ICP_1st half_Perry Point VAMC FINAL Oct 2021 SIGNED.pdf

DEPARTMENT OF VETERANS AFFAIRS

PERRY POINT

VETERANS AFFAIRS MEDICAL CENTER

INTEGRATED CONTINGENCY PLAN

Revision 6.0 | 2021

POTOMAC-HUDSON ENGINEERING, INC.

MANAGEMENT APPROVAL

The Perry Point Veterans Affairs Medical Center (VAMC) is committed to preventing discharges of oil and hazardous material/waste to navigable waters and the environment, and to maintaining the highest standards for spill prevention, control, and countermeasures through the implementation and regular review and amendment of this plan. This plan has the full approval of VA management. The Veterans Affairs Medical Center has committed the necessary resources to implement the measures described in this plan and to resolve the inadequacies identified in Section 19.0 of this plan.

The GEMS Coordinator is the designated person accountable for spill prevention at the VAMC and reports directly to the VAMHCS Safety and Health Program Manager.

Mr. Robert Johnson Date Acting Safety and Health Program Manager VA Maryland Health Care System

Ms. Kelley Anthony, LCSW-C Date Interim Assistant Director VA Maryland Health Care System

Mr. Mehdi Zekri Date Acting Chief, Facilities and Engineering VA Maryland Health Care System

Ms. Lori Rosenzweig Date Associate Director VA Maryland Health Care System

Date Jonathan R. Eckman, P.E.

Director VA Maryland Health Care System

Robert F. Johnson 443302

Digitally signed by Robert F.

Johnson 443302 Date: 2021.10.27 08:37:50 -04'00'

Kelley W. Anthony 237689

Digitally signed by Kelley W.

Anthony 237689 Date: 2021.10.27 10:44:21 -04'00'

MEHDI ZEKRI Digitally signed by MEHDI ZEKRI Date: 2021.10.29 08:47:33 -04'00'

Lori A. Rosenzweig 217848

Digitally signed by Lori A.

Rosenzweig 217848 Date: 2021.10.30 19:20:11 -04'00'

10/27/21

10/27/21

10/29/21

10/30/21

Table 0.1. Record of Revisions

REVISION

NUMBER

DATE OF

REVISION

SECTION NUMBERS REVISED

(Comments)

DATE

ENTERED

1.0 August 2006 Technical- Removal of USTs. They have been

replaced by similar volumetric ASTs.

August 2006

1.1 August 2006 Administrative- General update of language and reorganization of sections.

August 2006

1.2 August 2006 Technical- Update of facility improvements. August 2006

2.0 December

Technical- Addition of two ASTs. One 500 gal AST filled with diesel and one 150 gal used oil tank.

December

3.0 December

Technical- Addition of 6 ASTs, replacement AST, relocation of hazardous waste storage and AST, and update secondary containment and points of contact.

February

4.0 October 2017 Technical – Updated hazardous and universal waste operations; updated diagrams; updated responsibilities; added DT-23H/GG106 and DT-333, and mobile emergency generators, relabeled DT23 as

DT-23H/DT-361G, added Quick Reference Guide.

October 2017

5.0 May 2019 Technical – Addition of 4 new ASTs; elimination of one AST; corrected volumes for 5 ASTs; addition of 19 oil-filled transformers. Also includes several minor administrative changes.

June 2019

6.0 October 2021 Technical – Removal of two ASTs; replacement of two oil-filled transformers; addition of one oil-filled transformer. Also includes several minor administrative changes.

October 2021

Complete monthly and annual site inspections

Perform preventive maintenance as needed

Conduct annual employee training

Review the plan on an annual basis.

Review the plan at least once every 5 years

Amend the plan within 6 months

Submit the plan to the United States Environmental Protection Agency o

40 CFR 112.7, If the Plan calls for additional facilities or procedures, methods, or equipment not yet fully operational, these items must be discussed in separate paragraphs and must include the details of installation and operational start-up.

40 CFR 112.7, If you do not follow the sequence specified in this section for the Plan, you must prepare an equivalent Plan acceptable to the Regional Administrator that meets all of the applicable requirements listed in this part, and you must supplement it with a section cross-referencing the location of requirements listed in this part and the equivalent requirements in the other prevention plan.

40 CFR 112.4(d), The U.S. EPA may require the facility to amend the Plan if it finds that the Plan does not satisfy the requirements of 40 CFR §112, or if amendment is necessary to prevent and contain discharges from the facility. A spill event to navigable waters may subject the facility to additional reporting requirements of 40 CFR §112.4.

40 CFR 112.5(a), Amend the SPCC Plan for your facility in accordance with the general requirements in § 112.7, and with any specific section of this part applicable to your facility, when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge as described in § 112.1(b).

40 CFR 112.5(b), Complete a review and evaluation of the SPCC Plan at least once every five years from the date your facility becomes subject to this part. As a result of this review and evaluation, you must amend your SPCC Plan within six months of the review to include more effective prevention and control technology if the technology has been field-proven at the time of the review and will significantly reduce the likelihood of a discharge. You must implement any amendment as soon as possible, but not later than six months following preparation of any amendment. You must document your completion of the review and evaluation, and must sign a statement as to whether you will amend the Plan, either at the beginning or end of the Plan or in a log or an appendix to the Plan.

40 CFR 112.5(c), Have a Professional Engineer certify any technical amendment to your Plan in accordance with § 112.3(d).

40 CFR 112.3(e), Maintain a complete copy of the Plan at the facility if the facility is normally attended at least four hours per day, or at the nearest field office if the facility is not so attended, and

112.7(a) (3), Describe in your Plan the physical layout of the facility and include a facility diagram, which must mark the location and contents of each container. The facility diagram must include completely buried tanks that are otherwise exempted from the requirements of this part under §112.1(d) (4). The facility diagram must also include all transfer stations and connecting pipes.

