Pam_420-28_(Spill_Prevention).pdf

Fort McCoy Pamphlet 420-28

Public Works

Spill Prevention, Control, Countermeasure and Spill

Contingency Plans

Department of the Army Headquarters Fort McCoy

Fort McCoy, WI September 2013

UNCLASSIFIED

SUMMARY of CHANGE

Pamphlet 420-28 Installation Spill Prevention, Control, Countermeasure, and Spill Contingency Plans

This Revision – Technical Revision

� This pamphlet was previously published as Fort McCoy Regulation 420-28.

� A review and evaluation of the plan was conducted. This revision is the amendment resulting from that review.

� Updated tank tables in chapter 5 and appendix A to include new tanks,used vegetable oil containers, and the removal/replacement of a 100,000 gallon gasoline tank with a 12,000 gallon tank.

� Updated portable container information in Table 5-17.

� Updated spill history in appendix D.

� Updated hazmat response equipment in appendix E.

� Updated the spill response mutual aid agreements in appendix F.

� Updated volume calculations for secondary containment in appendix G.

� Updated physical deficiencies table in appendix H.

� Updated the spill bill in annex A.

� Updated figures 2.1 and 2.2.

� Updated spill prevention training schedule in table 4-1.

� Modified language and wording for clarification.

Revision May 2010 — Non-Technical Revision

� Updated tank tables in chapter 5 and appendix A to include new tanks.

� Updated portable container (essentially 55-gallon drum) Table 5-17 and in appendix A to comply with amendments in 73 FR 74235.

� Updated Physical Deficiencies Table in appendix H.

� Added discussion in appendix H regarding cooking oil tanks at dining facilities that do not yet meet the secondary containment requirements outlined in 73 FR 74235.

� Updated spill history in appendix D.

� Reviewed and updated regulatory citation in text and 40 CFR 112 Cross Reference Table.

� Updated Figure 2.2 to include portable container storage locations.

� Modified language to clarify existing requirements.

Revision August 2008

� The Installation Spill Prevention Control, Countermeasure, and Spill Contingency Plan was revised in its entirety to comply with the revised Oil Pollution Prevention regulations promulgated by EPA in 67 FR 47140, 67 FR 47146, 71 FR 77292, and 71 FR 77293.

Fort McCoy Pamphlet 420-28, September 2013 ii

CONTENTS

Revision Tracking Log, page v 40 CFR Cross Reference Table, page vi

Chapter 1 Introduction, page 1

Introduction 1-1, page 1 Plan Organization 1-2, page 1 Plan Distribution 1-3, page 2

Chapter 2 Facility Description, page 2

General Information 2-1, page 2 Regulated Oils 2-2, page 3 Containers Not Covered By this Plan 2-3, page 4 Navigable Waters 2-4, page 5

Chapter 3 Applicability Determination, page 8

Chapter 4 General Plan Requirements, page 9

Plan Review and Submittal 4-1, page 9 Conformance with Federal and State Regulations 4-2, page 11 Personnel Training 4-3, page 11 Security 4-4, page 13 Recordkeeping 4-5, page 13 Spill History 4-6, page 13 Spill Response 4-7, page 13 Inspection and Testing 4-8, page 15 Mobile and Portable Container Policy 4-9, page 15 Precipitation Inspection in Diked Areas 4-10, page 16 Undiked Areas 4-11, page 17 New Construction 4-12, page 17 General Product Handling 4-13, page 17

Chapter 5 Container Group Specific Information, page 18

Central Fuels 5-1, page 19 Aircraft Fueling from Underground Storage Tanks (UST) and Aboveground Storage Tanks (AST)

5-2, page 23 Central Vehicle Wash Rack 5-3, page 26 Maintenance and Service Shops 5-4, page 27 Military Training Activities 5-5, page 40 Electrical Transformers 5-6, page 42 Emergency Generator Tanks and Miscellaneous Containers 5-7, page 43 Oil/Water Separators 5-8, page 51

Chapter 6 Plan Certification and Endorsement, page 55

Fort McCoy Pamphlet 420-28, September 2013 iii

Appendices A. Petroleum, Oil, and Lubricants (POL) Containers, page 57 B. Certification of the Applicability of the Substantial Harm Criteria, page 67 C. Discharge Report to the US Environmental Protection Agency (EPA) Regional Administrator, page 68 D. Spill History, page 69 E. Hazmat Response Equipment, page 74 F. Spill Response Mutual Aid Agreements, page 80 G. Volume Calculations for Secondary Containment, page 90 H. Deviations from Conformance with 40 CFR 112 and Wisconsin Department of Agriculture, Trade and

Consumer Protection SPS 310 Regulations, page 96 I. State of Wisconsin Substance Release Notification Form (4400-225), page 100 J. Drawing F411-90-01, Sheets M-1, M-2, M-3, M-4, and M-5, page 101 K. Review Certification Form, page 102 L. Glossary, page 103

Figures List Figure 2-1: Facility Site Plan, page 6 Figure 2-2: Fixed POL Storage Locations, page 7 Figure 3-1: Criteria for Substantial Harm Flowchart, page 9

