-5

Table 4.2 Spill Reporting Agencies

Agency Phone

National Response Center 800-424-8802

Puerto Rico EQB

(787) 767-8181 or

(787) 724-0124

Puerto Rico Emergency Response Commission

(787) 767-8056 or

(787) 751-6274

Commonwealth of Puerto Rico Fire Department (787) 722-1120

IMCOM-SE (404) 464-0709

Fort Buchanan Fire Department 4911 or 5911

Fort Buchanan DPW Environmental (787) 707-3575r

The information in Table 4.3 should be reported after a spill. Spill response equipment is maintained throughout the installation, including the DPW complex

(Building 37), AAFES gas station (Building 677), the Fire Department (Building 1321), the U.S. Army Reserve Organizational Maintenance Shop (OMS) (Building 528), the

Golf Course (Building 138), the Auto Hobby Shop (Building 159), tanker truck 613, AFRC Motor Pool (Building 615), and the Logistics Readiness Fuel Station (Building

613).

4-6

Table 4.3 Spill Reporting Information

Individual Reporting Spill

Name and Address

Fort Buchanan

DPW Environmental Division

(IMSE-BUC-PWE)

U.S. Army Garrison

Fort Buchanan, PR 00934

Phone

Date and time of spill

Type of material discharged

Location of the spill

Quantity discharged (estimate) and time/duration of the event

Name of any surface water involved or threatened

The source of the discharge

Description of all affected media (soil, water, vegetation)

Cause of the discharge

Possible hazards to the environment

Any damages or injuries caused by the discharge

Any known or anticipated health risks associated with the incident

Actions being used to stop, remove, and mitigate the effects of the discharge

Whether an evacuation may be needed

Individuals or organizations contacted

Name Organization Time of Call

4-7

The Fire Department response truck contains sufficient materials to respond to, safely contain, and completely clean-up a spill of 300 gallons. There are enough fully encapsulating protective suits for an entire shift (5 firefighters) to don simultaneously.

Two overpack drums and side cabinets and boxes contain oil absorbent booms, sheets, pads, and socks. Decontamination equipment includes a free standing safety shower, a manual ring shower, and an inflatable decontamination tent with associated brushes, hoses, pumps, and connections. The hazmat trailer, which is not attached to the response truck, has approximately double the amount of response equipment.

Together they are adequate for spills of 1,000 gallons. For larger spills, the DPW

Operations and Maintenance (O&M) Division has approximately one pallet of oil absorbent compound as well as tools (shovels, rakes, picks, etc.) and earthmoving equipment (bulldozers, backhoes, excavators, etc.). Oil spill response organizations

(OSROs) can also be contracted if there is a large amount of cleanup required. The decision to call in OSROs would be made by the incident commander (the senior fire department officer on-scene). Funding mechanisms (approval, contracting, accounting, etc) need to be set up to allow for potential emergency use (see Appendix J for OSRO contacts). Recovered oils are managed as used oil if they can be separated in liquid form. Recovered oils that are mixed with soil are managed as non-hazardous regulated waste and as hazardous waste if contaminated with other chemicals (complex mixtures, unknowns, highly flammables, etc). The Commonwealth of Puerto Rico Fire

Department (CPRFD) can be called to assist with complex or burning spills (See

Appendix D for details regarding the mutual aid agreement with the CPRFD).

4.8 Inspection and Testing

Inspection and testing of tanks is required by 40 CFR 112.8(c)(6). The inspection and testing procedures for regulated containers in this Plan are based on applicable industry standards. Mobile and portable tank (including 55-gallon drum) inspection and testing requirements are described in section 4.9. The Steel Tank

Institute (STI) Standard SP001-05 (September 2011 revision) applies to stationary shop-built tanks. This standard requires combinations of periodic inspections by owners, certified inspections for the interior and exterior of ASTs, and certified integrity

(leak) tests at varying intervals depending on the volume and structure of the AST and secondary containment. Integrity tests are not required for shop-built ASTs with double-walls and volumes of less than or equal to 5,000 gallons. Instead, the STI

Standard calls for inspection of the interstitial space and verification of the leak detection system.