FACILITY NAME: Perry Point Veterans Affairs Medical Center

MAILING ADDRESS: Veterans Affairs Medical Center Perry Point Dept. of Veterans Affairs Medical Center Perry Point, Maryland 21902

FACILITY STREET ADD: Broad Street Perry Point, MD 21902

TELEPHONE: 410-642-2411

CONTACT NAME: Jennifer Dallaire, GEMS Program Manager Andrew Bannon, Fire Chief

LOCATION: The Perry Point VAMC is located at the terminus of Broad

Street in Perry Point, MD.

FACILITY DESCRIPTION: The Perry Point VAMC is the largest inpatient facility in the VA Maryland Health Care System (VAMHCS). The Perry Point VAMC provides inpatient medical, intermediate and long-term care programs, including nursing home care, rehabilitation services, geriatric evaluation and management, respite care, chronic ventilator care and hospice care. In addition to the medical campus facilities, there are several ancillary buildings including a drinking water plant, heating plant, and chiller plant.

TOTAL BULK STORAGE: The VAMC operates a 150,000-gallon AST as well as 32 other ASTs ranging in capacity from 75 to 15,000 gallons containing petroleum, oils, or lubricants (POLs). The facility also maintains one 275-gallon mobile refueling tank, as well as 24 elevator hydraulic fluid reservoirs and 49 oil-filled transformers.

Table 2-1. Aboveground Storage Tank Inventory

TANK NO. LOCATION CAPACITY

(gallons)

PRODUCT HI-LEVEL

ALARM

CONTAINMENT AND SPILL

CONTROL FEATURES

D-17H Kitchen, Bldg. 17H 3,000 Diesel Fuel Yes Double-walled tank, overfill prevention device DT-17H Emergency

Generator, Bldg.

17H

100 Diesel Fuel Yes Integral Secondary Containment

D-19H Medical Ward, Bldg. 19H

2,000 Diesel Fuel No Double-walled tank

D-20 Raw Water Pumping Station, Bldg. 20

605 Diesel Fuel No Double-walled tank, Secondary containment

D-20H/D-333 Generator Bldg.

333, adjacent to

Bldg. 20H

2,000 Diesel Fuel Yes Double-walled tank, overfill prevention device, spill bucket

DT-20H/DT-

Generator Bldg.

150 Diesel Fuel No Double-walled tank

D-23H/D-361G Hospital Clinic, Bldg. 23 (Outside

Building 23H)

2,500 Diesel Fuel Yes Double-walled tank, spill bucket

DT-23H/DT-

361G

Emergency Generator, Bldg.

75 Diesel Fuel Yes Double-walled tank

(gallons)

PRODUCT HI-LEVEL

ALARM

CONTAINMENT AND SPILL

CONTROL FEATURES

361G (Outside Building 23H)

DT-

23H/GG106

Room GG-106, Bldg. 23H (Inside

Building 23H)

75 Diesel Fuel Yes Double-walled tank

D-103

NEW Water Filter Plant, Bldg. 103

4000 Diesel Fuel No Vaulted, double-walled tank, Secondary containment

DT-103A

242 Diesel Fuel No Double-walled tank, Secondary containment

DT-103B

242 Diesel Fuel No Double-walled tank, Secondary containment

D-311 Wastewater Pumping Station, Bldg. 311

1,000 Diesel Fuel Yes Double-walled tank, spill bucket

DT-311 Emergency Generator, Bldg.

75 Diesel Fuel Yes Single-walled tank; secondary containment partially provided by building in conjunction with active measures D-315 Boiler Plant, Bldg.

150,000 Heating Oil No 164,000-gallon engineered berm consisting of soil and concrete with a PVC liner

D-321.A Chiller Plant, Bldg.

500 Diesel Fuel No Double-walled tank, spill bucket

DT-321.A Emergency Generator, Bldg.

75 Diesel Fuel Yes Double-walled tank

D-321.B Chiller Plant, Bldg.

15,000 Diesel Fuel Yes Double-walled tank

DT-321.B Chiller Plant, Bldg.

700 Diesel Fuel Yes Integral Secondary Containment

D-321.C Chiller Plant, Bldg.

15,000 Diesel Fuel Yes Double-walled tank

DT-321.C Chiller Plant, Bldg.

700 Diesel Fuel Yes Integral Secondary Containment

D-324 Generator Bldg.

550 Diesel Fuel No Double-walled tank, spill bucket

D-325 Generator Bldg.

550 Diesel Fuel No Double-walled tank, spill bucket

D-326 Generator Bldg.

550 Diesel Fuel No Double-walled tank, spill bucket

D-327 Generator Bldg.

500 Diesel Fuel No Double-walled tank, spill bucket

D-329 Generator Bldg.

550 Diesel Fuel No Double-walled tank, spill bucket

D-344 Generator Bldg.

550 Diesel Fuel Yes Double-walled tank; overfill prevention device

(gallons)

PRODUCT HI-LEVEL

ALARM

CONTAINMENT AND SPILL

CONTROL FEATURES

D-360G Filter Plant, Bldg. 360G 2,000 Diesel Fuel Yes Double-walled tank, spill bucket

D-365 Generator Bldg.

1,000 Diesel Fuel Yes Double-walled tank, spill bucket

DT-365 Emergency Generator, Bldg.

75 Diesel Fuel No Single-walled tank; secondary containment partially provided by building in conjunction with active measures D-507 Salt Shed, Bldg.

