Under the Federal Water Pollution Control Act (regulations found in 40 CFR part 112) facilities subject to the SPCC rule must prepare a plan to prevent the release of oil to the navigable waters of the United States. GBK, in partnership with CH Guernsey & Company completed a review and update of the Fort Sill Spill Prevention Control and Countermeasures Plan (SPCCP) and the Installation Spill Contingency Plan (ISCP). The update included assessing over 70 individual industrial-style facilities for inclusion in the plan. Each facility was mapped using ArcGIS software from available aerial imagery and information recorded from site visits. Facility diagrams included all pertinent information such as all outside-of-building hazardous materials and oil storage locations over 55 gallons, tanker pads, spill kits, oil-water separators, storm drains, direction of flow and unpaved ground. Locations of spill kits, fire hydrants and secondary containments were also recorded. Data during site visits was recorded using a Trimble GeoXT GPS handheld with submeter accuracy.
The facility descriptions included calculation and analysis of the adequacy of available secondary containment for worst-case discharge scenario during a 25yr storm event. Where applicable, the acceptable environmental equivalence was detailed or the facility was flagged for further action.
Furthermore, the Installation Spill Contingency Plan was updated and brought into line with requirement and ultimately GBK was able to provide a fully updated and compliant SPCCP and ISCP for Ft Sill in time for the 2009 EPAS inspection and before the EPA July 2009 SPCC amendment deadline.