Tables List Table 1-1: SPCC Plan Distribution, page 2 Table 2-1: SPCC-Exempt Underground Storage Tanks (UST) Subject to 40 CFR 280, page 5 Table 4-1: Spill Prevention Training Schedule, page 12 Table 4-2: Spill Response, Reporting, and Cleanup Procedures, page 14 Table 4-3: Spill Reporting Agencies, page 14 Table 4-4: Spill Reporting Information, page 15 Table 4-5: Mobile and Portable Container Inspections and Testing, page 16 Table 5-1: Central Fuels Containers, page 19 Table 5-2: Central Fuels Product Handling, page 20 Table 5-3: Central Fuels Secondary Containment, page 21 Table 5-4: Central Fuels Inspection and Testing, page 22 Table 5-5: Central Fuels Potential Spill Scenario, page 23 Table 5-6: Aircraft Fueling Containers, page 24 Table 5-7: Aircraft Fueling Product Handling, page 24 Table 5-8: Airport Fueling Secondary Containment, page 25 Table 5-9: Airport Fueling Inspection and Testing, page 25 Table 5-10: Aircraft Fueling Potential Spill Scenario, page 26 Table 5-11: Central Vehicle Wash Rack Containers, page 26 Table 5-12: Central Vehicle Wash Rack Product Handling, page 26 Table 5-13: Central Vehicle Wash Rack Secondary Containment, page 27 Table 5-14: Central Vehicle Wash Rack Inspection and Testing, page 27 Table 5-15: Central Vehicle Wash Rack Potential Spill Scenarios, page 27 Table 5-16: Maintenance and Service Area Tanks, page 28 Table 5-17: Maintenance and Service Areas with 55-gallon Drums that Store Petroleum Products, Table 5-18: Maintenance and Service Product Handling, page 32 Table 5-19: Maintenance and Service Areas Secondary Containment, page 34 Table 5-20: Maintenance and Service Areas Inspection and Testing, page 37 Table 5-21: Maintenance and Service Areas Potential Spill Scenario, page 40 Table 5-22: Military Training Containers, page 40 Table 5-23: Military Training Product Handling, page 41 Table 5-24: Military Training Secondary Containment, page 42 Table 5-25: Military Training Inspection and Testing, page 42 Table 5-26: Military Training Potential Spill Scenario, page 42 Table 5-27: Emergency Generator Tanks, page 43

Fort McCoy Pamphlet 420-28, September 2013 iv

Table 5-28: Miscellaneous Tanks, page 44 Table 5-29: Emergency Generator and Miscellaneous Tanks, page 46 Table 5-30: Generator and Miscellaneous Tanks Secondary Containment, page 48 Table 5-31: Emergency Generator Inspection and Testing, page 50 Table 5-32: Emergency Generator Potential Spill Scenario, page 51 Table 5-33: Oil/Water Separators (OWS), page 52 Table 5-34: OWS Secondary Containment, page 53 Table 5-35: OWS Inspection and Testing, page 54 Table 5-36: OWS Potential Spill Scenario, page 54

Annex A: Facility Response Plan, page 105

Fort McCoy Pamphlet 420-28, September 2013 v

REVISION TRACKING LOG

Date Revision Number

Plan Chapter Description

March 2004 Not specified Not Specified Not Specified

September 2004 1 All

This Spill Prevention, Control, and Countermeasures (SPCC) Plan was redeveloped in its entirety in order to comply with the revised Oil Pollution Prevention regulations promulgated by EPA in 67 FR 47042.

August 2008 2 All

This SPCC Plan was revised in its entirety to comply with the revised Oil Pollution Prevention regulations promulgated by EPA in 67 FR 47140, 67 FR 47146, 71 FR 77292 and 71 FR 77293.

May 2010 3 All

This SPCC Plan was reviewed and updated to include new tanks, clarify existing requirements, and to address the rule amendments in 73 FR 74235.

September 2013 4 All

This SPCC Plan was reviewed and updated in accordance with 40 CFR 112.5(a) and(b). The changes include new containers, removal of containers, movement of containers and correction of inaccuracies.

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

The plan will be reviewed annually as this will also satisfy the requirement of the five year review required by 40 CFR 112.5(b). The Review Certification Form may be found in appendix K.

Fort McCoy Pamphlet 420-28, September 2013 vi

40 CFR 112 CROSS REFERENCE TABLE

Final SPCC Rule Description of Chapter Chapter

§ 112.3(d) PE certification Engineer’s Certification

§ 112.3(e)(1,2) Facility maintains copy of plan 1-3

§ 112.4 Submittal requirements to the regional administrator 4-1

§ 112.5(a) Updating requirements 4-1

§ 112.5(b) Plan reviewed at least once every five years 4-1, Appendix K

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

§ 112.7 Facility management signature Endorsement Page

§ 112.7(a)(1,2) Conformance with the regulations, details on equivalent environmental protection 4-2

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

Figure 2.2, Tables in Chapter 5

§ 112.7(a)(3)(i) The type of oil in each container and its storage capacity Appendix A, 5-X a.

§ 112.7(a)(3)(ii) Discharge prevention measures for routine handling of products 4-13, 5-X b.

§ 112.7(a)(3)(iii) Discharge or drainage controls such as secondary containment 5-X c.

§ 112.7(a)(3)(iv) Countermeasures for discharge discovery, response and cleanup 4-7, Annex A

§ 112.7(a)(4) Spill reporting 4-7, Annex A

§ 112.7(b) Potential discharge from equipment failure 5-X e.

§ 112.7(c) Secondary containment 5-X c.

§ 112.7(d) Contingency planning 4-7

§ 112.7(e) Inspections, tests, and records 4-5, 5-X d.