500 Diesel Fuel No Double-walled tank

D-11.A Mobile Emergency Generator (200 kw)

100 Diesel Fuel No Double-walled tank

D-11.B Mobile Emergency Generator (200 kw)

100 Diesel Fuel No Double-walled tank

D-11.C Mobile Emergency Generator (100 kw)

100 Diesel Fuel No Double-walled tank

D-Mobile REMRO (Outside) Mobile Refueler

275 Diesel Fuel N/A None

D-REMRO Automotive Repair Garage

500 Heating Oil No Sec. containment basin

O-11 Garage, Bldg. 11 275 Used Oil No Sec. containment basin Total Volume 206,214

112.7(b), Where experience indicates a reasonable potential for equipment failure (such as loading or unloading equipment, tank overflow, rupture, or leakage, or any other equipment known to be a source of a discharge), include in your Plan a prediction of the direction, rate of flow, and total quantity of oil which could be discharged from the facility as a result of each type of major equipment failure.

Table 3-1. Potential Discharge from Regulated ASTs Tank ID Failure Direction Flow Rate Volume

(gallons) Basis

D-17H Tank Rupture To secondary containment

Instantaneous 3,000 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 3,000 Total volume is based on tank capacity.

Tank Overfill To containment berm

50 gal/min 500 Based on the typical fill rate over 10 minutes.

DT-17H Tank Rupture To secondary containment

Instantaneous 100 Total volume is based on tank capacity

Tank Leakage To secondary containment

1 gal/min 100 Total volume is based on tank capacity

D-19H Tank Rupture To secondary containment

Instantaneous 2,000 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 2,000 Total volume is based on tank capacity.

Tank Overfill To southeast and southwest to Avenue D

50 gal/min 500 Based on the typical fill rate over 10 minutes.

D-20 Tank Rupture To secondary containment

Instantaneous

Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min

Total volume is based on tank capacity.

Table 3-1. Potential Discharge from Regulated ASTs Tank ID Failure Direction Flow Rate Volume

(gallons) Basis

Tank Overfill To containment berm

50 gal/min 500 Based on the typical fill rate over 10 minutes.

D-20H/D-333 Tank Rupture To secondary containment

Instantaneous 2,000 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 2,000 Total volume is based on tank capacity.

Tank Overfill North/northeast to low area

50 gal/min 500 Based on the typical fill rate over 10 minutes.

DT-20H/DT-333 Tank Rupture To secondary containment

Instantaneous 150 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 150 Total volume is based on tank capacity.

D-23H/D-361G (Outside Bldg.

23H)

Tank Rupture To secondary containment

Instantaneous 2,500 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 2,000 Total volume is based on tank capacity.

Tank Overfill East to storm drain

50 gal/min 500 Based on the typical fill rate over 10 minutes.

DT-23H/DT-361G

(Outside Bldg.

23H)

Tank Rupture To secondary containment

Instantaneous 75 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 75 Total volume is based on tank capacity.

DT-23H/ GG106 Tank Rupture To secondary containment

Instantaneous 75 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 75 Total volume is based on tank capacity.

D-311 Tank Rupture To secondary containment

Instantaneous 1,000 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 1,000 Total volume is based on tank capacity.

Tank Overfill South to storm drain

50 gal/min 500 Based on the typical fill rate over 10 minutes.

(gallons) Basis

DT-311 Tank Rupture Radially across floor to doorway

Instantaneous 75 Total volume is based on tank capacity.

Tank Leakage Radially across floor to doorway

1 gal/min 75 Total volume is based on tank capacity.

D-315 Tank Rupture To secondary containment

Instantaneous 150,000 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 150,000 Total volume is based on tank capacity.

Tank Overfill To secondary containment

50 gal/min 500 Based on the typical fill rate over 10 minutes.

Piping Failure Outside Containment Structure

To nearby storm drains

50 gal/min 72,000 Estimated flow rate and a 24-hour time interval.

D-321.A Tank Rupture To secondary containment

Instantaneous 500 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 500 Total volume is based on tank capacity.

Tank Overfill Southwest to low area

50 gal/min 500 Based on the typical fill rate over 10 minutes.

DT-321.A Tank Rupture To secondary containment

Instantaneous 75 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 75 Total volume is based on tank capacity.

D-321.B and D-321.C

Tank Rupture To secondary containment

Instantaneous 15,000 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 15,000 Total volume is based on tank capacity.

Tank Overfill Southeast/west to Avenue D

50 gal/min 500 Based on the typical fill rate over 10 minutes.

DT-321.B

and

DT-321.C

Tank Rupture To secondary containment

Instantaneous 700 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 700 Total volume is

(gallons) Basis

Tank Overfill Southeast/west to Avenue D

50 gal/min 500 Based on the typical fill rate over 10 minutes.

D-324 Tank Rupture To secondary containment

Instantaneous 550 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 550 Total volume is based on tank capacity.

Tank Overfill Southeast/west to storm drains

50 gal/min 500 Based on the typical fill rate over 10 minutes.

D-325 Tank Rupture To secondary containment

Instantaneous 550 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 550 Total volume is based on tank capacity.

Tank Overfill Northeast to storm drain

50 gal/min 500 Based on the typical fill rate over 10 minutes.

D-326 Tank Rupture To secondary containment

Instantaneous 550 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 550 Total volume is based on tank capacity.

Tank Overfill South to storm drain

50 gal/min 500 Based on the typical fill rate over 10 minutes.

D-327 Tank Rupture To secondary containment

Instantaneous 500 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 500 Total volume is based on tank capacity.

Tank Overfill Northwest to storm drain

50 gal/min 500 Based on the typical fill rate over 10 minutes.

D-329 Tank Rupture To secondary containment

Instantaneous 550 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 550 Total volume is based on tank capacity.

Tank Overfill East to storm drain

50 gal/min 500 Based on the typical fill rate over 10 minutes.