Monthly AST inspections include the full length of piping associated with the

AST. This is a much greater frequency of piping inspection than required by American

4-8

Petroleum Institute Piping Inspection Code 570 (every 5 years or as determined by risk based analysis). In addition, if underground piping becomes exposed during excavation, construction, or demolition, a visual inspection for corrosion is required. If corrosion is found, then immediate corrective measures are undertaken (such as protective wrapping and coating or pipe replacement) and further excavation is completed to more fully examine the piping. 40 CFR 112.8(c)(8)(v) also requires verification of liquid level sensors on all bulk storage containers, which are tested monthly. Table 4.4 shows the documented inspections required of all bulk storage tanks and piping. Inspection checklists are in Appendix G. Section 4.5 describes recordkeeping procedures.

Table 4.4 AST and Piping Inspection and Testing

Inspection/Test Standard Method Frequency

Presence of water in primary tank

STI SP001-05,

Appendix C

Sampling Monthly

Presence of water, oil, or debris in secondary containment

STI SP001-05,

Appendix C

Manual Monthly

Operation of leak detection system

STI SP001-05,

Appendix C

Manual Monthly

Piping connections and openings properly sealed

STI SP001-05,

Appendix C

Visual Monthly

Drain valves operable and in closed position

STI SP001-05,

Appendix C

Visual Monthly

Operation of liquid level sensor

STI SP001-05,

Appendix C Manual Monthly

Visible signs of leakage, corrosion, or damage

STI SP001-05,

App C and

API 570, App D Visual Monthly

Exterior and coating deterioration/corrosion/distortion

STI SP001-05,

Appendix C

Visual Yearly

Operation and cleanliness of operating and emergency vents

STI SP001-05,

Appendix C

Visual Yearly

Emergency vent gasket

STI SP001-05,

Appendix C Visual Yearly

Proper drainage around tank

STI SP001-05,

Appendix C Visual Yearly

4-9

Inspection/Test Standard Method Frequency

Tank supports, pad, and foundation damage

STI SP001-05,

Appendix C

Visual Yearly

Tank grounding and electrical wiring

STI SP001-05,

Appendix C

Visual Yearly

Operation of overfill protection devices

STI SP001-05,

Appendix C

Visual Yearly

Certified STI Inspection

(Not required of double-walled tanks - 5,000 gallons or less)

STI SP001-05,

Appendix C

Enhanced visual and records review 20 Years

4.9 Mobile and Portable Container Policy

Fort Buchanan is implementing this policy to manage oils and fuels stored in drums, portable containers, and mobile containers with an oil storage capacity between

55-gallons and 2,000 gallons. Portable containers are typically mounted on skids or saddles and may remain in place for an extended period of time; 55-gallon drums are also considered portable containers. Mobile containers are mounted to frames with wheels. Examples of mobile containers include fuel pods, mobile generator fuel tanks, and tanker trucks. Personnel frequently move these containers or alter the number of containers in a particular area. For this reason, the exact location of each drum, portable container, or mobile container is not included in this Plan. However, the areas that are commonly used for storage of drums or other mobile and portable containers

(and the maximum allowable volume of POL products stored in those areas) are identified in this Plan.

All containers covered by this Mobile and Portable Container Policy must have the means available to prevent discharges to navigable waters. This may include spill kits or spill pallets, diked storage areas, and/or storing containers inside a building.

Secondary containment is required when containers covered under this policy are stationary and not in use for at least four consecutive hours.

Inspection and testing of all bulk storage tanks is required by 40 CFR

112.8(c)(6). The inspection and testing procedures for regulated containers in this Plan are based on consideration of applicable industry standards. Mobile and portable tank

(including 55-gallon drum) inspection and testing requirements are contained in STI

Standard SP001-05 (September 2011 revision). This standard requires periodic inspections by owners and recertification to Department of Transportation (DOT)

4-10 standards at varying intervals, depending on the material of construction and secondary containment used. Inspection checklists are in Appendix G.

