2022-Fort Buchanan SPCCP Final.pdf

December 2022 USAG Fort Buchanan SPCC Plan
Spill Prevention, Control, and
Countermeasure (SPCC) Plan
Prepared for:
US Army Garrison Fort Buchanan
Directorate of Public Works
Environmental Division
December 2022
Prepared by:
CRANSTON LLC
452 Ellis Street
Augusta, GA 30901

This Page Intentionally Left Blank

TABLE OF CONTENTS
ENGINEER'S CERTIFICATION..........................ERROR! BOOKMARK NOT DEFINED.
MANAGEMENT APPROVAL ..............................ERROR! BOOKMARK NOT DEFINED.
REVISION TRACKING FORM.......................................................................................III
40 CFR 112 CROSS REFERENCE TABLE ...................................................................IV
1.0 INTRODUCTION...................................................................................................1
2.0 FACILITY DESCRIPTION .....................................................................................2
2.1 GENERAL INFORMATION..........................................................................2
2.2 CONTAINERS NOT COVERED BY THIS PLAN .........................................3
2.3 NAVIGABLE WATERS ................................................................................3
3.0 APPLICABILITY DETERMINATION......................................................................8
4.0 GENERAL PLAN REQUIREMENTS ...................................................................10
4.1 PLAN REVIEW AND SUBMITTAL.............................................................10
4.2 CONFORMANCE WITH FEDERAL, ARMY, AND COMMONWEALTH OF PUERTO
RICO REGULATIONS ........................................................................................10
4.3 PERSONNEL TRAINING...........................................................................10
4.4 SECURITY ................................................................................................11
4.5 RECORDKEEPING ...................................................................................11
4.6 SPILL HISTORY........................................................................................11
4.7 SPILL RESPONSE....................................................................................11
4.8 INSPECTION AND TESTING....................................................................15
4.9 MOBILE AND PORTABLE CONTAINER POLICY.....................................17
4.10 RAINWATER INSPECTION IN DIKED AREAS .........................................18
4.11 UNDIKED AREAS .....................................................................................18
4.12 NEW CONSTRUCTION.............................................................................19
4.13 GENERAL PRODUCT HANDLING............................................................19
5.0 CONTAINER AREAS ..........................................................................................20
5.1 AAFES GAS STATION (BUILDING 677) ...................................................20
5.2 AUTO HOBBY SHOP (BUILDING 159) .....................................................24
5.3 AQUA PARK (BUILDING 161)...................................................................28
5.4 GOLF COURSE (BUILDING 172)..............................................................30
5.5 U.S. ARMY RESERVE ORGANIZATIONAL MAINTENANCE SHOP (OMS)
(BUILDING 528) .................................................................................................35
5.6 DPW COMPLEX (BUILDINGS 34, 37, AND 38) ........................................38
5.7 LOGISTIC READINESS CENTER (LRC) FUEL STATION (BUILDING 613)43
5.8 SCHOOL BUS STORAGE AREA and DODEA (BUILDING 566)...............46
5.9 ARMED FORCES RESERVE CENTER (AFRC) MOTOR POOL (BUILDING 615)
48
5.10 597TH
QUARTERMASTER CO. US ARMY RESERVE – ORGANIZATIONAL
MAINTENANCE SUPPORT (OMS) (BUILDING 609) .........................................51
(IN PROCESS)

5.11 NATIONAL GUARD READINESS CENTER, USPFO AND PRNG HQ (BUILDINGS
540 THROUGH 552)...........................................................................................53
5.12 ANTILLES ELEMENTARY SCHOOL (BUILDING 700) and CHILD/YOUTH
SERVICES FACILITY (BUILDING 1110) ...................................................58
5.13 EMERGENCY GENERATORS AND FORT BUCHANAN FIRE PUMP ENGINES
60
5.14 OFOE ELECTRICAL TRANSFORMERS...................................................71
5.15 USED FOOD GREASE CONTAINERS .....................................................74
5.16 OFOE HYDRAULICS.................................................................................75
6.0 CORRECTIVE ACTIONS ....................................................................................77
Appendix A SPCC Regulated Containers
Appendix B Certification of the Applicability of the Substantial Harm Criteria
Appendix C Discharge Report to US EPA Regional Administrator
Appendix D1 Mutual Aid Agreement – Commonwealth of Puerto Rico Fire Department
Appendix D2 Mutual Aid Agreement – Puerto Rico Department of Public Safety
Appendix E Volume Calculations for Secondary Containment Dikes
Appendix F Fuel Management Practices Memorandum
Appendix G Inspection Checklists
Appendix H Immediate Actions
Appendix I Reportable Quantities
Appendix J Oil Spill Response Organizations
Appendix K Fort Buchanan Spill Log
Appendix L Spill Contingency Plan
Appendix M Photographic Documentation
LIST OF FIGURES
Figure 2.1 Fort Buchanan Site Map 5
Figure 2.2 Fort Buchanan Overview and Drainage Map 6
Figure 2.3 Fort Buchanan Transformers 7
Figure 3.1 Substantial Harm Criteria Flowchart 9
Figure 5.1.1 AAFES Gas Station (Building 677) 22
Figure 5.2.1 Auto Hobby Shop (Building 159) 26
Figure 5.3.1 Aqua Park (Building 161) 29
Figure 5.4.1 Golf Course (Building 172) 32
Figure 5.5.1 U.S. Army Reserve OMS (Building 528) 36
Figure 5.6.1 DPW Complex (Buildings 34, 37, and 38) 40
Figure 5.7.1 Logistic Readiness Center Fuel Station (Building 613) 44
Figure 5.8.1 School Bus Storage Area and DODEA (Building 566) 47
Figure 5.9.1 AFRC Motor Pool (Building 615) 50
Figure 5.10.1 Quartermaster OMS (Building 609) 52
Figure 5.11.1 National Guard Readiness Center, USPFO, and PRANG HQ 55
(Buildings 540 through 552)

Figure 5.12.1 New Elementary School (Building 700 & 1110) 59
LIST OF TABLES
Table 2.1 SPCC Exempt USTs Subject to 40 CFR 280 3
Table 4.1 Spill Response and Reporting Procedures 12
Table 4.2 Spill Reporting Agencies 12
Table 4.3 Spill Reporting Information 14
Table 4.4 AST and Piping Inspection and Testing 16
Table 4.5 Mobile and Portable Container Inspections and Testing 17
Table 5.1.1 AAFES Gas Station Containers 21
Table 5.1.2 AAFES Gas Station Product Handling 23
Table 5.1.3 AAFES Gas Station Secondary Containment 23
Table 5.1.4 AAFES Gas Station Potential Spill Scenarios 24
Table 5.2.1 Auto Hobby Shop Containers 24
Table 5.2.2 Auto Hobby Shop Product Handling 25
Table 5.2.3 Auto Hobby Shop Secondary Containment 27
Table 5.2.4 Auto Hobby Shop Potential Spill Scenarios 27
Table 5.3.1 Aqua Park Containers 28
Table 5.3.2 Aqua Park Product Handling 28
Table 5.3.3 Aqua Park Secondary Containment 28
Table 5.3.4 Aqua Park Inspection and Testing 30
Table 5.3.5 Aqua Park Potential Spill Scenarios 30
Table 5.4.1 Golf Course Containers 30
Table 5.4.2 Golf Course Product Handling 33
Table 5.4.3 Golf Course Secondary Containment 33
Table 5.4.4 Golf Course Potential Spill Scenarios 34
Table 5.5.1 U.S. Army Reserve OMS Containers 35
Table 5.5.2 U.S. Army Reserve OMS Product Handling 37
Table 5.5.3 U.S. Army Reserve OMS Secondary Containment 37
Table 5.5.4 U.S. Army Reserve OMS Potential Spill Scenarios 38
Table 5.6.1 DPW Complex Containers 38
Table 5.6.2 DPW Complex Product Handling 41
Table 5.6.3 DPW Complex Secondary Containment 41
Table 5.6.4 DPW Complex Potential Spill Scenarios 42
Table 5.7.1 Logistic Readiness Center Fuel Station Containers 43
Table 5.7.2 Logistic Readiness Center Fuel Station Product Handling 43
Table 5.7.3 Logistic Readiness Center Fuel Station Secondary Containment 45
Table 5.7.4 Logistic Readiness Center Fuel Station Potential Spill Scenarios 45
Table 5.8.1 School Bus Storage Area and DODEA Containers 46
Table 5.8.2 School Bus Storage Area and DODEA Product Handling 46
Table 5.8.3 School Bus Storage Area and DODEA Secondary Containment 48
Table 5.8.4 School Bus Storage Area and DODEA Potential Spill Scenarios 48
Table 5.9.1 AFRC Motor Pool Containers 48

Table 5.9.2 AFRC Motor Pool Product Handling 49
Table 5.9.3 AFRC Motor Pool Secondary Containment 49
Table 5.9.4 AFRC Motor Pool Potential Spill Scenarios 51
Table 5.10.1 Quartermaster OMS Containers 51
Table 5.10.2 Quartermaster OMS Product Handling 51
Table 5.10.3 Quartermaster OMS Secondary Containment 53
Table 5.10.4 Quartermaster OMS Potential Spill Scenarios 53
Table 5.11.1 National Guard Readiness Center, USPFO and PRNG HQ Containers 53
Table 5.11.2 National Guard Readiness Center, USPFO and PRNG HQ Product Handling 56
Table 5.11.3 National Guard Readiness Center, USPFO and PRNG HQ Secondary
Containment 56
Table 5.11.4 National Guard Readiness Center, USPFO and PRNG HQ Potential
Spill Scenarios 57
Table 5.12.1 Antilles Elementary School and Child/Youth Service Facility Containers 58
Table 5.12.2 Antilles Elementary School and Child/Youth Service Facility Product Handling 58
Table 5.12.3 Antilles Elementary School and Child/Youth Service Facility Secondary
Containment 60
Table 5.12.4 Antilles Elementary School and Child/Youth Service Facility Potential Spill
Scenarios 60
Table 5.13.1 Emergency Generators/ Fort Buchanan Fire Pumps Engine Storage Tanks 60
Table 5.13.1A Emergency Generators at Las Colinas Housing Area 63
Table 5.13.2 Emergency Generator Product Handling 65
Table 5.13.3 Emergency Generators Secondary Containment 65
Table 5.13.4 Emergency Generators & Fort Buchanan Fire Pumps Potential Spill Scenarios 67
Table 5.14.1 Electrical Transformers 71
Table 5.15.1 Grease Drum Containers 74
Table 5.15.2 Grease Drum Product Handling 74
Table 5.15.3 Grease Drum Secondary Containment 75
Table 5.15.4 Grease Drums Potential Spill Scenarios 75
Table 6.1 Corrective Actions 77