(gallons) Basis

D-360G Tank Rupture To secondary containment

Instantaneous 2,000 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 2,000 Total volume is based on tank capacity.

Tank Overfill Southeast to low area around water tank

50 gal/min 500 Based on the typical fill rate over 10 minutes.

D-103 Tank Rupture To secondary containment

Instantaneous 4,000 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 4,000 Total volume is based on tank capacity.

Tank Overfill Southwest to low area

50 gal/min 500 Based on the typical fill rate over 10 minutes.

DT-103A Tank Rupture To secondary containment

Instantaneous 242 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 242 Total volume is based on tank capacity.

DT-103B Tank Rupture To secondary containment

Instantaneous 242 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 242 Total volume is based on tank capacity.

D-365 Tank Rupture To secondary containment

Instantaneous 1,000 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 1,000 Total volume is based on tank capacity.

Tank Overfill South to drainage swale

50 gal/min 500 Based on the typical fill rate over 10 minutes.

DT-365 Tank Rupture Radially across floor to doorway

Instantaneous 75 Total volume is based on tank capacity.

Tank Leakage Radially across floor to doorway

1 gal/min 75 Total volume is based on tank capacity.

D-344 Tank Rupture To secondary containment

Instantaneous 550 Total volume is

(gallons) Basis

Tank Leakage To secondary containment

1 gal/min 550 Total volume is based on tank capacity.

Tank Overfill South to storm drain

50 gal/min 500 Based on the typical fill rate over 10 minutes.

D-507 Tank Rupture To secondary containment

Instantaneous 500 Total volume is based on tank capacity.

Tank Leakage To secondary containment

1 gal/min 500 Total volume is based on tank capacity.

Tank Overfill Northeast to a low area

50 gal/min 250 Based on the typical fill rate over 10 minutes.

D-REMRO Tank Rupture To secondary containment structure

Instantaneous 500 Total volume is based on tank capacity.

Tank Leakage To secondary containment structure

1 gal/min 500 Total volume is based on tank capacity.

Tank Overfill To secondary containment structure

50 gal/min 500 Based on the typical fill rate over 10 minutes.

D-Mobile Refueler

Tank Rupture To floor drain Instantaneous 275 Total volume is based on tank capacity.

Tank Leakage To floor drain 1 gal/min 275 Total volume is based on tank capacity.

Tank Overfill To floor drain 50 gal/min 500 Based on the typical fill rate over 10 minutes.

O-11 Tank Rupture To secondary containment structure

Instantaneous 275 Total volume is based on tank capacity.

Tank Leakage To secondary containment structure

1 gal/min 275 Total volume is based on tank capacity.

Mobile Generators (D- 11.A, D-11B, and D-11.C)

Tank Rupture To floor drain to north

Instantaneous 100 Total volume is based on tank capacity.

Tank Leakage To floor drain to north

1 gal/min 100 Total volume is based on tank capacity.

Tank Overfill To floor drain to north

10 gal/min 10 Based on manual filling.

Table 3-2. Regulated Transformer Inventory Transformer No./ Label Information

Location Substance Volume (gallons)

001-324 PP Bldg. 3H/5H, Room 324 Dielectric Fluid 100 002-326 PP Bldg. 13H/14H, Room 326 Dielectric Fluid 225 003 329 PP Bldg. 329, Basement Dielectric Fluid 135 004 344 PP Bldg. 344, Basement Dielectric Fluid 167 005 325 PP Bldg. 1H/2H, Room 325 Dielectric Fluid 165 006-17H PP Bldg. 17H, Subbasement Dielectric Fluid 172

007 DIN CAR PP Bldg. 322, Electrical Substation Dielectric Fluid 2,400 008 DIN CAR PP Bldg. 322, Electrical Substation Dielectric Fluid 2,400

009 DIN CAR TP PP Bldg. 322, Electrical Substation, Load Tap Changer

Dielectric Fluid 300

010 DIN CAR TP PP Bldg. 322, Electrical Substation, Load Tap Changer

Dielectric Fluid 300

011 315 PP Bldg. 315, Boiler Plant Dielectric Fluid 216 012 321A PP Bldg. 321, Chiller Plant Dielectric Fluid 430 013 321B PP Bldg. 321, Chiller Plant Dielectric Fluid 351 014 11W PP Bldg. 11W Dielectric Fluid 172 015 314 PP Bldg. 314, Basement Dielectric Fluid 146

016 11H A PP Bldg. 11H Dielectric Fluid Unknown

017 11H B PP Bldg. 11H Dielectric Fluid Unknown 018 11H C PP Bldg. 11H Dielectric Fluid Unknown

019 6H PP Bldg. 6H Dielectric Fluid 70 020 8A 1 PP Bldg. 8A Dielectric Fluid 100 021 8A 2 PP Bldg. 8A Dielectric Fluid 100 022 8A 3 PP Bldg. 8A Dielectric Fluid 100

023 14H DHHS PP Bldg. 14 Dielectric Fluid 155 024 14H DHHS PP Bldg. 14 Dielectric Fluid 155 025 14H DHHS PP Bldg. 14 Dielectric Fluid 155

036 4R PP Bldg. 4R Dielectric Fluid 104 037 59 PP Bldg. 59 (Police Station) Dielectric Fluid Unknown

038 327 PP Bldg. 24H/25H, Room 327 Dielectric Fluid 269 039 311 PP Sewage Pumping Station Dielectric Fluid 163