Table 4.5 Mobile and Portable Container Inspections and Testing

Inspection/Test Standard Method Frequency

Presence of water in primary tank

STI SP001-05,

Appendix C

Sampling Monthly

Presence of water, oil, or debris in interstice or secondary containment

STI SP001-05,

Appendix C

Manual Monthly

Operation of leak detection system

(Double-walled tanks only)

STI SP001-05,

Appendix C

Manual Monthly

Visible signs of leakage or corrosion/distortion

STI SP001-05,

Appendix C

Visual Monthly

Piping connections and openings properly sealed

STI SP001-05,

Appendix C

Visual Monthly

Drain valves operable and in closed position

STI SP001-05,

Appendix C

Visual Monthly

Operation of liquid level sensor

STI SP001-05,

Appendix C

Manual Monthly

DOT recertification and leak testing

(required only if no secondary containment is used)

49 CFR 173.28

49 CFR 178.803

49 CFR 180.605

Hydrostatic Test, Mass

Measurement, Level

Measurement, Pressure

Decay, etc.

Plastic - Every 7 Years

Steel – Every 12

Years

Stainless Steel –

Every 17 Years

Records of external inspections are maintained for at least three years. Records of integrity tests shall be maintained for the life of the container. Fort Buchanan does not intend to keep any drums beyond the DOT recertification test period. Personnel will track the container's age if a mobile/portable tank or drum is to be used for more than the DOT recertification test period (see Table 4.5).

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4.10 Rainwater Inspection in Diked Areas

Some containers are surrounded by secondary containment dikes. Installation personnel drain rainwater from these diked areas through locked, manually activated valves. Prior to release, personnel verify that an oil sheen is not present on the surface of the collected rainwater. If a sheen is present, personnel take appropriate action for reporting and cleanup. Site personnel also maintain a drain log recording the date and volume of rainwater that is released from the diked areas.

4.11 Undiked Areas

The SPCC regulations in 40 CFR 112.8(b) require facilities to prevent potential discharges from undiked areas by designing drainage systems that flow into catchment basins or lagoons. This does not apply to Fort Buchanan. The limited potential for spills outside of typical fuel handling areas does not warrant a complete redesign of the existing drainage system. Fort Buchanan’s spill response capabilities as described in

Section 4.7, proper personnel training as described in Section 4.3, and periodic inspections as described in Sections 4.8 and 4.9 should be adequate to prevent and contain discharges associated with typical failure mode (most likely to be a small drip or leaks from small bore suction piping that only contains oil when an emergency generator is activated) from undiked areas. A spill kit with absorbents would be able to contain and clean up this quantity of oil. This qualifies as equivalent environmental protection (as allowed under 40 CFR 112.7(a)(2)).

Fuel tanks (greater than 55 gallons) on some larger equipment are exempt from

SPCC plan requirements because they are considered “motive power containers”.

Spills from these containers may occur in undiked areas. Spill response will follow the procedures outlined in Section 4.7.

4.12 New Construction

Any new construction will comply with the applicable requirements of 40 CFR

112.8(d). New buried metallic piping will either have a protective coating or cathodic protection. In the event that piping is exposed during an excavation, the pipe will be inspected for corrosion and repaired or replaced as necessary.

4.13 General Product Handling

Installation personnel follow standard operating procedures for product handling as listed in applicable military standards. These procedures are outlined in the Fort

Buchanan DPW Policy Memorandum DPW 2, Subject: POL Products/Diesel Fuel

Management Practices, attached as Appendix F. This document establishes policy and

4-12 administrative procedures for fuel operations, specifies duties for fuel management personnel, provides guidelines and procedures for operating storage tanks, and outlines responsibilities for operation and maintenance of storage and dispensing equipment.

Installation personnel follow the procedures specified in this document for all product handling activities.

In general, personnel follow the spill prevention procedures below when transferring product to or from a tanker truck:

Load or unload in approved locations only

Establish communications between the pumping and receiving stations

Verify the available volume of the receiving container

Properly close all drainage valves for any secondary containment

Allow sufficient volume (approximately 10% of the total capacity) in the receiving container for thermal expansion

Visually inspect all valves for leakage when transfer is complete

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5.0 CONTAINER AREAS

This section of the Plan provides details about SPCC-regulated containers in each area. An area typically encompasses all the containers owned and maintained by a single shop or functional unit. Transformers, generators, and grease drums have been grouped as “areas” because of their common contents and procedures. All

SPCC-regulated containers, regardless of container area, are in the consolidated table in Appendix A.

