Section_J_-_Fort_Belvoir_SPCC_Plan_Signed_and_Approved_-_updated_September_2017.pdf

Fort Belvoir Spill Prevention, Control, and Countermeasure Plan

Prepared for:

Fort Belvoir Directorate of Public Works

Environmental Division

Prepared by:

Water Resources Division Army Public Health Center

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

Aberdeen Proving Ground, MD 21010-5403

September 2017

September 2017 Fort Belvoir SPCC Plan i

Table of Contents Page

ENGINEER'S CERTIFICATION ........................................................................... iv

MANAGEMENT APPROVAL ................................................................................ v

REVISION TRACKING FORM ............................................................................. vi

40 CFR 112 CROSS REFERENCE TABLE ........................................................ vii

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 Virginia

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 ................................................................................ 4-4

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

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

4.10 Rainwater Inspection in Diked Areas............................................. 4-13

4.11 Undiked Areas ............................................................................... 4-13

4.12 New Construction .......................................................................... 4-13

4.13 General Product Handling ............................................................. 4-13

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

5.1 Transportation Motor Pool (Building 190) ........................................ 5-3

5.2 300-Area Fuel Point (Building 324) ................................................. 5-7

5.3 300-Area Maintenance (Building 331) ........................................... 5-11

5.4 300-Area Pier (Buildings 338 and 341) ......................................... 5-15

5.5 600-Area (Building 606) ................................................................ 5-20

5.6 Recycling Center (Building 1089) .................................................. 5-24

5.7 Directorate of Public Works (DPW) Roads and Grounds

(Building 1114) ........................................................................... 5-27

5.8 Capitalized Fuel Station (Building 1124) ....................................... 5-31

5.9 Building 1128................................................................................. 5-35 ii

5.10 Army Air Force Exchange System (AAFES)

Gas Station - South (Building 1135) .......................................... 5-38

5.11 Power Plant (Building 1234) .......................................................... 5-41

5.12 Motor Pool (Buildings 1417, 1419, and 1420) ............................... 5-46

5.13 Autocraft (Building 1462) ............................................................... 5-53

5.14 Marina (Building 1696) .................................................................. 5-57

5.15 Motor Pool (Buildings 1906 and 1956) .......................................... 5-60

5.16 Motor Pool (Buildings 1949 and 1950) .......................................... 5-65

5.17 AAFES Gas Station - South (Building 2304) ................................. 5-70

5.18 Earth Satellite (Building 2310) ....................................................... 5-73

5.19 Intelligence and Security Command (INSCOM) (Building 2444) ... 5-77

5.20 Defense Logistics Agency (DLA) (Building 2462) .......................... 5-81

5.21 Humphreys Engineer Center Support Activity (HECSA)

(Building 2580) ........................................................................... 5-85

5.22 2800-Area (Buildings 2800 and 2803) ........................................... 5-88

5.23 2800-Area (Building 2838) ............................................................ 5-92

5.24 Golf Course (Buildings 2909, 2990, and 2993) ............................. 5-95

5.25 Davison Army Airfield (DAAF) Hangar (Building 3121) ............... 5-102

5.26 DAAF Hangars (Buildings 3140 and 3144) ................................. 5-105

5.27 DAAF Hangars (Buildings 3151 and 3153) ................................. 5-108

5.28 DAAF Fuel Point (Building 3161) ................................................ 5-111

5.29 DAAF Hangars (Buildings 3231 and 3232) ................................. 5-116

5.30 National Geospatial-Intelligence Agency (NGA)

(Buildings 5103 and 5104) ....................................................... 5-119

5.31 Tulley Gate (Building 9500) ......................................................... 5-125

5.32 Electrical Transformers ............................................................... 5-128

5.33 Emergency Generators ............................................................... 5-131

5.34 Heating Oil Tanks ........................................................................ 5-143

5.35 Used Food Grease Containers .................................................... 5-150

5.36 Swimming Pool Chemical Containers ......................................... 5-155

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

Appendix A SPCC Regulated Containers and Underground Storage Tanks Appendix B Certification of the Applicability of the Substantial Harm Criteria Appendix C Discharge Report to US EPA Regional Administrator Appendix D Volume Calculations for Secondary Containment Dikes Appendix E Inspection Checklists Appendix F Immediate Actions Appendix G Reportable Quantities Appendix H Oil Spill Response Organizations Appendix I Satellite Locations SPCC Plans iii