§ 112.7(f)(1) Personnel training program requirements 4-3

§ 112.7(f)(2) Accountability for discharge prevention 1-1

§ 112.7(g) Security (excluding oil production facilities) 4-4

§ 112.7(h) Loading/unloading 5-X b.

§ 112.7(i) Brittle fracture evaluation requirements 5-X d.

§ 112.7(j) Conformance with Federal and State requirements 4-2, Appendix H

Note that “5-X” indicates a subchapter in each container area described under chapter 5 of the plan.

Fort McCoy Pamphlet 420-28, September 2013 vii

40 CFR 112 CROSS REFERENCE TABLE (Continued)

Final SPCC Rule Description of Chapter Chapter

§ 112.8(b) Facility drainage 2-4, 4-10

§ 112.8(c)(1) Bulk storage containers are compatible with material stored 2-2

§ 112.8(c)(2) Bulk storage containers have appropriate secondary containment

5-X c.

§ 112.8(c)(3) Requirements for drainage of diked areas 4-10

§ 112.8(c)(4) Cathodic protection for buried tanks 5-8

§ 112.8(c)(5) Cathodic protection for partially buried tanks Not applicable

§ 112.8(c)(6) Inspections and integrity testing for aboveground containers 5-X d.

§ 112.8(c)(7) Monitor internal steam heating coils Not applicable

§ 112.8(c)(8) High level alarm requirements 5-X b.

§ 112.8(c)(9) Observe effluent treatment facilities 5-X c.

§ 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 5-X b.

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

Note that “5-X” indicates a subchapter in each container area described under chapter 5 of the plan.

Fort McCoy Pamphlet 420-28, September 2013 1

Chapter 1 Introduction

1-1. Introduction

a. 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 Plan in order to reduce or eliminate oil discharges to navigable waters of the United States. Spill Prevention, Control and Countermeasures (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.

b. This document is the SPCC Plan for Fort McCoy located near Sparta, Wisconsin. This plan has been prepared in accordance with 40 CFR 112 as amended on July 17, 2002, December 26, 2006, and the December 2008 revisions. This plan includes references to industry standards that apply to containers at the facility, and has been certified by a Professional Engineer.

c. The objectives of this plan are:

(1) Provide a written site-specific description detailing how the installation’s operations have complied with the oil pollution prevention requirements.

(2) Demonstrate that planned controls and countermeasures for preventing the harmful discharge of oils to the waters of the United States are established.

(3) Organize routine procedures for monitoring oil use and storage areas and for detecting a release or a potential for a release.

(4) Encourage coordination of spill response activities to minimize any harmful health and environmental effects, limit property damage, and minimize interruption of installation activities.

(5) Include procedures for notification of appropriate governmental agencies and affected communities regarding the discharge of oil and hazardous substances, as required.

(6) Establish a foundation from which installation personnel can be trained in procedures for preventing and controlling an oil spill.

d. Implementation of this plan is the responsibility of Fort McCoy’s Commanding Officer. The SPCC Program Manager in the installation’s Environmental Division is responsible for maintaining this plan.

1-2. Plan Organization

a. 40 CFR 112 requires that the SPCC Plan be prepared in writing and that it follow the sequence specified therein. However, an equivalent plan may be developed provided that it meets all of the applicable requirements listed in 40 CFR 112 and is supplemented by a table cross-referencing the location of the requirements. This plan follows the latter approach. The cross-reference table may be found in the introduction beginning on page vi.

b. Chapter 2 of this plan describes the facility, the installation and the surrounding area. The applicability of the SPCC regulations is described in chapter 3. Chapter 4 contains general information

Fort McCoy Pamphlet 420-28, September 2013 2 required to be in any approved SPCC Plan, and chapter 5 describes the specific container storage groups. Chapter 6 contains the Plan Certification and Professional Engineer’s endorsement.

1-3. Plan Distribution The installation is staffed 24 hours per day, seven days a week. The SPCC Plan with revisions and amendments is maintained in convenient and accessible locations. It is available for review any time during normal working hours, Monday through Friday, excluding Federal holidays, at the installation Environmental Division located at 2171 S. 8th Avenue. Outside of normal working hours, the SPCC Plan is available and maintained at DES Fire and Emergency Services (F&ES) and the Emergency 911 (E911) Center.. Additionally, a copy of the plan is on the Fort McCoy Corporate website https://corporate.mccoy.army.mil/onlinelibrary/McCoyPubs.asp , and maintained by the Monroe County Local Emergency Planning Committee (LEPC). Table 1-1 identifies the plan locations.

Table 1-1 SPCC Plan Distribution

Title Location Commander 100 Headquarters Rd, Fort McCoy Fire Chief Response Vehicles, Fort McCoy Environmental Division, DPW 2171 South 8th Ave, Fort McCoy Safety Office 1678 South 10th Ave, Fort McCoy Occupational Health 2669 Regimental Ave, Fort McCoy Public Affairs 100 Headquarters Rd, Fort McCoy LEPC Monroe County Courthouse, Sparta Sparta Fire Department 118 East Oak, Sparta Sparta Police Department 121 East Oak, Sparta Franciscan Skemp Healthcare 310 West Main, Sparta Tomah Fire Department 316 Arthur Street, Tomah Tomah Police Department 819 Superior Avenue, Tomah Tomah Memorial Hospital 321 Butts Avenue, Tomah Monroe County Sheriff 210 West Oak, Sparta

Chapter 2 Facility Description

2-1. General Information

a. The facility is Fort McCoy, a United States Army Installation, located on approximately 60,000 acres in the north central portion of Monroe County, Wisconsin. The installation occupies part of six townships.