040 05 DHHS PP Bldg. 5 Dielectric Fluid 244 041 20H PP Bldg. 20H, Front of Bldg. Dielectric Fluid 166 042 364 PP Front of Bldg. 364 Dielectric Fluid 270 043 15H PP Bldg. 15H and Tunnel Dielectric Fluid 177 044 101 PP Bldg. 101 Dielectric Fluid 275 045 23H PP Bldg. 23H, Rear of Bldg. Dielectric Fluid 226 046 361 PP Bldg. 361, Rear of Bldg. 23H Dielectric Fluid 165 047 360 PP Bldg. 360 Dielectric Fluid 177

048A 41 GH PP Greenhouse Dielectric Fluid 210 048B 41 GH PP Greenhouse Dielectric Fluid 210

049 80H PP Bldg. 80H Dielectric Fluid 325 050 82H PP Bldg. 82H Dielectric Fluid 175

051 T5 REMRO PP Bldg. T5, REMRO Dielectric Fluid 200 052 91 MAN PP Bldg. 91 Dielectric Fluid 117 053 18H A PP Bldg. 18H Dielectric Fluid 65 054 18H B PP Bldg. 18H Dielectric Fluid 65 055 18H C PP Bldg. 18H Dielectric Fluid 65 056 19H PP Bldg. 19H, Tunnel Dielectric Fluid 224

057 20 RAW PUMP PP Bldg. 20 Dielectric Fluid 248 059 23H PP Bldg. 23H Dielectric Fluid 235

Table 3-3. Inventory of Regulated Hydraulic Reservoirs Reservoir ID Location Substance Volume

(gallons) 1H Bldg. 1H, Room 1 (Tunnel) Hydraulic

Fluid

2H Bldg. 2H, Room 1 (Tunnel) Hydraulic Fluid

3H Bldg. 3H, Room 126 Hydraulic Fluid

4H Bldg. 4H, Basement (Tunnel)

Hydraulic Fluid

4R Bldg. 4R, Ground Floor (exterior door adjacent to elevator shaft)

Hydraulic Fluid

5H Bldg. 5H, Basement (Tunnel)

Hydraulic Fluid

9H -1 Bldg. 9H, Basement Hydraulic Fluid

9H-2 Bldg. 9H, Basement Hydraulic Fluid

11-1 Bldg. 11, Basement Hydraulic Fluid

11-2 Bldg. 11, Basement Hydraulic Fluid

11H Bldg. 11H, Room 101 Hydraulic Fluid

13H Bldg. 13H, Room 2 Hydraulic Fluid

14H Bldg. 14H, Room 4B (Enter through Room 4 then into

Room 4B)

Hydraulic Fluid

15H Bldg. 15H, Room 101 Hydraulic Fluid

17H Bldg. 17H, Room 17 (Sub-basement)

Hydraulic Fluid

19H Bldg. 19H, Room 1A1 Hydraulic Fluid

22H Bldg. 22H, Elevator #2 – Kitchen) (Back of Bldg.

22H) NOTE: Elevator #1 (across from Nurse's station) is NOT hydraulic.

Hydraulic Fluid

Table 3-3. Inventory of Regulated Hydraulic Reservoirs Reservoir ID Location Substance Volume

(gallons) 24H Bldg. 24H, Room 1 Hydraulic

Fluid

25H Bldg. 25H, Room 2 Hydraulic Fluid

80H Bldg. 80H, Basement Hydraulic Fluid

82 Bldg. 82, Basement Hydraulic Fluid

314 Bldg. 314, Room B4 Hydraulic Fluid

GD-100 (P1 and P2) Bldg. 361, Room GD-100 Hydraulic Fluid

165 x 2

Table 3-4. Potential Discharge from Building 11 Drum Storage Area Potential Event Discharge

Direction Spill Rate Volume Discharged

(gallons) Secondary Containment and Control Drum Tipping Northwest to garage area Instantaneous 55 Spill pallet

Drum Leakage Northwest to garage area

<1 gal./min. 55 Spill pallet

Spills During Product Removal

Northwest to room entrance

Instantaneous 5 Spill pallet

Table 3-5. Potential Discharge from REMRO Drum Storage Area Potential Event Discharge Direction Spill Rate Volume Discharged

(gallons) Secondary Containment and Control Drum Tipping Southeast to storm drain Instantaneous 55 Spill pallet

Drum Leakage Southeast to storm drain

<1 gal./min. 55 Spill pallet

Spills During Product Removal

Contained within shed

Instantaneous 5 Spill pallet

Table 3-6. Potential Discharge From Grease Dumpster Potential Event Discharge Direction Spill Rate Volume Discharged

(gallons) Secondary Containment and Control Dumpster

Tipping North approximately 10 feet to floor drain

Instantaneous 150 None

Dumpster Leakage

North approximately 10 feet to floor drain

<1 gal./min. 10 None

Spills During Product Removal

North to storm drain Instantaneous 10 None

Provide appropriate containment and/or diversionary structures or equipment to prevent a discharge as described in §112.1(b). The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system, such as a tank or pipe, will not escape the containment system before cleanup occurs. At a minimum, you must use one of the following prevention systems or its equivalent:

(1) For onshore facilities:

(i) Dikes, berms, or retaining walls sufficiently impervious to contain oil;

(ii) Curbing;

(iii) Culverting, gutters, or other drainage systems;

(iv) Weirs, booms, or other barriers;

(v) Spill diversion ponds;

(vi) Retention ponds; or

(vii) Sorbent materials.

(2) For offshore facilities:

112.7(d), If you determine that the installation of any of the structures or pieces of equipment listed in 40 CFR 112.7 (c) and (h)(1), and 112.8(c)(2), 112.8(c)(11), … to prevent a discharge as described in 112.1(b) from any onshore or offshore facility is not practicable, you must clearly explain in your Plan why such measures are not practicable; for bulk storage containers, conduct both periodic integrity testing of the containers and periodic integrity and leak testing of the valves and piping; and, unless you have submitted a response plan under 112.20, provide in your Plan the following:

(1) An oil spill contingency plan following the provisions of 40 CFR 109.