LIST OF FIGURES

Figure 2.1 Fort Belvoir Area Overview Map ................................................................. 2-4 Figure 2.2 Fort Belvoir Containers and Drainage Map (Area 1) .................................. 2-5 Figure 2.3 Fort Belvoir Containers and Drainage Map (Area 2) .................................. 2-6 Figure 2.4 Fort Belvoir Containers and Drainage Map (Area 3) .................................. 2-7 Figure 2.5 Fort Belvoir Containers and Drainage Map (Area 4) .................................. 2-8 Figure 2.6 Fort Belvoir Containers and Drainage Map (Area 5) .................................. 2-9 Figure 2.7 Fort Belvoir Containers and Drainage Map (Area 6) ................................ 2-10 Figure 3.1 Substantial Harm Criteria Flowchart........................................................... 3-2 Figure 5.1.1 Transportation Motor Pool (Building 190) ................................................ 5-4 Figure 5.2.1 300-Area Fuel Point (Building 324) .......................................................... 5-8 Figure 5.3.1 300-Area Maintenance (Building 331) .................................................... 5-12 Figure 5.4.1 300-Area Maintenance (Building 331) .................................................... 5-17 Figure 5.5.1 600-Area (Building 606) ......................................................................... 5-21 Figure 5.6.1 Recycling Center (Building 1089) ........................................................... 5-25 Figure 5.7.1 DPW Roads and Grounds (Building 1114) ............................................ 5-28 Figure 5.8.1 Capitalized Fuel Station (Building 1124) ................................................ 5-32 Figure 5.9.1 Building 1128 ......................................................................................... 5-36 Figure 5.10.1 AAFES Gas Station - South (Building 1135) ........................................ 5-39 Figure 5.11.1 Power Plant (Building 1234) ................................................................. 5-43 Figure 5.12.1 Motor Pool (Buildings 1417, 1419, and 1420) ...................................... 5-49 Figure 5.13.1 Autocraft (Building 1462)...................................................................... 5-54 Figure 5.14.1 Marina (Building 1696) ......................................................................... 5-58 Figure 5.15.1 Motor Pool (Buildings 1906 and 1956) ................................................. 5-62 Figure 5.16.1 Motor Pool (Buildings 1949 and 1950) ................................................. 5-67 Figure 5.17.1 AAFES Gas Station - South (Building 2304) ........................................ 5-71 Figure 5.18.1 Earth Satellite (Building 2310) .............................................................. 5-75 Figure 5.19.1 INSCOM (Building 2444) ...................................................................... 5-79 Figure 5.20.1 DLA (Building 2462) ............................................................................. 5-83 Figure 5.21.1 HECSA (Building 2580) ........................................................................ 5-86 Figure 5.22.1 2800-Area (Buildings 2800 and 2803) ................................................. 5-90 Figure 5.23.1 2800-Area (Building 2838) ................................................................... 5-93 Figure 5.24.1 Golf Course (Building 2909) ................................................................. 5-98 Figure 5.24.2 Golf Course (Buildings 2990 and 2993) ............................................... 5-99 Figure 5.25.1 DAAF Hangar (Building 3121) ............................................................ 5-103 Figure 5.26.1 DAAF Hangars (Buildings 3140 and 3144) ........................................ 5-106 Figure 5.27.1 DAAF Hangars (Buildings 3151 and 3153) ........................................ 5-109 Figure 5.28.1 DAAF Fuel Point (Building 3161) ....................................................... 5-113 Figure 5.29.1 DAAF Hangars (Buildings 3231 and 3232) ........................................ 5-117 Figure 5.30.1 NGA (Buildings 5103 and 5104) ........................................................ 5-122 Figure 5.31.1 Tulley Gate (Building 9500) ................................................................ 5-126 vii

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.

viii

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, Figures 2.1-2.7, 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 B

*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 Belvoir, located near Alexandria, Virginia. 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 Belvoir, 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 Belvoir is on an 8,700-acre plot along the western bank of the Potomac River. The installation is about 11 miles southwest of Alexandria, 14 miles southwest of Washington, D.C, and 95 miles north of Richmond, Virginia.