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Page ii
INTENTIONAL BLANK

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REVISION TRACKING FORM
Date Revision No. Plan Section Description
Jul 2013 5.0, Appendix A
Added new emergency generators, new
containers for used food grease, and
storage tanks returned to active status.
Dec 2013
5.0, 6.0,
Appendix A
Added new emergency generators and
new transformer.
Feb 2015
5.0, 6.0,
Appendix A
Added new DPW Complex, new OMS,
new transformers, new generators, and
National Guard Readiness Center.
Jan 2016
5.0, 6.0,
Appendices A, E,
I, J
Added new Logistics Readiness Center
Fuel Station, new elementary school,
Fort Buchanan Fire pump at bowling
alley, sodium hypochlorite tank, new
generators, and new transformers.
Added new appendices for chemical
spills and cleanup contractors.
Removed Former AAFES Station,
substations 1 and 2, and transformers.
Aug 2019
Reviewed new generators and
demolition and new construction sites.
Oct 2022
Reviewed and updated new generators,
transformers. Addition of contingency
spill plan for Oil Filled Operational
Equipment and partial photo log.
Dec 2022 Final Plan
Note: If Non-technical revisions, such as changes in contact information, do not
require PE Certification. Except as provided in 40 CFR § 112.6, have a Professional
Engineer certify any technical amendments to your Plan in accordance with § 112.3(d).
In accordance with 40 CFR 112.5(b), US Army Garrison (USAG) Fort Buchanan, Directorate of
Public Work (DPW) – Environmental Division should perform a review and evaluation of this
SPCC Plan at least once every five years from the date the facility becomes subject to this part.
If there are no changes during the term of this SPCC plan, the Environmental Division Chief will
certify the following statement:
“I have completed review and evaluation of the SPCC Plan for USAG Fort Buchanan on
December 2027, and will not amend the Plan as a result.”
Signed:
Environmental Chief Division
Date:
If there are changes during the years of validity of the plan, it will be amended, and the
signature will be required.
The next plan review is therefore scheduled to take place on or prior to December 2027.

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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, 5.14
§ 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, App. L
§ 112.7(e) Inspections, tests, and records 4.5, 4.8, 4.9, 5.x.4*
§ 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 5.14, 5.16

Page v
Final SPCC Rule Rule Requirement Equivalent Section
§ 112.8(b) Facility drainage
2.3, Figure 2.1, Figure
2.2, 4.11
§ 112.8(c)(1) Compatible bulk storage containers 2.1
§ 112.8(c)(2)
Bulk storage containers secondary
containment
2.1, 5.x.3*
§ 112.8(c)(3) Requirements for drainage of diked areas 4.10
§ 112.8(c)(4) Cathodic protection for buried tanks N/A
§ 112.8(c)(5) Cathodic protection for partially buried tanks N/A
§ 112.8(c)(6)
Inspections and integrity testing for
aboveground containers
4.8, 4.9, 5.x.4*
§ 112.8(c)(7) Monitor internal heating coils N/A
§ 112.8(c)(8) High level alarm requirements 5.x.2*
§ 112.8(c)(9) Observe effluent treatment facilities N/A
§ 112.8(c)(10) Correct visible discharges 4.7
§ 112.8(c)(11)
Locate mobile containers in secondary
containment
4.9
§ 112.8(d)
Facility transfer operations, pumping, and
facility process
4.13, 4.8
§ 112.20(e) Certification of Substantial Harm Criteria 3.0, Appendix C
*Note that “5.x” indicates a subsection in each Container Area described under Section 5 of
the Plan.

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1.0 INTRODUCTION
The Oil Pollution Prevention regulations, administered under the authority of the United States
Environmental Protection Agency (USEPA), require certain facilities to prepare and implement a
Spill Prevention, Control, and Countermeasure (SPCC) Plan to reduce or eliminate oil discharges
to navigable waters of the United States. SPCC Plans document regulated containers at a facility
and the inspection, testing, and maintenance procedures for those containers. The SPCC Plan
also contains information regarding emergency response actions.
This document is the SPCC Plan (or Plan) for Fort Buchanan, located near San Juan, Puerto
Rico. This Plan has been prepared in accordance with 40 CFR 112 as amended. This Plan
includes references to industry standards that apply to containers at Fort Buchanan and has been
certified by a Professional Engineer registered in the State of Georgia.
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 identified in Section 5 retain
copies of their respective sections at the facilities.

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2.0 FACILITY DESCRIPTION
2.1 GENERAL INFORMATION
Fort Buchanan was established in 1923 as Camp Buchanan on a 300-acre plot. Camp Buchanan
was used as a maneuver training area and range by the Army and National Guard until it was
expanded (to 4,500 acres) and designated Fort Buchanan in May of 1940. After World War II,
Fort Buchanan was gradually reduced in size to its present 746 acres. From 1966 to 1971, Fort
Buchanan was under the command of the U.S. Navy. In 1972, the Army resumed command and
placed the U.S. Army Garrison, Fort Buchanan under the control of U.S. Army Forces Command.
On October 1st
, 2005, Fort Buchanan began a one-year transition into the U.S. Army Reserve in
accordance with the Puerto Rico Island-Wide Garrison Concept Plan of 12 May 2004.
Fort Buchanan’s primary mission is to provide base support services to all U.S Army Reserve
units in Puerto Rico and the U.S Virgin Islands. Fort Buchanan also is a Power Support Platform
and plans, prepares, develops and executes contingency plans; supports U.S Forces operating in
the Caribbean and Central and South America; executes oversight for the Army’s Anti-Terrorism /
Force Protection program; and serves as a Base Support Installation for the conduct of Military
Support to Civil Authorities. Fort Buchanan also supports tenant activities such as the Puerto Rico
National Guard, Army Air Force Exchange Service (AAFES), Department of Defense Domestic
Dependents Elementary and Secondary Schools, and the Defense Commissary Agency, and
provides housing for Department of Defense (DoD) personnel.
Fort Buchanan is located in Guaynabo and Bayamon Counties, near San Juan, Puerto Rico, at
18° 24’ 50” North latitude; 66° 7’ 50” West longitude.
The following SPCC-regulated oils are used on Fort Buchanan:
• Gasoline
• Diesel
• Engine Oil
• Hydraulic Oil
• Lubricating Grease
• Mineral Oil
• Vegetable Oil and Grease
• Used Oils and Sludges
• Used Food Grease
These products are stored in a variety of containers including underground storage tanks (USTs),
aboveground storage tanks (ASTs), electrical operating equipment, emergency generator day
tanks, 55-gallon drums, and smaller containers. All containers that hold 55-gallons or more of
SPCC-regulated oils are considered SPCC-regulated containers with the exception of regulated
USTs, see section 2.2 below. Appendix A lists specific information for the SPCC regulated
containers at Fort Buchanan. All of the regulated containers are designed to be compatible with
the materials stored and operate at ambient temperatures and pressures. Secondary containment
structures are sufficiently impervious to the oils they are intended to contain. No containers use
internal heating coils. Fort Buchanan does not have a tank car or tank truck loading/unloading
rack, pipeline, or any field-constructed tanks. Fort Buchanan is not a large quantity generator
regulated under the Resource Conservation and Recovery Act (RCRA) and, therefore, does not
require a RCRA contingency plan. Also, there are no polychlorinated biphenyl (PCB) oil storage
containers or PCB-containing devices (transformers, ballasts, etc.) onsite. The summatory of all
the above ground oil storage capacity is approximately 156,676 gallons.

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2.2 CONTAINERS NOT COVERED BY THIS PLAN
Containers owned and operated by contractors temporarily working on Fort Buchanan property
are not covered by this Plan. Such containers may include fuel tanker trucks or ASTs temporarily
brought onto Fort Buchanan. Each contractor is responsible for determining SPCC applicability
and developing a site-specific Plan if necessary. Although not included in the SPCC Plan, related
spill response activities may still involve Fort Buchanan personnel.
USTs subject to all the technical requirements of 40 CFR 280 are exempt from all SPCC
requirements. However, they must be shown on the Containers and Drainage Map (Figure 2.1).
Fort Buchanan has 6 USTs subject to the requirements of 40 CFR 280 (see Table 2.1).
Container ID Type
Capacity
(Gallons)
Material of
Construction
Contents
546D UST 200 Steel Inner / FRP Outer Used Oil
546E UST 200 Steel Inner / FRP Outer Used Oil
546F UST 200 Steel Inner / FRP Outer Used Oil
677A UST 20,000 FRP Gasoline
677B UST 20,000 FRP Gasoline
677E UST 260 Concrete Used Oil
Table 2.1: SPCC-Exempt USTs Subject to 40 CFR 280.
There are eleven oil/water (O/W) separators on Fort Buchanan. Four O/W separators are slow
flow, gravity separation chambers used for primary treatment of industrial wastewater to remove
free oil, grease and fuel. Treated effluent discharges to the sanitary sewer system. Another treats
storm water discharges from the Puerto Rico National Guard Joint Forces Headquarters. The
collected oil is periodically removed by a contractor. DPW personnel conduct periodic inspections
and maintenance on the O/W separators to ensure proper operation. These five O/W separators
are exclusively used for wastewater treatment and are excluded from regulation by 40 CFR 112.
There are two O/W separators at the AAFES gas station. One separates oil from the maintenance
bay floor drains. Skimmed oil is stored in a separate UST (677E in Table 2.1). The other O/W
separator at the AAFES gas station is a flow-through water treatment device, but it also serves
as additional secondary containment for the pump area (see Section 5.1 for information). The
eighth O/W separator is at the golf course and is described in Section 5.4. The remaining three
O/W separators are at the National Guard Readiness Center. Each stores separated oil in a
designated UST (546E, 546F, and 546G in Table 2.1).
Amendments to 40 CFR 112 (from 26 December 2006) exempt all “motive power” containers
(such as vehicle gas tanks) from SPCC Plan requirements. DoD recommends that the
containment methods listed under 40 CFR 112.7(c) be employed as much as practicable for
vehicle gas tanks and other such tanks over the 55-gallon threshold. Spills from these types of
sources can be addressed under the description of undiked areas. Fort Buchanan operates
equipment affected by this guidance including tactical vehicles, construction vehicles, and tractor-
trailer trucks. (See Section 4.11 for more details regarding Undiked Areas).
2.3 NAVIGABLE WATERS
Most of Fort Buchanan’s drainage discharges to El Toro Creek (known as Quebrada Santa
Catalina outside of Fort Buchanan), which flows to the northwest into the Malaria Control Canal
and eventually discharges to San Juan Bay on the Atlantic Ocean. El Toro Creek is a concrete
lined ditch for much of its path through Fort Buchanan. The town of Tintillo in Guaynabo County,