(2) A written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful.

112.7(e) Conduct inspections and tests required by this part in accordance with written procedures that you or the certifying engineer develop for the facility. You must keep these written procedures and a record of the inspections and tests, signed by the appropriate supervisor or inspector, with the SPCC plan for a period of three years. Records of inspections and tests kept under usual and customary business practices will suffice for purposes of this paragraph.

112.7(f) (1), At a minimum, train your oil-handling personnel in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and, the contents of the facility SPCC plan.

112.7(f) (2), Designate a person at each applicable facility who is accountable for discharge prevention and who reports to facility management.

112.7(f) (3), Schedule and conduct discharge prevention briefings for your oil-handling personnel at least once a year to assure adequate understanding of the SPCC plan for that facility. Such briefings must highlight and describe known discharges as described in §112.1(b) or failures, malfunctioning components, and any recently developed precautionary measures.

112.7(g)(1) Fully fence each facility handling, processing, or storing oil, and lock and/or guard entrance gates when the facility is not in production or is unattended.

112.7(g)(2) Ensure that the master flow and drain valves and any other valves permitting direct outward flow of the container’s contents to the surface have adequate security measures so that they remain in the closed position when in non-operating or non-standby status.

112.7(g)(3) Lock the starter control on each oil pump in the “off” position and locate it at a site accessible only to authorized personnel when the pump is in a non-operating or non-standby status.

112.7(g) (4) Securely cap or blank-flange the loading/unloading connections of oil pipelines or facility piping when not in service or when in standby service for an extended time. This security practice also applies to piping that is emptied of liquid content either by draining or by inert gas pressure.

112.7(g)(5) Provide facility lighting commensurate with the type and location of the facility that will assist in the:

(i) Discovery of discharges occurring during hours of darkness, both by operating personnel, if present, and by non-operating personnel (the general public, local police, etc.); and

(ii) Prevention of discharges occurring through acts of vandalism.

112.7(h)(1) Where loading/unloading rack drainage does not flow into a catchment basin or treatment facility designed to handle spills, use a quick drainage system for tank car or tank truck loading and unloading areas. You must design any containment system to hold at least the maximum capacity of any single compartment of a tank car or tank truck loaded or unloaded at the facility.

112.7(h)(2) Provide an interlocked warning light or physical barrier system, warning signs, wheel chocks, or vehicle brake interlock system in loading/unloading racks to prevent vehicles from departing before complete disconnection of flexible or fixed oil transfer lines.

112.7(h)(3) Prior to filling and departure of any tank car or tank truck, closely inspect for discharges the lowermost drain and all outlets of such vehicles, and if necessary, ensure that they are tightened, adjusted, or replaced to prevent liquid discharge while in transit.

112.7(i), If a field-constructed aboveground container undergoes a repair, alteration, reconstruction, or a change in service that might affect the risk of a discharge or failure due to brittle fracture or other catastrophe, or has discharged oil or failed due to brittle fracture failure or other catastrophe, evaluate the container for risk of discharge or failure due to brittle fracture or other catastrophe, and as necessary, take appropriate action.

112.7(j), In addition to the minimal prevention standards listed under this section, include in your Plan a complete discussion of conformance with the applicable requirements and other effective discharge prevention and containment procedures listed in this part or any applicable more stringent State rules, regulations, and guidelines.

Prohibition Against Oil Pollution

Report of Oil Spill or Discharge

Procedure for Removal

Oil Transfer License

Requirements for Above-Ground Oil Storage Facilities o o o o o o o

112.8(b)(1), Restrain drainage from diked storage areas by valves to prevent a discharge into the drainage system or facility effluent treatment system, except where facility systems are designed to control such discharge. You may empty diked areas by pumps or ejectors; however, you must manually activate these pumps or ejectors and must inspect the condition of the accumulation before starting, to ensure no oil will be discharged.

112.8(b) (2), Use valves of manual, open-and-closed design, for the drainage of diked areas. You may not use flapper-type drain valves to drain diked areas. If your facility drainage drains directly into a watercourse and not into an on-site wastewater treatment plant, you must inspect and may drain uncontaminated retained storm water, as provided in 112.8(c)(3)(ii), (iii), and (iv).

112.8(b) (3), Design facility drainage systems from undiked areas with a potential for a discharge (such as where piping is located outside containment walls or where tank truck discharges may occur outside the loading area) to flow into ponds, lagoons, or catchment basins designed to retain oil or return it to the facility. You must not locate catchment basins in areas subject to periodic flooding.

, If facility drainage is not engineered as in 112.8(b) (3), equip the final discharge of all ditches inside the facility with a diversion system that would, in the event of an uncontrolled discharge, retain oil in the facility.

Where drainage waters are treated in more than one treatment unit and such treatment is continuous, and pump transfer is needed, provide two “lift“ pumps and permanently install at least one of the pumps. Whatever techniques you use, you must engineer facility drainage systems to prevent a discharge as described in §112.1(b) in case there is an equipment failure or human error at the facility.

You must not use a container for the storage of oil unless its material and construction are compatible with the material stored and conditions of storage such as pressure and temperature.

, You must construct all bulk storage container installations so that you provide a secondary means of containment for the entire capacity of the largest single container and sufficient freeboard to contain precipitation. You must ensure that diked areas are sufficiently impervious to contain discharged oil. Dikes, containment curbs, and pits are commonly employed for this purpose. You may also use an alternative system consisting of a drainage trench enclosure that must be arranged so that any discharge will terminate and be safely confined in a facility catchment basin or holding pond.