The nearest population centers are the City of Sparta, located approximately seven miles to the west, and the City of Tomah, seven miles to the east. The regional metropolitan center is La Crosse, Wisconsin, located 40 miles west of the installation. The term facility will be used throughout this plan in place of Fort McCoy or installation.

b. The facility opened in 1909. Its original name was Camp Robinson. After World War I, Camp Robinson was renamed the Sparta Ordnance Depot. The facility was renamed Camp McCoy in 1926.

Fort McCoy Pamphlet 420-28, September 2013 3

Camp McCoy served as a major military training location through World War II. It achieved semi-active US Army Installation status in 1974 and was consequently renamed Fort McCoy.

c. The majority of the facility consists of open space used for military training. The northern portion of the facility is used primarily for live fire training. The central portion of the facility, known as the cantonment area, contains barracks, administrative buildings, storage, and support service facilities. The southern portion has additional training areas and live fire ranges.

d. The installation is served by several major highways all running east and west. State Highway 21, is the primary means of access to the cantonment area. Further to the south, Interstate 90 and U.S. Route 16 cross the installation. The Canadian Pacific Railroad has two tracks running parallel to and just south of State Highway 21 that provide rail service to the facility.

e. Figure 2.1, on page 6, is a map of the facility.

2-2. Regulated Oils

a. Oil, as defined in 40 CFR 112.2, means oil of any kind or in any form, including, but not limited to:

fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil.

b. The following SPCC-regulated oils are used at Fort McCoy:

(1) Gasoline

(2) Diesel Fuel/JP-8

(3) Engine Oil

(4) Hydraulic Fluid

(5) Mineral Oil

(6) Mineral Spirits

(7) Transformer Oil

(8) Vegetable Oil and Grease

(9) Used Oils and Sludge

c. These products are stored in a variety of containers including underground storage tanks, aboveground storage tanks, electrical operating equipment, generator day tanks, 55-gallon drums, and smaller containers. Appendix A lists specific information for the SPCC regulated containers at this facility.

With the exception of two tanks, all of the regulated containers are designed to operate at ambient temperatures and pressures. Also, all containers are designed to be compatible with the material stored.

d. Figure 2.2, page 7, identifies fixed Petroleum, Oils and Lubricants (POL) storage locations.

Fort McCoy Pamphlet 420-28, September 2013 4

2-3. Containers Not Covered By this Plan

a. Containers less than 55 gallons.

b. Containers owned and operated by contractors temporarily working on installation property are not covered by this plan. Such containers may include fuel tanker trucks or temporary aboveground storage tanks (AST) for fueling construction equipment. These contractors are responsible for determining SPCC applicability and developing a site-specific plan if necessary. Spill response activities may involve installation personnel, but such containers are not covered by this plan. However, outside contractors bringing POL and other potentially hazardous materials onto the installation must submit an inventory of materials and site-specific Health and Safety and Spill Plans to the Installation Safety Office (ISO) prior to beginning work.

c. The local power utility, Excel Energy, operates electrical substations near the main entrance that contain oil-filled electrical equipment that could have more than 55-gallon capacity. Oil filled electrical equipment is specifically exempt from the definition of a storage container and, therefore, is exempt from the SPCC Plan standards. However, Excel is responsible for any oil storage activities at the substation.

Pursuant to chapter C.10 of the agreement effective April 5, 2000, between Fort McCoy and Northern States Power Company (Excel Energy). Excel Energy is responsible for complying with all Federal, state and local environmental and safety and associated environmental assessments, studies, permitting, and coordination to execute their portion of the contract. This agreement applies to all oil filled primary electrical equipment such as transformers and capacitors, either in operation or in storage at the installation.

Also, the Wisconsin Army National Guard Maneuver Area Training Equipment Site (MATES) owns and operates two facilities on the installation and is responsible for any SPCC-regulated containers at those sites.

The City of Sparta operates an airplane hangar and fueling facilities at the facility airfield and is responsible for any SPCC-regulated containers at that location. Pursuant to Condition 11 of the November 12, 1986, lease agreement between Fort McCoy and the City of Sparta; the City of Sparta shall comply with all applicable laws, ordinances, and regulations of the State, county, and municipality where their facilities are located, with regard to construction, sanitation, licenses or permits to do business, and all other matters.

d. Underground Storage Tanks (UST) subject to all the technical requirements of 40 CFR 280 or to a State program approved under 40 CFR 281 are exempted from all SPCC requirements. However, they must be shown on the facility diagram. This facility has several USTs subject to all of the technical requirements of 40 CFR 280. These containers are shown in Table 2-1.