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where Quebrada Santa Catalina originates, discharges municipal storm water to El Toro Creek
upstream of the southern forested area of Fort Buchanan. The northeastern portion of Fort
Buchanan (the 600-area) drains via ditches directly to the Malaria Control Canal. An industrial
park located off-post, just south of the 600-area also discharges via the same drainage ditches,
upstream of the Fort Buchanan discharges. Fort Buchanan owns a small man-made lake that was
acquired in 2018. A small area occupied by Building 379 and the back of the Middle School drains
to Las Casas Lake, which has a flood-control overflow, via the Fort Buchanan storm water piping
system, to El Toro Creek. The farthest eastern portion of Fort Buchanan, including about half of
the Golf Course, drains via Rio Puerto Nuevo into San Juan Bay on the Atlantic Ocean. See Fort
Buchanan Overview Map, Figure 2.2 for details.

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Figure 2.1: Fort Buchanan Site Map.

Page 6
Figure 2.2: Fort Buchanan Overview and Drainage Map.

Page 7
Figure 2.3: Fort Buchanan Transformers.

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3.0 APPLICABILITY DETERMINATION
According to 40 CFR 112.1, Fort Buchanan requires an SPCC Plan. The facility-wide
aboveground oil storage capacity totals more than 1,320 gallons, and oil discharges could reach
navigable waters.
AR 200-1, chapter 11, paragraph 11-4b(2) states, “Ensure that the SPCC Plan addresses
secondary containment (or lack thereof) at oil and hazardous material storage facilities.” This Plan
includes identification of hazardous materials storage sites.
40 CFR 112.20(e) requires that affected facilities determine their potential to cause substantial
harm and file a Facility Response Plan with the EPA Regional Administrator, if necessary. Figure
3.1 shows the Flowchart of Criteria for Substantial Harm from Attachment C-1, Appendix C, 40
CFR 112. This flowchart asks several questions regarding facility processes and storage capacity.
As required by 40 CFR 112.20(e), the Certification of the Applicability of the Substantial Harm
Criteria is included in Appendix B of this Plan. Fort Buchanan has less than one million gallons of
oil storage capacity and does not transfer oil over water to/from vessels and does not pose a
threat of substantial harm to fish and wildlife, a sensitive environment, or a drinking water intake.
Therefore, a Facility Response Plan is not required.

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Figure 3.1: Substantial Harm Criteria Flowchart.
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

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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 Division personnel can review the Plan and sign
the revision tracking form on page v.
This Plan must also be updated whenever there is a change in the facility design, construction,
operation, or maintenance that materially affects its discharge potential. These types of changes
include, but are not limited to, commissioning or decommissioning containers; replacement,
reconstruction, or movement of containers; reconstruction, replacement, or installation of piping
systems; construction or demolition that might alter secondary containment structures; changes
of product or service; or revision of standard operation or maintenance procedures. Movement of
containers within an area that does not increase either the likelihood or the potential severity of a
discharge would not require an update to the Plan.
Required Plan amendments must be prepared within six months of the change in operation, and
implemented as soon as possible, but not later than six months following preparation of the
amendment. The revisions page at the beginning of this Plan must be updated to include all
technical and non-technical changes to the Plan.
A report must be submitted to the US EPA Regional Administrator only if Fort Buchanan has:
• Discharged more than 1,000 gallons of oil in a single discharge or
• Discharged more than 42 gallons of oil in each of two discharges, occurring within
any twelve-month period.
40 CFR 112.4(a) lists the information that must be submitted to the USEPA Regional
Administrator no more than 60 days from the date of the discharge that required the submittal.
This required information is also presented in Appendix C. The Regional Administrator may also
require that the SPCC Plan be submitted for review.
4.2 CONFORMANCE WITH FEDERAL, ARMY, AND COMMONWEALTH OF PUERTO
RICO REGULATIONS
The main purpose of this Plan is to comply with the requirements of 40 CFR 112. However, Army
Regulation (AR) 200-1, chapter 11, paragraph 11-4b(2) states, “Ensure that the SPCC Plan
addresses secondary containment (or lack thereof) at oil and hazardous material storage
facilities.” So, this Plan also includes hazardous material storage sites. The Puerto Rico
Emergency Response Commission indicates that there are no local or Commonwealth of Puerto
Rico requirements more stringent than the Federal requirements in regard to SPCC Plans.
4.3 PERSONNEL TRAINING
As required by 40 CFR 112.7(f)(1 and 3), oil handling personnel are trained to prevent discharges.
Fort Buchanan conducts SPCC Plan training on an annual basis for all oil-handling personnel.
This training includes a review of this SPCC Plan, applicable pollution control laws, spill response
procedures, inspection and recordkeeping requirements, and the spill history for Fort Buchanan.
Personnel also receive specific training in petroleum product handling procedures and equipment

Page 11
maintenance and operation. Fort Buchanan Directorate of Logistics (DOL) personnel responsible
for fuel transfers receive additional training commensurate with their specific job requirements.
The additional training may include:
• Occupational Safety and Health Administration (OSHA) Hazardous Waste
Operations and Emergency Response (29 CFR 1910.120),
• OSHA Hazard Communication Standard (29 CFR 1910.1200),
• OSHA Process Safety Standard (29 CFR 1910.119),
• Resource Conservation and Recovery Act (RCRA) Personnel Training (40 CFR
265.16),
• RCRA Waste Handling / Emergency Procedures (40 CFR 262.17(a)(7), and
• Department of Transportation Hazardous Materials Training (49 CFR 172,
Subpart H).
Records of training for the Hazardous Materials Handlers Course are maintained by the
Directorate of Planning, Training, Mobilization, & Security. Records of additional training are
maintained by individual units or activities.
4.4 SECURITY
Fort Buchanan is a fenced military installation. Access requires positive identification, and all
vehicles are subject to random searches. This level of security helps ensure that oil storage areas
are only accessed by authorized personnel. In addition, military police conduct roving patrols
throughout the installation. All pump starter controls are locked off when not in use and are only
accessible to authorized personnel. Outdoor fuel dispensers are disabled after operating hours.
All container areas have adequate facility lighting.
4.5 RECORDKEEPING
DPW Environmental Division 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
Division also maintains inspection and testing records for certified inspections for the life of the
container. General inspection and testing procedures for containers are described in more detail
in Sections 4.8 and 4.9. Exceptions to the general procedures are identified in individual container
area descriptions in Section 5 of this Plan.
4.6 SPILL HISTORY
The Fort Buchanan spill history is maintained by DPW Environmental Division 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. A spill log
is provided in Appendix K.
4.7 SPILL RESPONSE
If a spill occurs, installation personnel follow the response, reporting, and cleanup procedures
appropriate to the level of spill. Personnel, if properly trained and equipped to do so safely, will
promptly correct and cleanup (using available absorbents or spill kits) any visible POL discharges
less than 5 gallons which are still on an impervious surface. All POL spills of any size that contact
the ground or surface water, POL spills greater than 5 gallons, or any size spills of a hazardous
material (even on impervious surfaces) are called in to the Fort Buchanan Fire Department
immediately. Table 4.1 indicates the response for various spills. The Fort Buchanan Fire
Department is the primary spill responder and can be reached on any installation phone at 4911
or 5911.

Page 12
Spill reporting may include notifications to the National Response Center (NRC), the Puerto Rico
Department of Natural and Environmental Resources (PRDNER), the Puerto Rico Emergency
Response Commission, and Installation Management Command - Southeast (IMCOM-SE). The
USEPA 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 Division is responsible for all reporting to external agencies.
For Fort Buchanan, this means that the NRC must be called if an oil spill reaches El Toro Creek,
the Malaria Control Canal, Rio Puerto Nuevo, or their tributaries as shown on Figures 2.2.
Hazardous materials used at Fort Buchanan are listed in Appendix I. Their reportable quantities
(RQs) and largest container sizes are also listed. Only sodium hypochlorite solution (used for
drinking water disinfection at the golf course wellhouse) is stored in a large enough container to
potentially require reporting. It should be noted that there are also some hazardous materials that
may not have RQs established, and spills below the RQ for some hazardous materials could still
cause harm to the environment if spilled.
Spill Volume Response Reporting
Hazardous Material
Less than RQ or still on
impervious surface within
containment
Fort Buchanan Fire
Department
DPW Environmental Division
Hazardous Material
Greater than RQ that leaves
containment
Fort Buchanan Fire
Department
NRC, Puerto Rico PRDNER,
Puerto Rico Emergency
Response Commission,
IMCOM-SE,
Less than 5 gallons of POL
contained on impervious
surface
Onsite Personnel None
Greater than 5 gallons of POL
contained on impervious
surface
Onsite Personnel and/or
Fort Buchanan Fire
Department
Any amount of POL that
reaches ground surface
Fort Buchanan Fire
Department
Any amount of POL that
reaches a navigable water
Fort Buchanan Fire
Department
Greater than 25 gallons of
POL in a single event
Fort Buchanan Fire
Department
Table 4.1: Spill Response and Reporting Procedures.
Agency Phone
National Response Center (800) 424-8802
PRDNER (787) 767-8181 or (787) 724-0124
Puerto Rico Emergency Response Commission (787) 767-8056 or (787) 751-6274
Commonwealth of Puerto Rico Fire Department (787) 722-1120
IMCOM-SE (404) 464-0709
Fort Buchanan Fire Department 4911 or 5911
Fort Buchanan DPW Environmental Division (787) 707-3575/3522
Table 4.2: Spill Reporting Agencies.