You must not allow drainage of uncontaminated rainwater from the diked area into a storm drain or discharge of an effluent into an open watercourse, lake, or pond, bypassing the facility treatment system unless you:

(i) Normally keep the bypass valve sealed closed.

(ii) Inspect the retained rainwater to ensure that its presence will not cause a discharge as described in §112.1(b).

(iii) Open the bypass valve and reseal it following drainage under responsible supervision; and

(iv) Keep adequate records of such events, for example, any records required under permits issued in accordance with 40 CFR 122.41(j)(2) and 40 CFR 122.41(m)(3).

You must protect any completely buried metallic storage tank installed on or after January 10, 1974 from corrosion by coatings or cathodic protection compatible with local soil conditions. You must regularly leak test such completely buried metallic storage tanks.

You must not use partially buried or bunkered metallic tanks for the storage of oil, unless you protect the buried section of the tank from corrosion. You must protect partially buried and bunkered tanks from corrosion by coatings or cathodic protection compatible with local soil conditions.

You must test each aboveground container for integrity on a regular schedule, and whenever you make material repairs. The frequency of and type of testing must take into account container size and design (such as floating roof, skid-mounted, elevated, or partially buried). You must combine visual inspection with another testing technique such as hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or another system of non-destructive shell testing. You must keep comparison records and you must also inspect the container’s supports and foundations. In addition, you must frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices will suffice for purposes of this paragraph.

Table 13-1. Tank Testing Requirements Summary Tank ID Type of Installation Inspection & Testing

Requirements Previous Testing Testing Due

D-315 Field-erected 150,000-gallonAST

Formal external inspection by certified inspector every

5 years Formal internal inspection by certified inspector every

10 years

10/23/2018 Oct 2023 (E) Oct 2028 (I)

D-315 Piping Single-walled steel piping between Boiler

Plant and D-315

Inspect piping in accordance with API

Standard 570 to verify conformance and reaming wall thickness.

10/23/2018 Oct 2028

D-321.B Shop-fabricated 15,000-gallon AST

Formal external inspection by certified inspector every

20 years

Installed

D-321.C Shop-fabricated 15,000-gallon AST

Formal external inspection by certified inspector every

20 years

Installed

112.8(c)(7), You must control leakage through defective internal heating coils by monitoring the steam return and exhaust lines for contamination from internal heating coils that discharge into an open watercourse or pass the steam return or exhaust lines through a settling tank, skimmer, or other separation or retention system.

112.8(c) (8), You must engineer or update each container installation in accordance with good engineering practice to avoid discharges. You must provide at least one of the following:

(i) High liquid level alarms with an audible or visual signal at a constantly attended operation or surveillance station. In smaller facilities an audible air vent may suffice.

(ii) High liquid level pump cutoff devices set to stop flow at a predetermined container content level.

(iii) Direct audible or code signal communication between the container gauge and the pumping station.

(iv) A fast response system for determining the liquid level of each bulk storage container such as digital computers, telepulse, or direct vision gauges. If you use this alternative, a person must be present to monitor gauges and the overall filling of bulk storage containers.

(v) You must regularly test liquid level sensing devices to ensure proper operation.

112.8(c) (9), You must observe effluent treatment facilities frequently enough to detect possible system upsets that could cause a discharge as described in §112.1(b).

112.8(c) (10), You must promptly correct visible discharges which result in a loss of oil from the container, including but not limited to seams, gaskets, piping, pumps, valves, rivets, and bolts.

You must promptly remove any accumulations of oil in diked areas.

112.8(c) (11), You must position or locate mobile or portable oil storage containers to prevent a discharge as described in §112.1(b). You must furnish a secondary means of containment, such as a dike or catchment basin, sufficient to contain the capacity of the largest single compartment or container with sufficient freeboard to contain precipitation.

112.8(d)(1), Provide buried piping that is installed or replaced on or after August 16, 2002, with a protective wrapping and coating. You must also cathodically protect such buried piping installations or otherwise satisfy the corrosion protection standards for piping in 40 CFR 280 or a State program approved under 40 CFR 281. If a section of buried line is exposed for any reason, you must carefully inspect it for deterioration. If you find corrosion damage, you must undertake additional examination and corrective action as indicated by the magnitude of the damage.

112.8(d)(2), Cap or blank-flange the terminal connection at the transfer point and mark it as to origin when piping is not in service or is in standby service for an extended time.

112.8(d)(3), Properly design pipe supports to minimize abrasion and corrosion and allow for expansion and contraction.

112.8(d)(4), Regularly inspect all aboveground valves, piping, and appurtenances. During the inspection you must assess the general condition of items, such as flange joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces.

You must also conduct integrity and leak testing of buried piping at the time of installation, modification, construction, relocation, or replacement.

112.8(d)(5), Warn all vehicles entering the facility to be sure that no vehicle will endanger aboveground piping or other oil transfer operation

Table 14-1. VAMC Oil Loading/Unloading Procedures

When Loading/Unloading:

1. Ensure that both the tank and tanker truck are properly grounded.

2. Ensure that spill response materials are readily available.

3. Visually check condition of all equipment and piping to make sure all is normal before pumping.

4. Check fuel level of receiving tank to prevent overfilling. This can be done by utilizing one of the following methods:

a. Manually gauging (“sticking”) the tank;

b. Using a functional vent whistle;

c. Using an approved overfill alarm;

d. Inquiring about the capacity and contents of the tank with facility personnel; or

e. Using another method approved by MDE.