Fort Belvoir’s primary mission is to provide support services to activities and tenants located at Fort Belvoir and throughout the National Capital Region. The mission includes: regional administrative, logistics, recreation, housing, and contingency military support.

Fort Belvoir is located in Fairfax County, near Alexandria, Virginia, at 38° 41’ North latitude; 77° 08’ West longitude.

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

• Gasoline

• Diesel

• Heating Oil

• Kerosene

• JP8

• Engine Oil

• Hydraulic Oil

• Grease

• Mineral Oil

• Vegetable Oil and Grease

• Used Oils and Sludges

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 Belvoir. 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 Belvoir does not have any field-constructed

2-2 tanks. Fort Belvoir is a RCRA large quantity generator and, therefore, requires a RCRA contingency plan. Building 1495 is the RCRA less than 90-day storage facility. It has a RCRA Contingency Plan, prepared October 2014. 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 Belvoir property are not covered by this Plan. Such containers may include fuel tanker trucks or ASTs temporarily brought onto Fort Belvoir. 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 Belvoir personnel.

USTs subject to all the technical requirements of 40 CFR 280 (see Appendix A, Table A-2) are exempt from all SPCC requirements. However, they must be shown on the Containers and Drainage Maps (Figures 2.2 to 2.7) and are listed in Table A-2 in Appendix A. There is one UST (2849D) listed in the Appendix that was installed but has never been used and will never be used. However, it was pre-registered as an UST. This tank could be removed from all listings and maps if the registration was nullified.

There are oil/water (O/W) separators at various locations on Fort Belvoir. The 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. 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 O/W separators are exclusively used for wastewater treatment and are excluded from regulation by 40 CFR 112.

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 Belvoir 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).

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Fort Belvoir is also responsible for satellite locations, including Rivanna and the Mark Center, that are geographically distinct and effectively not under direct management of daily operations. These are considered separate facilities for SPCC Plan purposes. These sites have their own SPCC Plans as required by 40 CFR 112.

The NGA also has a separate SPCC Plan but this satellite location is closer and more directly linked to the Fort Belvoir Garrison and is thus included in this SPCC Plan too.

Copies of the satellite location SPCC Plans are in Appendix I.

2.3 Navigable Waters

Fort Belvoir is surrounded on its eastern, western, and southern borders by the Potomac River and its tributaries, Dogue Creek, and Accotink Creek (which widens into Accotink Bay and Gunston Cove). Drainage discharges to Dogue Creek or Accotink Creek (through Gunston Cove) and eventually discharges to the Potomac River and then the Chesapeake Bay. Various towns in Fairfax County discharge municipal storm water to Dogue Creek and Accotink Creek upstream of Fort Belvoir. See Fort Belvoir Area Overview Map, Figure 2.2 for details.

Some of Fort Belvoir’s territory is within a recognized flood zone. The Federal Emergency Management Agency maps of the 1 percent annual likelihood flood area (also known as the 100-year flood) include areas near Accotink Creek (including the entire northeast side of Davison Army Airfield, portions of Pohick Road and nearly up to Building 1495, the RCRA less than 90-day facility) on Fort Belvoir’s main cantonment area western boundary, near the Potomac River on the southern end of Fort Belvoir (300-Area pier) and the eastern bank of Dogue Creek (near the marina) in the easternmost portion of Fort Belvoir.

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Figure 2.1 Fort Belvoir Area Overview Map

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Figure 2.2 Fort Belvoir Containers and Drainage Map (Area 1)

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Figure 2.3 Fort Belvoir Containers and Drainage Map (Area 2)

2-7

Figure 2.4 Fort Belvoir Containers and Drainage Map (Area 3)

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Figure 2.5 Fort Belvoir Containers and Drainage Map (Area 4)

2-9

Figure 2.6 Fort Belvoir Containers and Drainage Map (Area 5)

2-10

Figure 2.7 Fort Belvoir Containers and Drainage Map (Area 6)

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3.0 APPLICABILITY DETERMINATION

According to 40 CFR 112.1, Fort Belvoir 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 (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 Belvoir has less than one million gallons of oil storage capacity (approximately 700,000 gallons) 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 Belvoir 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.