Page 13
The information in Table 4.3 should be reported after a spill. Spill response equipment is
maintained throughout the installation, including the DPW complex (Building 37), AAFES gas
station (Building 677), the U.S. Army Reserve Organizational Maintenance Shop (OMS) (Building
528), the Golf Course (Building 138), the Auto Hobby Shop (Building 159), tanker truck 613, AFRC
Motor Pool (Building 615), the Logistics Readiness Center Fuel Station (Building 613), the
Quartermaster OMS (Building 609), the National Guard Readiness Center (Buildings 540 – 552)
and the Antilles Elementary School (Building 700) and Child/Youth Service Facility (Building 1110)

Page 14
SPILL REPORT #
FORT BUCHANAN
HAZARDOUS MATERIALS SPILL REPORT
DATE: TIME: INCIDENT LOCATION:
I. GENERAL INFORMATION:
1. Person Notifying Emergency Spill:
2. Person Notifying to DPW Environmental Division:
3. Substance Type:
4. Spill Quantity:
5. Type:
II. SITE DESCRIPTION:
1. Contained:
2. Water Involved:
3. Waterway:
4. Drinking Water Impacted:
5. Substance Usage:
III. EMERGENCY PROCEDURES:
1. Engineering Controls:
2. Affected Natural Resources:
3. Affected Human Resources:

Page 15
Table 4.3: Spill Reporting Information.
The Fort Buchanan Fire Department response truck contains sufficient materials to respond to,
safely contain, and completely clean-up a spill of 300 gallons. There are enough fully
encapsulating protective suits for an entire shift (5 Fort Buchanan Firefighters) to don
simultaneously. Two overpack drums and side cabinets and boxes contain oil absorbent booms,
sheets, pads, and socks. Decontamination equipment includes a free standing safety shower, a
manual ring shower, and an inflatable decontamination tent with associated brushes, hoses,
pumps, and connections. The hazmat trailer, which is not attached to the response truck, has
approximately double the amount of response equipment. Together they are adequate for spills
of 1,000 gallons. For larger spills, the DPW Operations and Maintenance (O&M) Division has
approximately one pallet of oil absorbent compound as well as tools (shovels, rakes, picks, etc.)
and earthmoving equipment (bulldozers, backhoes, excavators, etc.). Oil spill response
organizations (OSROs) can also be contracted if there is a large amount of cleanup required. The
decision to call in OSROs would be made by the incident commander (the senior Fort Buchanan
Fire department officer on-scene). Funding mechanisms (approval, contracting, accounting, etc.)
need to be set up to allow for potential emergency use (see Appendix J for OSRO contacts).
Recovered oils are managed as used oil if they can be separated in liquid form. Recovered oils
that are mixed with soil are managed as non-hazardous regulated waste and as hazardous waste
if contaminated with other chemicals (complex mixtures, unknowns, highly flammables, etc.). The
Commonwealth of Puerto Rico Fire Department (CPRFD) can be called to assist with complex or
burning spills (See Appendix D for details regarding the mutual aid agreement with the CPRFD).
4.8 INSPECTION AND TESTING
Inspection and testing of tanks are 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
IV. FINDINGS AND ASSESSMENTS
1.
V. ADDITIONAL INFORMATION:
1. Waste Generated:
2. Expected:
3. Oversight:
VI. RECOMMENDATIONS
1.
2021 SEPTEMBER, SEMS REV, RL #73

Page 16
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 examine the piping more fully. 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.
Inspection/Test Standard Method Frequency
Presence of water in primary tank
STI SP001-05,
Appendix C
Sampling Monthly
Presence of water, oil, or debris in
secondary containment
STI SP001-05,
Appendix C
Manual Monthly
Operation of leak detection system
STI SP001-05,
Appendix C
Manual Monthly
Piping connections and openings
properly sealed
STI SP001-05,
Appendix C
Visual Monthly
Drain valves operable and in closed
position
STI SP001-05,
Appendix C
Visual Monthly
Operation of liquid level sensor
STI SP001-05,
Appendix C
Manual Monthly
Visible signs of leakage, corrosion, or
damage
STI SP001-05,
App C and API
570, App D
Visual Monthly
Exterior and coating
deterioration/corrosion/distortion
STI SP001-05,
Appendix C
Visual Yearly
Operation and cleanliness of
operating and emergency vents
STI SP001-05,
Appendix C
Visual Yearly
Emergency vent gasket
STI SP001-05,
Appendix C
Visual Yearly
Proper drainage around tank
STI SP001-05,
Appendix C
Visual Yearly
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

Page 17
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
Table 4.4: AST and Piping Inspection and Testing.
4.9 MOBILE AND PORTABLE CONTAINER POLICY
Fort Buchanan is implementing this policy to manage oils and fuels stored in drums, portable
containers, and mobile containers with POL storage capacity between 55-gallons and 6,000
gallons. Portable containers are typically mounted on skids or saddles and may remain in place
for an extended period of time; 55-gallon drums are also considered portable containers. Mobile
containers are mounted to frames with wheels. Examples of mobile containers include fuel pods,
mobile generator fuel tanks, and tanker trucks. Personnel frequently move these containers or
alter the number of containers in a particular area. For this reason, the exact location of each
drum, portable container, or mobile container is not included in this Plan. However, the areas that
are commonly used for storage of drums or other mobile and portable containers (and the
maximum allowable volume of POL products stored in those areas) are identified in this Plan.
These areas are most commonly used to store mobile or portable containers, two of which
frequently vary in quantity and type. The Logistics Readiness Center (LRC) Fuel Station maintains
a 3,300 gallons capacity fuel truck used for filling generations and other diesel ASTs located on
base and is usually parked in the concrete diked area near building 613. This location also has
three (3) 6,000 gallons tankers stored on site, each parked within a collapsible POL container
dike (see photo log, Appendix M).
The DPW storage yard near Building 37 contains various POL containers such as generators,
transformers or other portable containers set for future installation or disposal (see photo log,
Appendix M). The US Army Reserve OMS shop (Building 528) also has a storage yard with
various portable containers including generators, a tanker truck (2,500-gallon capacity), and other
small equipment used for deployment, as-needed. The tanker is parked within a collapsible POL
containment dike (see photo log, Appendix M).
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 G.
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

Page 18
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
Table 4.5: Mobile and Portable Container Inspections and Testing.
Records of external inspections are maintained for at least three years. Records of integrity tests
shall be maintained for the life of the container. Fort Buchanan does not intend to keep any drums
beyond the DOT recertification test period. Personnel will track the container's age if a
mobile/portable tank or drum is to be used for more than the DOT recertification test period (see
Table 4.5).
4.10 RAINWATER INSPECTION IN DIKED AREAS
Some containers are surrounded by secondary containment dikes. Installation personnel drain
rainwater from these diked areas through locked, manually activated valves. Prior to release,
personnel verify that an oil sheen is not present on the surface of the collected rainwater. If a
sheen is present, personnel take appropriate action for reporting and cleanup. Site personnel also
maintain a drain log recording the date and volume of rainwater that is released from the diked
areas.
4.11 UNDIKED AREAS
The SPCC regulations in 40 CFR 112.8(b) require facilities to prevent potential discharges from
undiked areas by designing drainage systems that flow into catchment basins or lagoons. This
does not apply to Fort Buchanan. The limited potential for spills outside of typical fuel handling
areas does not warrant a complete redesign of the existing drainage system. Fort Buchanan’s
spill response capabilities as described in Section 4.7, proper personnel training as described in
Section 4.3, and periodic inspections as described in Sections 4.8 and 4.9 should be adequate to
prevent and contain discharges associated with typical failure mode (most likely to be a small drip
or leaks from small bore suction piping that only contains oil when an emergency generator is
activated) from undiked areas. A spill kit with absorbents would be able to contain and clean up
this quantity of oil. This qualifies as equivalent Environmental protection (as allowed under 40
CFR 112.7(a)(2)).
Fuel tanks (greater than 55 gallons) on some larger equipment are exempt from SPCC plan
requirements because they are considered “motive power containers”. Spills from these

Page 19
containers may occur in undiked areas. Spill response will follow the procedures outlined in
Section 4.7.
4.12 NEW CONSTRUCTION
Any new construction will comply with the applicable requirements of 40 CFR 112.8(d). New
buried metallic piping will either have a protective coating or cathodic protection. In the event that
piping is exposed during an excavation, the pipe will be inspected for corrosion and repaired or
replaced as necessary.
4.13 GENERAL PRODUCT HANDLING
Installation personnel follow standard operating procedures for product handling as listed in
applicable military standards. These procedures are outlined in the Fort Buchanan DPW Policy
Memorandum DPW 2, Subject: POL Products/Diesel Fuel Management Practices, attached as
Appendix F. This document establishes policy and administrative procedures for fuel operations,
specifies duties for fuel management personnel, provides guidelines and procedures for operating
storage tanks, and outlines responsibilities for operation and maintenance of storage and
dispensing equipment. Installation personnel follow the procedures specified in this document for
all product handling activities.
In general, personnel follow the spill prevention procedures below when transferring product to or
from a tanker truck:
• Load or unload in approved locations only
• Establish communications between the pumping and receiving stations
• Verify the available volume of the receiving container
• Properly close all drainage valves for any secondary containment
• Allow sufficient volume (approximately 10% of the total capacity) in the receiving
container for thermal expansion
• Visually inspect all valves for leakage when transfer is complete

Page 20
5.0 CONTAINER AREAS
This section of the Plan provides details about SPCC-regulated containers in each area. An area
typically encompasses all the containers owned and maintained by a single shop or functional
unit. Transformers, generators, and grease drums have been grouped as “areas” because of their
common contents and procedures. All SPCC-regulated containers, regardless of container area,
are in the consolidated table in Appendix A. Fort Buchanan has the following container areas:
• AAFES Gas Station
• Auto Hobby Shop
• Aqua Park
• Golf Course
• U.S. Army Reserve OMS
• DPW Complex
• Logistics Readiness Center (LRC) Fuel Station
• School Bus Storage Area and DODEA
• AFRC Motor Pool
• Quartermaster OMS
• National Guard Readiness Center
• Antilles Elementary School and Child/Youth Service Facility
The term “visual” is used in tables throughout Section 5 to describe a method of overfill prevention
wherein the person filling a container can see the level of product in the container while it is being
filled and can immediately shut off inflow upon reaching 90% of container capacity (40 CFR
112.8(8)(iii-iv). The following is a list of dispersed SPCC-regulated containers:
• Emergency Generators
• Oil Filled Operational Equipment (OFOE) Electrical Transformers
• Food Grease Containers
• OFOE Hydraulics
5.1 AAFES GAS STATION (BUILDING 677)
5.1.1 AREA DESCRIPTION
The AAFES Gas Station is a self-service gas station with 16 pumps for unleaded regular and
premium gasoline. Customers pump gas into personally owned vehicles from two USTs (677A
and B). No tactical vehicles are serviced or fueled at this site. The pumping area is a concrete
slab with overhead protection. There is also a maintenance area with two maintenance bays (oil
and tire changes only). One AST (677C) is used to store used oil outside the maintenance bay.
An emergency generator with an inherent diesel tank (677D) is located beside the storage area
(see Section 5.13 for more information on emergency generators). Other hazardous materials
and POL products are stored inside the building (pallets of quart containers of oil), flammable
lockers, and the maintenance bays. There are two O/W separators, one for the floor drains in the
maintenance bays and another for the pump area. The floor drain O/W separator includes a UST
(677E) that stores oil separately from the O/W separator. The pump area O/W separator is a flow
through wastewater treatment device that would provide some containment in the case of a spill.
Table 5.1.1 provides container details, and Figure 5.1.1 shows their locations.