Fort McCoy Pamphlet 420-28, September 2013 5

Table 2-1 SPCC-Exempt Underground Storage Tanks (UST) Subject to 40 CFR 280

Container

ID

Location

Service Application

Capacity (Gallons)

Material of Construction

242-1 MATES – B242 Used Oil 550 Fiberglass 242-3 MATES – B242 JP-8 2,500 Fiberglass

1538-1 AAFES – B1538 Gasoline 12,000 Fiberglass 1538-2 AAFES – B1538 Gasoline 15,000 Fiberglass 6010-1 Airfield – B6010 JP-8 20,000 Steel 6010-2 Airfield – B6010 JP-8 20,000 Steel 6010-3 Airfield – B6010 JP-8 20,000 Steel 6010-4 Airfield – B6010 JP-8 20,000 Steel

Sparta-1 Sparta Airport Aviation Gas 1,000 Steel Sparta-2 Sparta Airport Aviation Gas 1,000 Steel

e. This facility does not currently have any permanently closed containers that are exempt from the SPCC regulations. In the future should the facility permanently close a tank, the tank and any connecting piping will be emptied of liquid and sludge, all associated piping disconnected, and the tanks will be clearly labeled as permanently closed.

f. Motive power containers, meaning any onboard bulk storage container used primarily to power the movement of a motor vehicle, or ancillary onboard oil-filled operational equipment are not covered by this plan. An onboard bulk storage container which is used to store or transfer oil for further distribution is not a motive power container. The definition of motive power container does not include oil drilling or work over equipment, including rigs. This facility operates several types of equipment that meet this definition including military track and tactical equipment, earth moving equipment, snow removal equipment, recreational vehicles, and tractor-trailer trucks.

2-4. Navigable Waters

a. The EPA defines “navigable waters” in 40 CFR 112.2. The term includes wetlands, lakes, bays, rivers, and streams of the United States.

b. There are approximately 261 surface acres of ponds and streams located on the facility, including 51 miles of trout streams. Wetlands cover approximately 4,800 acres.

c. Most of the streams on the facility flow into two river basins; the La Crosse River and the Black River. Headwaters of the La Crosse River are located in the northeastern portion of Fort McCoy. Ranch and Clear Creeks, both located in the northwestern portion of the installation, flow into the Black River basin. Land to the east of the installation, including a very small portion of the installation, is located in the Lemonweir River portion of the Wisconsin River basin. The La Crosse River is considered a minor Mississippi drainage, while the Black and Wisconsin Rivers are considered major Mississippi drainages.

Fort McCoy Pamphlet 420-28, September 2013 6

Fort McCoy Pamphlet 420-28, September 2013 7

Fort McCoy Pamphlet 420-28, September 2013 8

Chapter 3 Applicability Determination

a. Fort McCoy meets the general applicability criteria of the Oil Pollution Prevention regulations in 40 CFR 112. The facility is not a transportation–related facility and is not involved in the bulk transport of petroleum as defined in the Memorandum of Understanding between the Secretary of Transportation and the Administrator of the Environmental Protection Agency, dated November 24, 1971. The facility-wide aboveground oil storage capacity totals more than 1,320 gallons, and oil discharges could potentially reach navigable waters. For these reasons, the facility must prepare a SPCC Plan.

b. 40 CFR 112.20(e) requires that affected facilities determine their potential for substantial harm and the ensuing requirement to file a Facility Response Plan (FRP) with the EPA Regional Administrator.

Figure 3.1 shows the Flowchart of Criteria for Substantial Harm from attachment C-1 to appendix C of 40 CFR 112. This flowchart asks several questions regarding the 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.

c. Fort McCoy does not pose a threat of substantial harm to a fish and wildlife sensitive environment or a drinking water intake. However, the installation has prepared a FRP, in accordance with AR 200-1. The FRP is included as annex A to this plan.

Fort McCoy Pamphlet 420-28, September 2013 9

Figure 3.1 Criteria for Substantial Harm Flowchart

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

SUBMIT RESPONSE PLAN

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?

YES

NO

NO

NO

NO

YES

NO

NO

YES

YES

YES

YES

Chapter 4 General Plan Requirements

4-1. Plan Review and Submittal

a. This plan shall be reviewed and evaluated annually. The Review Certification Form located in appendix K shall be completed upon each review. 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

Fort McCoy Pamphlet 420-28, September 2013 10 amendments to the plan, then a Professional Engineer must recertify the plan. Technical amendments include changes to the plan that require engineering practice such as including physical modifications or changes in facility procedures. If the changes are non-technical in nature, e.g., contact name, phone number, container identification number, etc., then the facility owner must review the plan and indicate that no technical changes were made.

b. This plan must be updated when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge. Examples of changes that may require amendment of the plan 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 at a facility. Movement of containers within an area that does not increase the potential for a discharge would not require an update to the plan.

c. An amendment made to the plan must be prepared within six months of the change in facility 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.

d. Pursuant to 40 CFR 112.4 a spill report must be submitted to the EPA Regional Administrator and the state agency managing SPCC programs when a facility has:

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

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

e. The report must be submitted to the EPA Regional Administrator within 60 days from the date of the discharge that required the submittal. The Regional Administrator may require that the SPCC Plan be submitted for review. The information that must be included in the report is identified below. A complete copy of all information provided to the Regional Administrator must also be provided to the appropriate state agency.

(1) Name of the facility;

(2) Your name;

(3) Location of the facility;

(4) Maximum storage or handling capacity of the facility and normal daily throughput;

(5) Corrective action and countermeasures you have taken, including a description of equipment repairs and replacements;

(6) An adequate description of the facility, including maps, flow diagrams, and topographical maps, as necessary;

Fort McCoy Pamphlet 420-28, September 2013 11

(7) The cause of such discharge including a failure analysis of the system or subsystem in which the failure occurred;

(8) Additional preventive measures you have taken or contemplated to minimize the possibility of recurrence; and

(9) Such other information as the Regional Administrator may reasonably require pertinent to the plan or discharge.