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4.2 Conformance with Federal, Army, and Commonwealth of Virginia 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 Commonwealth of Virginia has additional requirements [9 Virginia Administrative Code (VAC) 25-91] more stringent than the Federal requirements in regards to ASTs and spill contingency plans. ASTs in Virginia are required to be registered with the state; the DEQ must be notified of major repairs or changes to ASTs; AST operator inspectors require additional training; AST closures must include a site assessment to evaluate potential soil, surface water, or groundwater contamination;

secondary containment must be evaluated and certified by a PE; and ASTs must also have storage capacity, product stored, and tank identification number labeled on the tank. All of these requirements are applicable only to ASTs with volumes of greater than 660 gallons that are not an integral part of an emergency generator (base tank, belly tank). Section 4.7, Inspection and Testing includes additional requirements and exclusions.

4.3 Personnel Training

As required by 40 CFR 112.7(f)(1 and 3), oil handling personnel are trained to prevent discharges. Fort Belvoir 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 Belvoir. Personnel also receive specific training in petroleum product handling procedures and equipment maintenance and operation. Fort Belvoir Directorate of Logistics (DOL) personnel responsible for fuel transfers receive additional training commensurate with their specific job requirements.

Records of additional training are maintained by individual units or activities. 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), 4-3

• 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).

Further training for personnel inspecting ASTs is required by 9VAC25-91. The training must include occupational safety, hazard recognition, personnel protection, facility operations, and procedures for conducting inspections, evaluating AST condition, and responding to identified hazards.

4.4 Security

Fort Belvoir 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 Belvoir 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. The spill log must be reviewed annually to assess spill response and evaluate existing procedures.

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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, surface water, storm drains, or the sanitary sewer; POL spills greater than 5 gallons; or any size spills of a hazardous material (even on impervious surfaces) are called in to the Fort Belvoir Fire Department immediately. Table 4.1 indicates the response for various spills. The Fort Belvoir Fire Department is the primary spill responder and can be reached on any installation phone by dialing 911.

Spill reporting may include notifications to the National Response Center (NRC), the Virginia Department of Environmental Quality (DEQ), the Virginia Emergency Response Commission, and Installation Management Command (IMCOM). 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 Belvoir, this means that the NRC must be called if an oil spill reaches Accotink Creek/Bay, Dogue Creek/Bay, the Potomac River, any associated wetlands, or their tributaries as shown on Figures 2.1 and 2.2.

Hazardous materials used at Fort Belvoir are listed in Appendix G. Their reportable quantities (RQs) and largest container sizes are also listed. One herbicide monosodium methanearsonate (known as MSMA) at the Golf Course (Building 9293) and sodium hypochlorite solutions at Buildings 2444 and 5104 are stored in large enough containers to potentially require reporting. It should be noted that there are also some hazardous materials that may not have RQs established, and that spills below the RQ for some hazardous materials could still cause environmental harm.

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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, Virginia DEQ, Virginia Department of Emergency

Management, IMCOM, 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 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, Virginia DEQ, DPW

Environmental Greater than 25 gallons of

POL in a single event Fire Department NRC, Virginia DEQ, DPW Environmental

Spill to Sewer System Fire Department Fairfax County Lower Pollution Control Plant

Table 4.2 Spill Reporting Agencies

Agency Phone National Response Center (800) 424-8802 Virginia DEQ (703) 583-3800 Virginia Department of Emergency Management (800) 468-8892

Fairfax County Virginia Fire Department

Woodlawn 911 or (703) 780-0110 Gunston 911 or (703) 339-5970

Fairfax County Lower Pollution Control Plant (703) 323-1211

IMCOM (404) 464-0709

Fort Belvoir Fire Department 911 or (703) 806-1800

Fort Belvoir DPW Environmental

(703) 806-3694 or

(703) 806-0020 or

(703) 806-2119

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The information in Table 4.3 should be reported after a spill. Spill response equipment is maintained throughout the installation, including the Fort Belvoir Fire Department [Buildings 191 (South), 2119 (North), 3237 (DAAF), and 5100 (NGA)], 300- Area Pier (Buildings 338 and 341), DPW Roads and Grounds (Building 1114), Capitalized Fuel Station (Building 1124), AAFES gas stations (Buildings 1135 and 2304), DPW motor pool (Building 1420), autocraft (Building 1462), less than 90-day storage facility (Building 1495), motor pools (Buildings 1949 and 1950), golf course (Building 2990), DAAF Fuel Point (Building 3161), NGA (Building 5103).