Page 21
Container ID Type
Capacity
(Gallons)
Material of
Construction
Product Stored
677A UST 20,000
Fiberglass
Reinforced
Plastic (FRP)
Gasoline
677B UST 20,000 FRP Gasoline
677C AST, Vertical 250 Steel Used Oil
677D AST, Horizontal 322 Steel Diesel
677E UST 260 Concrete Used Oil
Table 5.1.1: AAFES Gas Station Containers.

Page 22
Figure 5.1.1: AAFES Gas Station (Building 677).

Page 23
5.1.2 PRODUCT HANDLING
Tanker trucks of up to 10,000-gallon capacity deliver gasoline to the station. AAFES personnel
follow the truck unloading procedures described in Section 4.13. USTs (677A and 677B) have
automatic tank gauges (ATGs) with alarms and automatic pump shutoff. Each underground tank
has a separate spill catchment basin and both tanks have underground piping to the dispensers.
Customers use common commercial fueling station dispensers when fueling their vehicles. An
emergency stop button and spill response materials are available near the pumps. Mechanics fill
tank 677C by using oil pans to hand-pour the oil drained from vehicles. The used oil is removed
from tank 677C by a vacuum truck and then recycled. The generator tank (677D) is filled by the
DOL fuel truck. UST 677E is filled by gravity skimming of oil from the maintenance bay O/W
separator. Oil and water are removed by a vacuum truck. Table 5.1.2 provides more details
regarding product handling activities for this area.
Container ID Loading Method Overfill Protection Unloading Method
677A (UST) Truck ATG Dispensed to customers
677B (UST) Truck ATG Dispensed to customers
677C Manual Visual Vacuum Truck
677D Truck Visual Used in generator
677E (UST)
From O/W
Separator
NA Vacuum Truck
Table 5.1.2: AAFES Gas Station Product Handling.
5.1.3 SECONDARY CONTAINMENT
Tanks 677A, 677B, and 677E are subject to all the technical requirements of 40 CFR 280 and are
therefore exempt from any secondary containment requirements imposed by the SPCC rule.
A spill in the pumping area would flow to an O/W separator prior to discharge. See Appendix E
for volume calculations. Fueling station personnel maintain spill kits near the fueling area for
additional spill control. Tanks 677C and 677D are double-walled. Neither double-walled tank
collects storm water.
Container ID Type Storm Water Release
Pump Area OWS NA
677C Double-walled NA
677D
Double-walled, Sub-Base
Double Wall, AST
NA
Table 5.1.3: AAFES Gas Station Secondary Containment.
5.1.4 INSPECTION AND TESTING
This Plan does not restate the inspection and testing requirements for tanks 677A, 677B, and
677E imposed by 40 CFR 280. AAFES personnel reconcile product inventory by maintaining daily
records of fuel dispensed and received. DPW Environmental Division personnel maintain records
of all AST inspections for at least three years as required by 40 CFR 112.7(e). Section 4.8
establishes the Fort Buchanan policy for the integrity testing of shop-built containers (and piping)
with less than 5,000 gallons capacity.

Page 24
5.1.5 POTENTIAL SPILL SCENARIOS
The loss of the entire contents of a commercial tanker truck could spill 10,000 gallons onto the
concrete pad in front of the USTs. Customer filling errors could cause a spill of 25 gallons. The
truck that removes used oil has a 2,000-gallon capacity. Complete failure of an AST could result
in a spill of 322 gallons. Any spill would flow into a storm water inlet and then by pipe, west to El
Toro Creek (see Figures 5.1.1, 2.1, and 2.2). A spill in this area would trigger the spill response
procedures listed in Section 4.7.
Container ID
Spill Amount
(Gallons)
Contents Cause Pathway
Pump Area 25 Gasoline Customer Error
Storm water inlet
to O/W separator
then west to El
Toro Creek
677A(UST) and
677B(UST)
10,000 Gasoline Delivery Truck Error
Storm water inlet
west to El Toro
Creek
677C (AST)
250
Used Oil
Container Failure
Storm water inlet
west to El Toro
Creek
2,000 Collection Truck Error
677D (AST)
322
Diesel
Container Failure
3,300 Delivery Truck Error
677E (UST) 2,000 Used Oil Collection Truck Error
Table 5.1.4: AAFES Gas Station Potential Spill Scenarios.
5.2 AUTO HOBBY SHOP (BUILDING 159)
The Auto Hobby Shop is used by military personnel and civilians to work on their POVs with
specialized tools. A 500-gallon AST (159) is used to collect used oil. This AST was moved from
its former location at the old AAFES gas station where it was labeled AST386A. An underground
O/W separator removes oil from water discharged through the trench floor drains in the
maintenance bays. Used antifreeze is collected in drums in the maintenance bays. Other
hazardous materials and POL products (such as parts cleaning solvents, oil, and antifreeze) are
stored in smaller containers (less than 55-gallons) in the maintenance bays. Table 5.2.1 provides
container details, and Figure 5.2.1 shows their locations.
Container ID Type
Capacity
(Gallons)
Material of
Construction
Product Stored
159 Vertical AST 500 Steel Used Oil
159DRA 55-Gallon Drum 55 Steel Used Oil
159DRB 55-Gallon Drum 55 Steel Used Antifreeze
Does not contain oil, not regulated by 40 CFR 112
Table 5.2.1: Auto Hobby Shop Containers.

Page 25
Patrons and/or mechanics of the Auto Hobby Shop drain used oil and antifreeze from their
vehicles into drip pans and then hand carry the drip pans to a used oil or antifreeze drum inside
the maintenance bay. The used oil drum transfers the oil via a small electric pump to the AST.
Only mechanics pump the oil into the tank. The amount of oil in the tank is checked prior to every
transfer to ensure that there is enough capacity to hold the amount to be transferred (55 gallons).
The used antifreeze drums are removed when full. Table 5.2.2 provides product handling details.
159 Electric Pump Sight Gauge Vacuum Truck
159DRA Manual Visual Electric Pump
159DRB Manual Visual NA
Table 5.2.2: Auto Hobby Shop Product Handling.

Page 26
Figure 5.2.1: Auto Hobby Shop (Building 159) and Bowling Center (Building 168).

Page 27
The AST is a double-walled steel tank. The drums are inside the building but are near the
doorways, so they do not have adequate secondary containment. The drums require secondary
containment (See Section 6.0, Corrective Actions).
The piping only contains oil when the pump is turned on. General containment [40 CFR 112.7(c)]
is achieved by active deployment of absorbent materials and shutting off the pump if a leak occurs.
Shop personnel monitor the pump when it is turned on.
159 Double-walled NA
159DRA None NA
159DRB None NA
Table 5.2.3: Auto Hobby Shop Secondary Containment.
Records of monthly visual inspections and overfill protection system tests are maintained by area
personnel for at least three years. Sections 4.8 and 4.9 establish the Fort Buchanan policies for
the integrity testing of shop-built containers (and piping) less than 5,000 gallons capacity and
portable containers.
Complete container failure of AST 159 could result in a spill of up to 500 gallons of used oil. It is
assumed that only one drum would spill in a given event. The loss of the entire contents of the
collection tanker truck could spill 2,000 gallons of used oil. Any spill from this area would flow
across the parking lot to a storm water inlet and then open concrete drainage west to El Toro
Creek (see Figures 5.2.1, 2.1, and 2.2). A spill in this area would trigger the spill response
Container
ID
Spill Amount
(Gallons)
159
500
Used Oil
Container Failure
Storm water inlet
then concrete
drainage west to El
Toro Creek
159DRA
55
Used Oil
Container Failure
5 Transfer Error
159DRB
55
Used
Antifreeze
Container Failure Storm water inlet
then concrete
drainage west to El
Toro Creek
5 Transfer Error
- Does not contain oil, not regulated by 40 CFR 112
Table 5.2.4: Auto Hobby Shop Potential Spill Scenarios.

Page 28
5.3 AQUA PARK (BUILDING 161)
The Aqua Park is a recreation area with outdoor pools and waterslides. There is no oil storage at
this site, and therefore 40 CFR 112 does not apply; however, AR 200-1 requires Army spill plans
to address hazardous materials. Pool water treatment chemicals stored beside Building 161 are
added automatically through a computerized pumping system. Tank 161B is a 55-gallon drum of
hydrochloric acid (for pH adjustment); and up to three back-up drums may also be present. The
drums are stored in a corrosive resistant plastic secondary containment shell. Table 5.3.1
provides container details, and Figure 5.3.1 shows the location.
Container ID Type
Capacity
(Gallons)
Material of
Construction
Product Stored
161B 55-Gallon Drums
55
(up to 4)
Polyethylene
Hydrochloric
Acid
Table 5.3.1: Aqua Park Containers.
The drums that make up tank 161B are not filled onsite. New drums are purchased and placed in
the containment shell. Table 5.3.2 provides more details regarding product handling activities for
this area.
161B NA NA (drum) Consumed in water treatment
Table 5.3.2: Aqua Park Product Handling.
Tank 161B is a corrosive resistant plastic containment shell. Although not regulated by 40 CFR
112, secondary containment for the acid drums is provided.
161B Plastic Containment Shell NA
Table 5.3.3: Aqua Park Secondary Containment.