4-2. Conformance with Federal and State Regulations

a. The main purpose of this plan is to comply with the requirements of 40 CFR 112. Pursuant to 40 CFR 112.7 the SPCC Plan must include a discussion of the facility’s conformance with the applicable portions of the regulations and identify any additional facilities or procedures, methods, or equipment that may be necessary to comply with the standards therein. These additional requirements must be listed separately and detail provided regarding their implementation and startup. Non-conforming items are addressed throughout the plan in respective chapters with a comprehensive discussion included in appendix H.

b. The State of Wisconsin also regulates POL storage and transfer activities pursuant to Department of Agriculture,Trade and Consumer Protection Chapter SPS 310. The purpose of these regulations is to provide for safe storage, display, installation, operation, use, maintenance, and transportation of flammable and combustible liquids and the equipment, facilities and buildings that are used to store, transfer and dispense them. Deviations from SPS 310 are also included in appendix H.

c. The LEPC indicates that there are no local requirements more stringent than the Federal requirements with regard to SPCC plans.

4-3. Personnel Training

a. As required by 40 CFR 112.7(f)(1 and 3), oil-handling personnel are trained in the operation and maintenance of equipment to prevent discharges. The Environmental Division conducts training on, at least, an annual basis for all oil-handling personnel in spill prevention and response. This training includes a review of this SPCC Plan, applicable pollution control laws, spill response procedures, and the spill history for the facility. Training will highlight and describe known malfunctioning components and recently developed precautionary measures to prevent spills. Personnel also receive specific training in petroleum product handling procedures and equipment maintenance and operation. This training may include instruction on the following topics, dependent upon the employee’s defined role in oil pollution prevention and spill response:

(1) Overview of applicable environmental regulations.

(2) Potential environmental and health hazards from regulated materials.

(3) Causes of leaks, spills, and releases.

(4) Implementation of pollution prevention measures.

(5) Emergency recognition, alerting, and response procedures.

Fort McCoy Pamphlet 420-28, September 2013 12

(6) Use and location of communication and alarm systems.

(7) Lines of authority during a spill.

(8) Location of personal protective equipment, spill response equipment, and cleanup materials.

(9) Inspection and maintenance of equipment.

(10) Location of controls for operation cut-off and/or shutdown.

(11) Appropriate response to spills.

b. Each activity listed in Table 4-1 is required to attend annual spill prevention training. Training will be offered on a quarterly basis according to the schedule in Table 4-1. This training is also available to any activity requesting information and/or training. MATES conducts their own spill prevention training in accordance with their SPCC Plan.

Table 4-1 Spill Prevention Training Schedule

Quarter Location Building # 1st PX Gas Station 1538 85th Division/181st 1871 Commissary 1537 Wastewater Treatment Plant 2260, 2280 Water Treatment Plant 5015, 5021, 7060

ECS 67 3050, 2682, 2683, 2684

IMMA Heavy 200 IMMA Allied Trades 200, 204 IMMA Wheeled Vehicle 200 IMMA Supply 200, 201, 206

IMMA TES 208

IMMA Can Point 205

DOL Food Service

50, 90, 95, 605, 639, 805, 1571, 1616, 1626, 1716, 1717, 1738, 1816, 1817, 1826, 1827, 2416, 2427, 2516, 2527, 2528, 2627, 2674, 2715, 2727, 2815, 2827, COL Liberty, COL Freedom, AT-MOB DFAC

DPTMS Range Maintenance 2785

DPTMS RETS 8129, R029S

Ammunition Supply Point 9005, 9056 2nd SEA BEES 2880 Reserve Airport Hanger 6058 Whitetail Ridge 8060 Pine View Campground 8053 DPW Washrack 252 3rd Rumpel Fitness Center 1121, 1122 Fire Department 1680

Fort McCoy Pamphlet 420-28, September 2013 13

Quarter Location Building #

DRMO 2184

Range Control 2954

LRAM 2954, 2955

DPW Natural Resources Branch 2168 USNCO Academy Motor Pool 1446 4th 90-Day Storage/Re-use It Store 207 MWR Autocraft 1763 Central Fuels 3010 DPW Pest Control 2220 DOL Engine House 2195 1152nd Trans Co/Rail Ops 2195 DPW Heating Shop 2116C DPW Metal Shop 2116D DPW Roads and Grounds 1152 DPW Supply and Paint Storage 2118, 2120, 2122 DPW Supply 1370 DPW Supply Paint Storage 2198 DPW Paint Shop 2117, 2199 RTS Maintenance 2107, 2108 RTS Medical Maintenance 1093 RTS Medical Ground Maintenance 10005

4-4. Security The cantonment portion of the facility is a secured military installation. Vehicle entrance gate guards require positive identification and all vehicles are subject to random searches. Security specific to each geographic container area is discussed in the appropriate part of chapter 5. All container areas on the facility have adequate facility lighting.

4-5. Recordkeeping Individual shops maintain signed inspection and test records for the containers within their control. In accordance with 40 CFR 112.7(e), records are maintained for a minimum of three years. Individual shops and/or the Environmental Division maintain inspection and testing records for certified inspections for the life of the container. Inspection and testing procedures for each container are described in more detail in chapter 5 of this plan.

4-6. Spill History The facility’s spill history in appendix D shows dates, quantities, and reportability of all spills for the last five years. All spills over one gallon, whether they are a reportable quantity or not, are noted in the facility’s spill log as maintained by the installation’s Environmental Division.