Fort Buchanan has the following container areas:

AAFES Gas Station

Auto Hobby Shop

Aqua Park

Golf Course

U.S. Army Reserve OMS

DPW Complex

Logistics Readiness Fuel Station

School Bus Storage Area

Electrical Transformers

Emergency Generators

Food Grease Drums

AFRC Motor Pool

Quartermaster OMS

National Guard Readiness Center

New Elementary School

The term “visual” is used in tables throughout Section 5 to describe a method of overfill prevention wherein the person filling a container can see the level of product in the container while it is being filled and can immediately shut off inflow upon reaching

90% of container capacity (40 CFR 112.8(8)(iii-iv).

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5.1 AAFES Gas Station (Building 677)

5.1.1 Area Description

The AAFES Gas Station is a self-service gas station with 16 pumps for unleaded regular and premium gasoline. Customers pump gas into personally owned vehicles from two USTs (677A and B). No tactical vehicles are serviced or fueled at this site.

The pumping area is a concrete slab with overhead protection. There is also a maintenance area with two maintenance bays (oil and tire changes only). One AST

(677C) is used to store used oil outside the maintenance bay. An emergency generator with an inherent diesel tank (677D) is located beside the storage area (see Section 5.10 for more information on emergency generators). Other hazardous materials and POL products are stored inside the building (pallets of quart containers of oil), flammable lockers, and the maintenance bays. There are two O/W separators, one for the floor drains in the maintenance bays and another for the pump area. The floor drain O/W separator includes a UST (677E) that stores oil separately from the O/W separator.

The pump area O/W separator is a flow through wastewater treatment device that would provide some containment in the case of a spill. Table 5.1.1 provides container details, and Figure 5.1.1 shows their locations.

Table 5.1.1 AAFES Gas Station Containers

Container

ID Type

Capacity

(Gallons)

Material of

Construction

Product

Stored

677A UST 20,000

Fiberglass Reinforced

Plastic (FRP) Gasoline

677B UST 20,000 FRP Gasoline

677C AST, Vertical 250 Steel Used Oil

677D AST, Horizontal 350 Steel Diesel

677E UST 260 Concrete Used Oil

5-3

Figure 5.1.1 AAFES Gas Station (Building 677)

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5.1.2 Product Handling

Tanker trucks of up to 10,000-gallon capacity deliver gasoline to the station.

AAFES personnel follow the truck unloading procedures described in Section 4.13.

USTs (677A and 677B) have automatic tank gauges (ATGs) with alarms and automatic pump shutoff. Each underground tank has a separate spill catchment basin and both tanks have underground piping to the dispensers. Customers use common commercial fueling station dispensers when fueling their vehicles. An emergency stop button and spill response materials are available near the pumps. Mechanics fill tank 677C by using oil pans to hand-pour the oil drained from vehicles. The used oil is removed from tank 677C by a vacuum truck and then recycled. The generator tank (677D) is filled by the DOL fuel truck. UST 677E is filled by gravity skimming of oil from the maintenance bay O/W separator. Oil and water are removed by a vacuum truck. Table 5.1.2 provides more details regarding product handling activities for this area.

Table 5.1.2 AAFES Gas Station Product Handling

Container ID Loading Method Overfill Protection Unloading Method

677A (UST) Truck ATG Dispensed to customers

677B (UST) Truck ATG Dispensed to customers

677C Manual Visual Vacuum truck

677D Truck Visual Used in generator

677E (UST)

From O/W Separator

NA Vacuum truck

5.1.3 Secondary Containment

Tanks 677A, 677B, and 677E are subject to all the technical requirements of 40

CFR 280 and are therefore exempt from any secondary containment requirements imposed by the SPCC rule.

A spill in the pumping area would flow to an O/W separator prior to discharge.

See Appendix E for volume calculations. Fueling station personnel maintain spill kits near the fueling area for additional…