Page 29
Figure 5.3.1: Aqua Park (Building 161).

Page 30
Records of monthly visual inspections are maintained for at least three years. Tank 161B is not
made of steel and does not contain oil; therefore, it is not subject to STI Standard SP001-05. An
approximately equivalent inspection and testing schedule is followed instead. Note that the
bottoms of the drums in 161B should be inspected during the monthly visual inspection because
they can be moved easily. The inspection and testing requirements for the containers are shown
in Table 5.3.4.
Container ID Inspection/Test Method Frequency
161B External Condition and Leak Check Visual Monthly
161B
Hydrostatic Test, Mass or Level
Measurement, Pressure Decay, etc.
Measurement 7 Years^
^ -This testing is required only if the same drum has been used for 7 years.
Table 5.3.4: Aqua Park Inspection and Testing.
It is assumed that only one of the drums of acid would spill in a given event. Complete failure of
one drum at 61B could result in a spill of 55 gallons of hydrochloric acid. There is not enough
hydrochloric acid stored at this location to exceed the reportable quantity. Any spill from this area
would flow along the storm ditches to El Toro Creek (see Figures 5.3.1, 2.1, and 2.2) and trigger
the spill response procedures in Section 4.7.
Container
ID
Spill Amount
(Gallons)
161B 55
Hydrochloric
Acid
Container Failure
Across grass to concrete
drainage west to El Toro
Creek
Table 5.3.5: Aqua Park Potential Spill Scenarios.
5.4 GOLF COURSE (BUILDING 172)
The golf course has a used food grease tank from the snack bar (172UFG), an emergency
generator for a sewage pump station (163), an interior pesticide storage and mixing area
(138PDR), and an O/W separator treatment system (138O/W) for wash water and storm water
runoff from the pesticide area. The sewage pump station is owned by the Puerto Rico Aqueduct
and Sewer Authority (PRASA). However, the emergency generator for the pump station, and its
associated AST, are owned and operated by Fort Buchanan (see Sections 5.13 and 5.15 for more
information on emergency generators and food grease drums, respectively). There is also a
drinking water well located at the driving range of the golf course with an emergency generator
and a sodium hypochlorite tank for disinfection. The pesticide drum and the sodium hypochlorite
tank do not contain oil and are not regulated by 40 CFR 112; they are regulated by AR 200-1, and
40 CFR 262. Table 5.4.1 provides container details, and Figure 5.4.1 shows their locations.
Container ID Type
Capacity
(Gallons)
Material of
Construction
Product Stored
172DR AST 200 Steel Used Food Grease

Page 31
Container ID Type
Capacity
(Gallons)
Material of
Construction
Product Stored
163 AST 250 Steel Diesel
138DR 55-Gallon Drum 55 Steel Used Oil
138PDR 55-Gallon Drum 55 Plastic
Monosodium Acid
Methanearsonate
(Herbicide)
138O/W
OWS,
3 Vertical Tanks
1,500 total
(500 each)
Plastic Oily Water
Wellhouse
127
AST 492 Steel Diesel
Wellhouse
127
AST 500 Plastic
Sodium
Hypochlorite
Table 5.4.1: Golf Course Containers.

Page 32
Figure 5.4.1: Golf Course (Building 172).

Page 33
The emergency generator tanks are filled by DOL personnel from a fuel delivery truck. The sodium
hypochlorite tank is filled by pumping from drums. The pesticide drums are not filled onsite but
are purchased new and transported full. The used oil drum is filled by pouring from small
containers. The grease tank at the snack bar is filled by employees with a pump. A vacuum truck
pumps out the tank when filled. The O/W separator is filled by the wash rack discharge and storm
water collecting in the wash area. The O/W separator does not collect oil separately; the water is
treated biologically and discharged to the sanitary sewer. Table 5.4.2 provides more details
regarding product handling activities for this area.
172UFG Electric Pump Sight Vacuum Truck
163 Truck Sight Gauge Used in Generator
138DR Manual Visual Vacuum Truck
138PDR NA NA
Mixed with water and
sprayed on golf course
138O/W
Wash Water and
Storm Water
NA
Discharges to Sanitary
Sewer
Wellhouse 127 Truck Sight Gauge Used in Generator
Wellhouse 127 Electric Pump Sight Used in Water Treatment
Table 5.4.2: Golf Course Product Handling.
The tank connected to the wellhouse emergency generator (AST 127) is double walled. The
sewage pump station tank (AST 163) is a single-walled steel tank with a concrete secondary
containment dike. The rainwater release valve needs to be repaired or replaced to comply with
40 CFR 112.8(c)(3) (See Section 6.0, Corrective Actions). The O/W separator tanks also have a
concrete dike. The pesticide drums are stored inside the building and do not collect storm water.
The used oil drum is stored on a 75-gallon containment pallet. The used food grease tank is
double walled. Appendix E contains the volume calculations for diked areas. Personnel follow the
rainwater release procedures in Section 4.10 prior to any release from the diked areas.
172DR Double walled NA
163 Single-walled, Concrete Containment Manual
138DR Plastic Containment Pallet NA
138PDR Within Building NA
138O/W Concrete Containment Manual
Wellhouse 127 Double-walled NA
Wellhouse 127 Double-walled NA
Table 5.4.3: Golf Course Secondary Containment.
Records of monthly visual inspections and overfill protection system tests are maintained by Golf
Course personnel for at least three years. Section 4.8 establishes the Fort Buchanan policy for

Page 34
the integrity testing of shop-built containers (and piping) less than 5,000 gallons capacity. Section
4.9 contains test methods for drums.
Complete failure of AST 172 or 163 could result in a spill of 275 or 250 gallons of diesel,
respectively. The loss of the entire contents of the delivery tanker truck could spill 2,000 gallons
of diesel. The used food grease vacuum collection truck could spill 2,000 gallons. It is assumed
that only one drum would spill in a given event. The O/W separator could drain two of its three
tanks in a spill since they are manifolded together. Any spill from this area would flow along the
storm ditches east to Rio Puerto Nuevo (see Figures 5.4.1, 2.1, and 2.2). A spill in this area would
trigger the spill response procedures in Section 4.7.
Container
ID
Spill Amount
(Gallons)
172UFG
200
Used Food
Grease
Container Failure
Across grass to
concrete drainage to
ditch east to Rio
Puerto Nuevo
2,000
Collection Truck
Error
163
210
Diesel
Container Failure
138DR
55
Used Oil
Container Failure
Ditch east to Rio
Puerto Nuevo
2,000
Collection Truck
Error
138PDR 55 Pesticides Container Failure
Ditch east to Rio
Puerto Nuevo
138O/W 1,500 Oily Water Container Failure
Ditch east to Rio
Puerto Nuevo
Wellhouse
127
492
Diesel
Container Failure
Across grass to ditch
east to Rio Puerto
Nuevo
Wellhouse
127
500 Sodium
Hypochlorite
Container Failure
55 Transfer Error
Table 5.4.4: Golf Course Potential Spill Scenarios.

Page 35
5.5 U.S. ARMY RESERVE ORGANIZATIONAL MAINTENANCE SHOP (OMS) (BUILDING
528)
The 1st
Mission Support Command (1st
MSC) operates the OMS as a central area to store and
maintain tactical vehicles and supplies for the U.S. Army Reserve in Puerto Rico. POL and
antifreeze are stored outside in a covered concrete secondary containment area (528DR), with
space for up to sixteen 55-gallon drums. Used oil is stored in two double-walled ASTs (528A and
B) outside of the maintenance bays. There is also a drum for collecting used antifreeze inside the
building. Tactical vehicles are refueled in the parking area by the DOL fuel delivery truck (see
Logistic Readiness Center (LRC) Fuel Station, Section 5.7). Table 5.5.1 provides container
details, and Figure 5.5.1 shows their locations.
Container ID Type
Capacity
(Gallons)
Material of
Construction
Product Stored
528A AST, Vertical 132 Steel Used Oil
528B AST, Vertical 132 Steel Used Oil
528DRA 55-Gallon Drums
55
(up to 5)
Steel
Oil, Hydraulic
Oil, Grease
Antifreeze
528DRB 55-Gallon Drums
55
(up to 2)
Steel Used Antifreeze
528DRC 55-Gallon Drums
55
(up to 5)
Steel
Oil, Hydraulic
Oil, Grease
Antifreeze
528DRD 55-Gallon Drums
55
(up to 20)
Steel
Oil, Hydraulic
Oil, Grease
Antifreeze
Table 5.5.1: U.S. Army Reserve OMS Containers.

Page 36
Figure 5.5.1: U.S. Army Reserve OMS (Building 528).

Page 37
Mechanics drain vehicle oil by hand into sinks that then transfer it to tanks 528A and 528B via
electric pump. The used oil is removed by a vacuum truck for recycling. POL and antifreeze drums
are ordered and delivered full on a flatbed truck. Used antifreeze is poured into a drum. Tactical
vehicles are refueled by the DOL fuel truck. Table 5.5.2 provides more details regarding product
handling activities.
528A Electric Pump Sight Gauge Vacuum Truck
528B Electric Pump Sight Gauge Vacuum Truck
528DRA NA NA
Used in
Maintenance
528DRC NA NA
Used in
Maintenance
528DRD NA NA
Used in
Maintenance
Table 5.5.2: U.S. Army Reserve OMS Product Handling.
The two used oil ASTs are double-walled steel tanks and do not collect storm water. The drums
are stored in a covered, three-sided containment area with a concrete secondary containment
dike (A), inside the maintenance bays (B), on plastic spill pallets that are under an overhanging
roof (C) or within portable steel closable containers with internal dikes (D). AST 528B is so
corroded that holes may develop (See Section 6.0, Corrective Actions).
Appendix E contains the volume calculations for the diked area. Personnel follow the rainwater
release procedures in Section 4.10 prior to any release from the diked area.
528A Double-walled NA
528B Double-walled NA
528DRA Concrete Dike Manual
528DRB None NA
528DRC Plastic Spill Pallets NA
528DRD
Portable Container W/
Internal Dike
NA
Table 5.5.3: U.S. Army Reserve OMS Secondary Containment.
Records of monthly visual inspections and overfill protection system tests are maintained by OMS
personnel for at least three years. Sections 4.8 and 4.9 establish the policies for the integrity
testing of shop-built containers (and piping) less than 5,000 gallons capacity and drums,
respectively.