4-7. Spill Response This section lists general spill response procedures. More detailed information may be found in the FRP included as annex A attachment to this document.

a. If a spill occurs, installation personnel follow the response, reporting, and cleanup procedures appropriate to the level of spill. Trained spill response personnel will promptly correct and cleanup any visible discharges. Table 4-2 indicates the various spill levels and reporting requirements.

Fort McCoy Pamphlet 420-28, September 2013 14

Table 4-2 Spill Response, Reporting, and Cleanup Procedures

Spill Volume (Gallons) Response Report To Less than 1 Shop Personnel None

Greater than 1 Fire Department/Range Control DPW Environmental Division and

State of Wisconsin by DPW Environmental if Gasoline

Greater than 5 Fire Department/Range Control State of Wisconsin by DPW Environmental Division

Any amount that reaches a navigable water Fire Department/Range Control

National Response Center and State of Wisconsin by DPW

Environmental Division

b. The DES Fire and Emergency Services is the primary responder for spills in the Cantonment area and can be reached from any installation phone by dialing 608-388-2266. Spills on the ranges should be reported to Range Control at 608-388-4848 or frequency 46.80. The person(s) discovering a spill are responsible for remaining at the scene until released by the On-Scene Coordinator.

c. Spill reporting may include notifications to the National Response Center (NRC), the Wisconsin Department of Natural Resources, and the Monroe County LEPC. The EPA does not distinguish between types of oil, and (according to 40 CFR 110.6) any spill that causes a sheen upon “navigable waters” or that violates applicable water quality standards must be reported to the NRC. For the installation, this means that the NRC must be called if an oil spill reaches the La Crosse river or its tributaries, as shown on figure 2.1.

d. Table 4-3 lists additional agencies that the SPCC Program Manager may need to contact to report a spill. However, if a spill reaches the La Crosse river or its tributaries, Directorate of Public Works (DPW) Environmental Division will contact the NRC and the State of Wisconsin.

Table 4-3 Spill Reporting Agencies

Agency Phone LEPC for Monroe County 608-269-8711 State Emergency Planning Committee 608-242-3232 Wisconsin DNR 800-943-0003 National Response Center (NRC) 800-424-8802

e. The information in Table 4-4 should be available when reporting a spill. Spill response equipment is maintained throughout the facility. Appendix E lists the spill response equipment and supplies maintained in the Fire Department’s HazMat Response Truck and Trailer. The Fire Department estimates that they could handle a POL spill of up to 500 gallons. Spills exceeding this volume would require assistance from outside responders. The facility has mutual aid agreements with emergency response departments in the surrounding communities. Copies of the agreements are included in appendix F.

f. Table 4-4 identifies the information that should be obtained, if possible, by the person receiving notification of a spill.

Fort McCoy Pamphlet 420-28, September 2013 15

Table 4-4 Spill Reporting Information

Parameter Comment Individual Reporting Spill Name of person making the report.

Phone How can the person reporting be reached?

Date and Time of Spill When did the spill occur or was first observed?

Type of material discharged Oil, Diesel, JP-8, other?

Estimate of the total quantity discharged Name of any waters involved or threatened Is the spill into or near any waterways?

Extent of actual and potential water pollution Estimate. Is it flowing toward open water?

Location of the spill Building number, range number, etc.

The source of the discharge Identify tank, pipeline or unit that is leaking.

Description of all affected media Is the spill on pavement or soil?

Cause of the discharge Vehicle accident, broken hose, etc.

Any damages or injuries caused by the discharge

Known injuries first. Property damage second.

Any known or anticipated health risks associated with the incident

If yes, move to a safe location upwind and motion for others to do as well.

Actions being used to stop, remove, and mitigate the effects of the discharge How is the spill currently being managed?

The names of individuals and/or organizations who have also been contacted and the time contacted.

Who else has been called?

4-8. Inspection and Testing The inspection and testing requirements for regulated containers in this plan were based on consideration of applicable industry standards. The Steel Tank Institute issued Standard SP001-03 that applies to stationary shop-built tanks. This standard requires a certified inspection every 10 years and a certified integrity test every 10 years. However, integrity tests will not be performed for small shop-built tanks (i.e., less than 5,000 gallons). Instead, facility personnel will provide equivalent environmental protection as allowed under 40 CFR 112.7(a)(2) by conducting monthly visual inspections. The Monthly Aboveground Storage Tank Inspection Form (Fort McCoy Form 372) can be found at the following Fort McCoy Extranet link: https://extranet.mccoy.army.mil/AKO/FormsAndRegulations/index.asp . All items identified on the form shall be inspected monthly. All records of inspections will be maintained for three years.

4-9. Mobile and Portable Container Policy

a. Fort McCoy 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 7,500 gallons.

Portable containers are typically mounted on skids or saddles but may remain in place for an extended period of time. Mobile containers are mounted to frames with wheels. Examples of mobile containers include bowsers, portable generator fuel tanks, and tanker trucks. Personnel frequently move these https://extranet.mccoy.army.mil/AKO/FormsAndRegulations/index.asp

Fort McCoy Pamphlet 420-28, September 2013 16 containers to another area or alter the number of containers in a particular area. For this reason, details for all the drums, portable containers, and mobile containers at this facility are not included in this plan.

b. All containers covered by this Mobile and Portable Container Policy must have some form of secondary containment. This secondary containment may include booms or spill pallets, diked storage areas, and/or storing containers inside a building with no spill route to navigable waters. Secondary containment is required when containers covered under this policy contain fuel and are stationary for at least 24 consecutive hours. For example, bowsers and tanker trucks do not require secondary containment when moving from one location to another to provide fuel, but do require secondary containment when parked for 24 consecutive hours. See appendix H for more information on mobile fuel tanker requirements.

c. As allowed under 40 CFR 112.7(a)(2), this facility will provide equivalent environmental protection through frequent inspections and testing as shown in table 4-5. These inspections are based upon professional engineering recommendations.