The Fire Department response trucks contain 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 to don simultaneously. Two overpack drums and side cabinets and boxes contain oil absorbent booms, sheets, pads, and socks. The hazmat trailers, which are not attached to the response trucks, have approximately double the amount of response equipment. The trailers are adequate for spills of 1,000 gallons. The Fire Department does not clean-up spills, they contain and control spills to maintain public safety. Spills are cleaned up by installation maintenance contractor personnel. Some areas also have separate maintenance contractors that include spill clean-up. For larger spills, the DPW Roads and Grounds has approximately five pallets of oil absorbent compounds as well as containers (steel drums, plastic drums, and overpack drums), 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 H for OSRO contactors). Recovered oils are managed as used oil or used fuel 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/toxics, etc.). The DPW Environmental POL and Hazardous Waste Managers and RCRA less than 90-day facility personnel will make determinations on the management of spill related wastes. The Fairfax County Fire Department can be called to assist with complex or burning spills.

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Table 4.3 Spill Reporting Information

Individual Reporting Spill

Name and Address

Fort Belvoir DPW Environmental Division

(IMBV-PWE)

U.S. Army Garrison Fort Belvoir, VA 22060

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

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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 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 4.4a 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

4-9

Inspection/Test Standard Method Frequency

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

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

All ASTs with volumes greater than 660 gallons must also be inspected in accordance with Virginia regulation (9VAC25-91-130). There are two exclusions to this regulation that apply at Fort Belvoir: heating oil tanks, which only require the Virginia inspections at greater than 5,000 gallons; and tanks that are an integral part of a generator and the fuel is only used by the generator (e.g. belly tanks). Tanks 246D, 324R, 324T, 765A, 765B, 1114A, 1956B, 2810D, 3138J, and tanks 5104A to 5104G are required to meet these additional inspection requirements. The tanks listed above are exempt from Virginia requirements for inventory control and variability analysis, because the tanks and associated piping are completely off the ground [9VAC25-91- 130.B.1(a)(1)]. The requirements, listed in Table 4.4b below, as well as those listed in Table4.4a above, will be met for each of these tanks.

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Table 4.4b Additional Inspection/Test Schedule for Tanks 246D, 324R, 324T, 765A, 765B, 1114A, 1956B, 2810D, 3138J, and Tanks 5104A to 5104G

* - Daily inspections must include: complete walk-throughs of the areas to assure no hazardous conditions exist; ground inspections for signs of spills/leaks or stains; a check of the containment for water and closed valves; visual inspections of the tank exteriors for damage/leakage; and evaluations of the tanks’ appurtenances.

# - Weekly inspections must be conducted using checklists that include the following minimum items: inspection of secondary containment condition; containment free of oil or water; containment valves secured; containment area free of debris; tank shell surface, including welds, rivets, bolts, seams, and foundation, inspected for rust or other deterioration; ground surface checked for signs of leakage; leak detection operational; separator or drainage tank in satisfactory condition; tank bottom water draw-offs secured; tank fill valves secured; valves inspected for signs of leakage or deterioration; piping and flanges inspected for leakage; and tank gauges inspected and operational.

Containers (drums and ASTs) of chemicals not regulated by 40 CFR 112, because they do not contain oil, are regulated by AR 200-1. AR 200-1 does not have requirements for container integrity testing or inspections. However, it would be a good management practice to visually inspect chemical containers for visible leaks and signs of areas of corrosion, wear, cracking, material thinning, and tightness/alignment of piping, fittings, connections, and gaskets as well as operability of gauges, pumps, and valves.

4.9 Mobile and Portable Container Policy

Fort Belvoir 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

Inspection/Test Standard Method Frequency Visual Inspection* 9VAC25-91-

130.B.5.a Visual Daily

Visual Inspection# 9VAC25-91- 130.B.5.b Visual Weekly

Pressure Testing of Piping 9VAC25-91- 130.B.4.b

Hydrostatic or API 570 5 years

4-11 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) standards at varying intervals, depending on the material of construction and secondary containment used. Inspection checklists are in Appendix E.

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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 Belvoir 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). Records of monthly visual inspections are maintained for at least three years.

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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 Belvoir. The limited potential for spills outside of typical fuel handling areas does not warrant a complete redesign of the existing drainage system. Fort Belvoir’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 vehicles and 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…