Page 38
Complete failure of AST 528A or 528B could result in a spill of up to 132 gallons of used oil. The
loss of the entire contents of the collection tanker truck could spill 2,000 gallons of used oil. A spill
from the DOL fuel delivery truck could cause a spill of 3,300 gallons of diesel. It is assumed that
only one drum would spill in a given event. Any spill from this area would flow north directly into
the adjacent El Toro Creek (see Figures 5.5.1, 2.1, and 2.2) and trigger the spill response
Container
ID
Spill Amount
(Gallons)
528A
132
Used Oil
Container Failure
North to El Toro
Creek
528B
132
Used Oil
Container Failure
528DRA 55
Oil, Hydraulic
Oil, Grease Container Failure
Antifreeze
528DRB
55
Used Antifreeze
Container Failure North to El Toro
Creek
5 Transfer Error
528DRC
55
Oil, Hydraulic
Oil, Grease
Container Failure North to El Toro
Creek
5 Antifreeze Dispensing Error
528DRD 55
Oil, Hydraulic
Oil, Grease Container Error
North to El Toro
Creek
Antifreeze
Truck 3,300 Diesel Delivery Truck Error
North to El Toro
Creek
Table 5.5.4: U.S. Army Reserve OMS Potential Spill Scenarios.
5.6 DPW COMPLEX (BUILDINGS 34, 37, AND 38)
This area is the replacement for the former DPW shops and offices that were demolished.
Containers that were moved from the previous complex retain the same container number for
continuity purposes. There is a pesticide storage/mixing building with up to three pesticide drums
that is covered and contained, there is a vehicle parking area that is covered but without walls, so
some precipitation could accumulate. The pesticide drum (38IDR) does not contain oil but is
included to comply with AR 200-1. Out-of-service transformers are stored in the parking lot. There
are about 7 pad-mounted transformers (about 250 gallons each), all stored without secondary
containment (See Section 6.0, Corrective Actions). Table 5.6.1 provides container details, and
Figure 5.6.1 shows their locations.
Container
ID
Type
Capacity
(Gallons)
Material of
Construction
Product
Stored
34A
Internal
AST, Horizontal
6,200 Steel Diesel

Page 39
Container
ID
Type
Capacity
(Gallons)
Material of
Construction
Product
Stored
34FP AST, Horizontal 185 Steel Diesel
37DR 55-Gallon Drums
55
(up to 6)
Steel
Oil, Hydraulic
Oil
Antifreeze,
Used Antifreeze
37D@ AST, Horizontal 800 Steel Diesel
37E@ AST, Horizontal 475 Steel Diesel
37F AST, Horizontal 215 Steel Used Oil
38IDR 55-Gallon Drum 55 Plastic Insecticides
38PM
AST, Horizontal
Mobile
50 Plastic Herbicides
@
- not in service, to be used for emergency replacements only
Table 5.6.1: DPW Complex Containers.

Page 40
Figure 5.6.1: DPW Complex (Buildings 34, 37, and 38).

Page 41
The emergency generator tanks are filled by DOL personnel from a fuel delivery truck. DOL
personnel follow the truck unloading procedures described in Section 4.13. The used oil AST is
filled by pouring from small containers and emptied by a vacuum truck. The drums of new POL
and pesticides are purchased full and delivered on a flatbed truck. POL products are distributed
via an overhead air pressure hose system. Concentrated pesticides are dispensed into tank 38PM
for mixing. The pesticide tank 38PM is filled by adding a small amount of pesticide then filling the
remainder of the tank with water to create the appropriate strength. Table 5.6.2 provides more
details regarding product handling activities for this area.
34A Truck Sight Gauge Used in Generator
34FP Truck Sight Gauge
Used in Fort Buchanan
Fire Pump
37DR NA NA Used in Maintenance
37D@
NA NA NA
37E@
NA NA NA
37F Manual Visual Vacuum Truck
38IDR NA NA
Dispensed to 38PM for
mixing
38PM
Pesticide Added
Manually, Water
from Hose
Visual
Sprayed on vegetation or
building foundations
@
Table 5.6.2: DPW Complex Product Handling.
Tanks 37D, 37E, and 37F are double-walled steel with an interstitial space for monitoring.
Pesticide drums are stored inside Building 38 on plastic containment pallets (nominal 70-gallon
capacity). Tank 38PM is mounted in an application truck and sits in a concrete dike when not in
use. The POL drums are on secondary containment pallets that are too small (See Section 6.0,
Corrective Actions). The out-of-service transformers are stored without secondary containment
(See Section 6.0, Corrective Actions). Appendix E contains the volume calculations for the
bermed areas. Personnel follow the rainwater release procedures in Section 4.10 prior to any
release from the diked area.
34A Double-walled NA
34FP Double-walled NA
37DR Plastic Containment Pallet NA
38D Double-walled NA
37E Double-walled NA

Page 42
37F Double-walled NA
38IDR Plastic Containment Pallet NA
38PM Concrete Dike Manual
Table 5.6.3: DPW Complex Secondary Containment.
Records of monthly visual inspections and overfill protection system tests are maintained by DPW
testing requirements for shop-built containers (and piping) less than 5,000 gallons capacity and
drums, respectively.
Complete failure of AST 34A could result in a spill of up to 6,200 gallons. A spill from the DOL fuel
delivery truck could cause a spill of 3,300 gallons of diesel. It is assumed that only one drum
would spill in a given event. A spill from Building 34 would go north to the storm water pond and
then northwest to El Toro Creek. A spill from 37DR, 38PM, the pesticide drums, or the out of
service generators (assuming that they held product at the time) would go north to a storm water
inlet and then to El Toro Creek and trigger the spill response procedures listed in Section 4.7.
Container
ID
Spill
Amount
(Gallons)
34A
7,500
Diesel
Container Failure North and then
northwest in piping to
El Toro Creek
34FP
185
Diesel
Container Failure North and then
northwest in piping to
El Toro Creek
37DR
55
Oil,
Hydraulic Oil
Container Failure Northwest to storm
water inlet then to El
Toro Creek
37D@
800
Diesel
Container Failure
Northwest to storm
Toro Creek
37E@
475
Diesel
Container Failure
37F
215
Used Oil
Container Failure
38IDR 55 Insecticides Container Failure Northwest to storm
Toro Creek
38PM 50 Pesticides Container Failure
@
Table 5.6.4: DPW Complex Potential Spill Scenarios.

Page 43
5.7 LOGISTIC READINESS CENTER (LRC) FUEL STATION (BUILDING 613)
The Logistic Readiness Center (LRC) Fuel Station consists of two 8,000-gallon diesel tanks
moved from the previous fuel area and a new 10,000-gallon diesel and a new 5,000-gallon
gasoline AST. DOL mobile refueler trucks fill up at the fuel station and deliver diesel to emergency
generators throughout the installation. DOL mobile refueler trucks are parked empty in a
containment area when not in use. Table 5.7.1 provides container details, and Figure 5.7.1 shows
their locations.
Container ID Type
Capacity
(Gallons)
Material of
Construction
Product Stored
607
Sub-Base Double
Wall, AST
100 Steel Diesel
613 (Truck1) Mobile Refueler 3,300* Steel Diesel
613A AST, Horizontal 8,000 Steel Diesel
613B AST, Horizontal 8,000 Steel Diesel
613C AST, Horizontal 10,000 Steel Diesel
613D AST, Horizontal 5,000 Steel Gasoline
613E
Sub-Base Double
Wall, AST
48 Steel Diesel
613WH
Sub-Base Double
Wall, AST
100 Steel Diesel
*Stored empty when not in use
Table 5.7.1: Logistic Readiness Center (LRC) Fuel Station Containers.
The tanks are loaded in this area from contractor fuel delivery trucks. The tanker truck is filled
from the tanks by reversing the pumps. The tanker truck is then used to dispense fuel to
emergency generators throughout the installation and tactical vehicles at the U.S. Army Reserve
OMS (Building 528, see Section 5.5). Vehicles can also be fueled directly from commercial style
pumps on the opposite side of the tanks. Table 5.7.2 provides more details regarding product
handling activities.
613 (Truck1-4)
Electric Pump from
613A, 613B, or
613C
Sight Gauge
Dispensed to
vehicles or
generators
613A-613C Truck Sight Gauge
Dispensed to Truck
613 or directly to
vehicles
613D Truck Sight Gauge
Dispensed to
vehicles
Table 5.7.2: Logistic Readiness Center (LRC) Fuel Station Product Handling.

Page 44
Figure 5.7.1: Logistic Readiness Center Fuel Station (Building 613).