Table 4-5 Mobile and Portable Container Inspections and Testing

Inspection Method Frequency Routine external inspection for leaks Visual At Least Monthly

Integrity Test or Internal Inspection

Hydrostatic, ultrasonic or other method recommended by the manufacturer or military standard

As Required

d. Records of external inspections shall be maintained for at least three years. Records of integrity tests and internal inspections should be maintained for the life of the container. For integrity testing, personnel should implement a method for tracking the container's age, if necessary.

4-10. Precipitation Inspection in Diked Areas

a. Any accumulated rainwater in diked areas will be promptly removed so that containment capacity will not be significantly reduced and corrosion of tanks and containers will be avoided.

b. Removal of accumulated precipitation in secondary containment structures will be done in a manner that does not result in a discharge of oil to surface waters. Accumulated rainwater will be examined and determined to be free of oil contamination. Drainage of accumulated precipitation from diked storage areas into a storm drain or into a drainage system that empties into surface waters (and bypassing the installation’s Waste Water Treatment Plant (WWTP)) will be accomplished in the following manner:

(1) Any accumulated precipitation in diked areas will be promptly removed through pumping or draining. The bypass valve, if present, will normally be closed except when the accumulation is being removed.

(2) Appropriate operating personnel will inspect drainage prior to removal to ensure compliance with applicable water quality standards and to ensure that the drainage will not cause a harmful discharge of

Fort McCoy Pamphlet 420-28, September 2013 17 oil. Accumulated precipitation will be observed to be free of any film, sheen, or discoloration due to the presence of oil. If oil is detected, it will either be removed prior to discharge and the accumulated precipitation discharged to the installation’s WWTP with prior approval, or the entire accumulation removed for proper off-site disposal.

(3) The bypass valve will be opened during the removal of accumulated precipitation and then properly closed following drainage. This operation will be conducted under responsible supervision.

(4) Records will be maintained as part of this SPCC Plan by operating personnel whenever accumulated precipitation, determined to be in compliance with water quality standards, is drained from diked storage areas into storm drains or into surface waters. The Drainage Event Form (Fort McCoy Form

374) shall be used to record these drainage events, i.e., date, time, personnel, and to document the inspection of the drainage. Area operators shall maintain copies for three years. Fort McCoy Form 374 can be found at the following Fort McCoy Extranet link:

https://extranet.mccoy.army.mil/AKO/FormsAndRegulations/index.asp.

c. If any oil sheen or accumulation of oil is observed, an alternate method of draining the diked area will be employed, unless the drainage will be directed through the installation’s WWTP or an oil-water separator before entering a storm drain or surface water. The source of the oil will also be determined and corrections implemented to prevent any future oil releases.

4-11. Undiked Areas

a. SPCC regulations in 40 CFR 112.8(b) require facilities to prevent potential discharges from undiked areas by designing facility drainage systems to flow into catchment basins or lagoons. A significant portion of the facility’s drainage system is not engineered in this fashion. The limited potential for spills outside of typical fuel handling areas does not warrant a complete redesign of the existing drainage system. The facility’s spill response capabilities as described in chapter 4-7 and proper personnel training as described in chapter 4-3 will prevent potential discharges from any undiked areas. These activities provide equivalent environmental protection (as allowed under 40 CFR 112.7(a)(2)) to a catchment basin.

b. Fuel tanks on some larger equipment have storage capacities exceeding 55 gallons. Potential spills from these containers may occur in undiked areas. Spill response activities will follow the procedures outlined in chapter 4-7.

4-12. New Construction Any new construction will comply with the applicable requirements of 40 CFR 112.8(d) and Wisconsin Administrative Code SPS 310. New buried metallic piping will either have a protective coating, double walled and cathodic protection. In the event that piping is exposed during an excavation, the pipe will be inspected for corrosion.

4-13. General Product Handling

a. Installation personnel follow standard operating procedures for product handling as listed in applicable military standards. These documents establish policy and administrative procedures for fuel operations, specify duties for fuel management personnel, provide guidelines and procedures for operating storage tanks, and outline responsibilities for operation and maintenance of storage and

Fort McCoy Pamphlet 420-28, September 2013 18 dispensing equipment. Installation personnel follow the procedures specified in these documents for all product handling activities.

b. These documents also specify truck unloading procedures for the unloading rack that includes some method to prevent truck departure prior to complete decoupling from the transfer point and a visual check of all valves to ensure no leakage. Signs are located near the unloading racks that remind drivers to disconnect all lines before leaving. Loading rack connections are capped and locked when not in use.

The only loading/unloading racks on the facility are in the Central Fuels tank farm (building 3010/3080) and the airport (building 6010). In general, personnel follow the spill prevention procedures below when transferring product to or from a tanker truck:

(1) Load or unload in approved locations only.

(2) Establish communications between the pumping and receiving stations.

(3) Verify the remaining volume of the receiving container.

(4) Properly close…