Page 45
The ASTs are double walled. None collect storm water. Mobile refueler 613 uses the concrete
berm when it is parked. The transfer area for the tanks has a concrete berm, with drains that are
closed when a truck is present, which provides additional secondary containment during transfers.
Appendix E contains the volume calculations for the berm area. DOL personnel follow the
rainwater release procedures in Section 4.10 prior to any release from the diked area.
613 (Truck 1) Concrete Berm Manual
613A-613D Double-walled NA
613 Transfer Area Concrete Berm Manual
613 (Truck 2-4)
Collapsible Containment
Berm
Manual
Table 5.7.3: Logistic Readiness Fuel Station Secondary Containment.
Records of certified inspections (for tanks greater than 5,000 gallons) are maintained by DPW
Environmental Division for the life of the container. Records of monthly visual inspections and
overfill protection system tests are maintained for at least three years by DPW Environmental
Division. Sections 4.8 and 4.9 establish the Fort Buchanan policies for the integrity testing of
shop-built containers (and piping) less than 5,000 gallons capacity and mobile and portable
containers, respectively.
Complete failure of 613C could result in a 10,000-gallon fuel spill. The loss of the entire contents
of the delivery tanker truck could spill 10,000 gallons of diesel. The loss of the contents of DOL
fuel truck 1 could spill 3,300 gallons of diesel. The loss of the contents of DOL fuel truck (2-4)
could spill 6,000 gallons of diesel. Spills would flow northeast across grass to storm ditches, and
then to Malaria Control Canal (see Figures 5.7.1, 2.1, and 2.2). A spill in this area would trigger
the spill response procedures listed in Section 4.7.
Container ID
Spill Amount
(Gallons)
613 (Truck 1)* 3,300 Diesel Container Failure
Drain to
grassy area
northeast to
Malaria
Control Canal
613A
8,000
Diesel
Container Failure
3,300 DOL Fuel Truck Error
25 Customer Error
613B
8,000
Diesel
Container Failure
25 Customer Error
613C
10,000
Diesel
Container Failure
25 Customer Error

Page 46
Container ID
Spill Amount
(Gallons)
613D
5,000
Gasoline
Container Failure
25 Customer Error
613 (Truck 2-4) 6,600 Diesel Container Failure
*When parked at building 613
Table 5.7.4: Logistic Readiness Fuel Station Potential Spill Scenarios.
5.8 SCHOOL BUS STORAGE AREA AND DODEA (BUILDING 566)
School buses for the Department of Defense Domestic Dependents Elementary and Secondary
Schools are parked in this complex. The maintenance of the buses is completed off-post. A
permanent emergency generator is located on the south side of building 566 (AST 566) (see
Section 5.10 for more information on emergency generators). There are also two small mobile
emergency generators that do not have their own fuel supply, so diesel needs to be provided.
Drums of diesel (566DR) for the mobile emergency generators are also stored outside within
plastic overpack drums. Table 5.8.1 provides container details, and Figure 5.8.1 shows their
locations.
Container ID Type
Capacity
(Gallons)
Material of
Construction
Product Stored
566
Sub-Base Double
Wall, AST
196 Steel Diesel
566DR 55-Gallon Drums 55 (up to 5) Steel Diesel
Table 5.8.1: School Bus Storage Area and DODEA Containers.
The emergency generator tank is filled by the DOL fuel delivery truck. The diesel drums are
purchased and delivered to the site by flatbed truck. The drums of diesel are moved with the
mobile generators when necessary. Table 5.8.2 provides more details regarding product handling
activities for this area.
566 Truck Sight Gauge Used in generator
566DR NA NA
Small hand pump to
mobile generators
Table 5.8.2: School Bus Storage Area and DODEA Product Handling.

Page 47
Figure 5.8.1: School Bus Storage Area and DODEA (Building 566).

Page 48
Tank 566 is double-walled steel with monitoring for the interstitial space. The drums of diesel are
steel and stored in plastic overpack drums. Some diesel is spilled inside the overpack drums (see
Corrective Actions, Section 6.0). None of the secondary containment systems collect storm water.
566 Double-walled NA
566DR Overpack Drums NA
Table 5.8.3: School Bus Storage Area and DODEA Secondary Containment.
testing requirements for shop-built containers (and piping) less than 5,000 gallons capacity and
drums, respectively.
Complete failure of AST 566 could result in a spill of 200 gallons of diesel. The loss of the entire
contents of the delivery tanker truck would create a 3,300 gallon diesel spill. It is assumed that
only one drum would spill in a given event. Any spill from this area would flow east across the
asphalt parking lot to the surface storm water drainage channel that discharges north to El Toro
Creek (see Figures 5.8.1, 2.1, and 2.2). A spill in this area would trigger the spill response
Container
ID
Spill Amount
(Gallons)
566
200
Diesel
Container Failure
East across parking
lot to storm water
drainage then north
to El Toro Creek
566DR
55
Diesel
Container Failure
5 Dispensing Error
Table 5.8.4: School Bus Storage Area and DODEA Potential Spill Scenarios.
5.9 ARMED FORCES RESERVE CENTER (AFRC) MOTOR POOL (BUILDING 615)
The AFRC Motor Pool is used for vehicle maintenance by the Army, Navy, Air Force, and Marine
Reserves. There is a flammable storage area inside the building where drums are kept. Table
5.9.1 provides container details, and Figure 5.9.1 shows their locations.
Container ID Type
Capacity
(Gallons)
Material of
Construction
Product Stored
615DR 55-Gallon Drums
55
(up to 20)
Steel
Oil, Hydraulic Oil,
Used Oil
Antifreeze, Used
Antifreeze
Table 5.9.1: AFRC Motor Pool Containers.

Page 49
Drums are delivered and removed full. Products are dispensed for vehicle maintenance by hand
pumps. Table 5.9.2 provides more details regarding product handling activities for this area.
615DR (New) NA NA
Used in
Maintenance
615DR (Used) Manual Visual Removed on Truck
Table 5.9.2: AFRC Motor Pool Product Handling.
The drums are stored indoors on a concrete containment floor. The containment floor does not
collect storm water. See Appendix E for volume calculations.
615DR Contained by Building NA
Table 5.9.3: AFRC Motor Pool Secondary Containment.

Page 50
Figure 5.9.1: AFRC Motor Pool (Building 615).

Page 51
personnel for at least three years. Section 4.9 establishes the policy for the integrity testing
requirements for drums.
It is assumed that only one drum would spill in a given event. Any spill from this area would flow
north towards Malaria Control Canal (see Figures 2.1 and 2.2). A spill in this area would trigger
the spill response procedures listed in Section 4.7.
Container
ID
Spill Amount
(Gallons)
615DR
(new)
55 Oil, Hydraulic Oil Container Failure
North to
Malaria
Control
Canal
615DR
(used)
55 Used Oil Container Failure
5 Used Antifreeze Transfer Error
Table 5.9.4: AFRC Motor Pool Potential Spill Scenarios.
5.10 597TH
QUARTERMASTER CO. US ARMY RESERVE – ORGANIZATIONAL
MAINTENANCE SUPPORT (OMS) (BUILDING 609)
The 597th
Quartermaster operates the OMS to store and maintain tactical vehicles and supplies.
POL and antifreeze are stored in two concrete secondary containment flammable storage areas
(609DRA and 609DRB), with space for up to twenty and ten 55-gallon drums, respectively. Table
5.10.1 provides container details, and Figure 5.10.1 shows their locations.
Container ID Type
Capacity
(Gallons)
Material of
Construction
Product Stored
55
(up to 20)
Steel
Oil, Hydraulic Oil
Antifreeze
55
(up to 10)
Steel
Used Oil
Used Antifreeze
-Does not contain oil, not regulated by 40 CFR 112
Table 5.10.1: Quartermaster OMS Containers.
Mechanics drain vehicle used oil and used antifreeze by hand into drums. The used oil is removed
by a vacuum truck for recycling. New POL and antifreeze drums are ordered and delivered full on
a flatbed truck. Table 5.10.2 provides more details on product handling activities for this area.
609DRA NA NA
Used in
Maintenance
Table 5.10.2: Quartermaster OMS Product Handling.

Page 52
Figure 5.10.1: 597th
Quartermaster Co. OMS (Building 609).

Page 53
The drums are stored indoors in containment rooms with a concrete secondary containment dike.
The rooms do not collect storm water. Appendix E contains the volume calculations for the diked
area.
609DRA Concrete Dike NA
609DRB Concrete Dike NA
Table 5.10.3: Quartermaster OMS Secondary Containment.
Records of monthly visual inspections are maintained by OMS personnel for at least three years.
Section 4.9 establishes the policy for the integrity testing of drums.
The loss of the entire contents of the collection tanker truck could spill 2,000 gallons of used oil.
It is assumed that only one drum would spill in a given event. Any spill from this area would flow
north into Malaria Control Canal (see Figures 5.10.1, 2.1, and 2.2) and trigger the spill response
Container
ID
Spill Amount
(Gallons)
609DRA
55
Oil, Hydraulic
Oil
Container Failure North to Malaria
Control Canal
609DRB
55 Used Oil Container Failure North to Malaria
Control Canal
2,000 Used Antifreeze Collection Truck Error
Table 5.10.4: Quartermaster OMS Potential Spill Scenarios.
5.11 NATIONAL GUARD READINESS CENTER, USPFO AND PRNG HQ (BUILDINGS 540
THROUGH 552)
The National Guard Readiness Center, USPFO and PRNG HQ includes an emergency generator
and Fort Buchanan fire pump, a fuel dispensing point, and a maintenance facility for tactical
vehicles and equipment. There is currently no maintenance occurring at this site and therefore no
oil storage in drums, but the mission and unit assignments could change rapidly, so the areas
where POL and antifreeze drums would be stored are identified and described in this section.
There are also three USTs attached to O/W separators. Table 5.11.1 provides container details,
and Figure 5.11.1 shows their locations.
Container
ID
Type
Capacity
(Gallons)
Material of
Construction
Product
Stored
Building
540
Sub-Base
Double wall, AST
600 Steel Diesel USPFO-Adm

Page 54
Container
ID
Type
Capacity
(Gallons)
Material of
Construction
Product
Stored
Building
541
Sub-Base
Double wall, AST
225 Steel Diesel USPFO-WH
545 AST, Horizontal 8,000 Steel Diesel
Readiness
Center
546 AST, Horizontal 5,000 Steel Diesel
Readiness
Center
547FP AST, Horizontal 115 Steel Diesel
Readiness
Center
546A UST 200
Inner Steel /
Outer FRP
Used Oil
Readiness
Center
546B UST 200
Inner Steel /
Outer FRP
Used Oil
Readiness
Center
546C UST 200
Inner Steel /
Outer FRP
Used Oil
Readiness
Center
55 (up to
40)
Steel
Oil,
Hydraulic
Oil
Readiness
Center
Antifreeze
Readiness
Center
55 (up to
20)
Steel
Used Oil
Readiness
Center
Used
Antifreeze
Readiness
Center
549DRC 55-Gallon Drums
55 (up to
6)
Steel
Oil,
Hydraulic
Oil, Used
Oil
Readiness
Center
Antifreeze,
Used
Antifreeze
Readiness
Center
552
Sub-Base
Double wall, AST
1,200 Steel Diesel PRNG-HQ
Table 5.11.1: National Guard Readiness Center, USPFO and PRNG HQ Containers.

Page 55
Figure 5.11.1: National Guard Readiness Center, USPFO and PRANG HQ (Buildings 540 through 552).

2022-Fort Buchanan SPCCP Final.pdf

2022-Fort Buchanan SPCCP Final.pdf

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