5. Document fuel level of receiving tank (in writing) and maintain records for 30 days.

6. Properly connect loading/unloading hose, making sure the connection is secure and tight.

7. Open suction (discharge) valve on pump.

8. Start pumping.

After Loading/Unloading:

1. Shutdown pump.

2. Close suction (discharge) valve on pump.

3. Visually check condition of all equipment and piping to make sure all is normal.

4. Check fuel level of receiving tank.

5. Check preloading volume and the supply slip to ensure appropriate amount of fuel was placed in tank.

6. Make sure all hoses have been properly disconnected, drained of any remaining oil, and stored.

7. Un-ground tanker.

8. Check for oil leaks and/or spills before departing.

9. In the event of an oil spill or leak immediately contact the Perry Point Fire Department (x22222), the GEMS Coordinator (x25227) or the Safety Program Manager (x26499).

Table 16-1. Emergency Contact Numbers Name Phone Number Primary Response Coordinator Jennifer Dallaire GEMS Coordinator

Office: (410) 642-2411 x25227 Home: (443) 206-9394

Alternate Response Coordinator (No. 1) Andrew Bannon Fire Chief

Office: (410) 642-2411 x25208 Cell: (443) 350-4492

Alternate Response Coordinator (No. 2) Mr. Robert Johnson Acting VAMHCS Emergency Manager

Office: (410) 642-2411 x26499 Cell: (443) 206-8222

VAMC Fire Department 22222 Safety Office (410) 642-2411 x26499

Table 16-2. State and Federal Agency Phone Numbers Agency Phone Number MDE 24-Hour Emergency Response Number (866) 633-4686 National Response Center (800) 424-8802 US EPA Region III, Emergency Response Center (215) 814-9016 US EPA Region III, Customer Service Hotline (800) 438-2474

Table 16-3. Other Important Phone Numbers Department Phone Number

Cecil County Department of Emergency Services (HAZMAT) (410) 392-2006

VAMC Police (410) 642-2411 x 21000

VAMC Drinking Water Treatment Plant 410-642-2411 x25918

MDE CWA Water Emergency Response

410-537-3510 (after hours: 866-MDE-GOTO)

Perryville Wastewater Treatment Plant (410) 642-6142

VAMHCS GEMS Coordinator or VAMHCS Emergency Manager:

Table 16.4. Spill Response Contractor Name Allstate Power Vac

Address 2931 Whittington Ave.

Baltimore, MD 21230

24-Hour Emergency No. 800-7-SPILLS (800-777-4557)

Telephone No. 410-368-9170

Fax No. 410-368-9171

EPA ID No. NJD003812047

Table 18-1. Location of VAMC Spill Response Equipment Location Item Quantity Type

Fire Department Oil Absorbent Media (30 gal container) 1 Absorbent Solvent Absorbent Pads 100 Absorbent

Spaghetti Boom (3 in x 10 ft) 5 Boom Spaghetti Booms (5 in x 10 ft) 3 Boom

Shag Sorb Absorbent Pads (18 in x 20 in) 20 Pad Spill Pad (16.5 in x 20 in) 125 Pad

Spaghetti Pillow (24 in x 24 in) 5 Pillow CPF 3 Chemical Suits 5 PPE

Latex Boot Covers 12 PPE Absorbent Socks (3 in x 4 ft) 20 Sock

Spaghetti Socks (10 in x 10 ft) 2 Sock Aluminum shovel 1 Tool Overpack drums 2 Tool

Plastic shovel 1 Tool Hazardous Waste Storage

Shed Oil Absorbent Pads (15 in x 150 ft) 3 Pad

Oil Absorbent Pads (22 in x 85’) 3 Pad HazMat Absorbent Pads (15 in x 150 ft) 2 Pad

Cellulose Absorbent (22 lb. bag) 2 Absorbent Oil Absorbent Media (46 qt bag) 2 Absorbent

Hazardous Material Neutralizing Kit (5 gal) 1 Neutralizer Overpack drum (110 gal) 1 Tool

Fence Northwest of Hazardous Waste Storage

Shed

Fire Extinguisher 1 Safety

Universal Waste Storage Shed

Mercury Spill Kit (5 gal) 1 Neutralizer

Bldg. 13H, Rm. 2 (Elevator Reservoir)

Oil Absorbent Media (bag) 1 Absorbent

Bldg. 80H (Elevator Reservoir)

Oil Absorbent Media (bag) 1 Absorbent

Bldg. 4R (Elevator Reservoir)

Oil Absorbent Media (bag) 2 Absorbent

REMRO Garage, SAA Shed Portable Spill Kit 1 Absorbent/PPE Boiler Plant Oil Absorbent Pads (16 in x 18 in) 450 Pad

Integrated Contingency Plan Perry Point, MD VA Medical Center October 2021 70

19.0 FACILITY UPGRADES

To ensure the VAMC is in conformance with the requirements of 40 CFR 112, the improvements summarized in Table 19-1 are required. Most of the improvements addressed in Table 19-1 are considered technical changes to infrastructure and operations that would require review from a Professional Engineer before this plan can be certified. Any new design or construction detailed will need to be reviewed by the engineer as part of the review and certification process for this plan.

Table 19 1. Summary of Required Facility Upgrades

Location Deficiency Upgrade Required Status

AST D 315 Observations of the containment berm showed signs of deterioration due to erosion and groundhog burrows, such that it may no longer be sufficiently impervious to contain a spill that could result from a catastrophic failure of the tank.

It is also recommended that the facility conduct a detailed visual inspection of the berm to identify defects. Perform repairs and rehabilitation of the berm as needed based on the findings of the inspection, analysis, and hydrostatic testing of the berm.

Design of the replacement tank farm and secondary containment are 99% completed. Verifying schedule for construction of replacement before this detailed inspection would be pursued.

A review of design documentation for the containment berm revealed that the berm includes a PVC liner; however, the integrity of the liner could not be assessed.

The integrity of this liner is crucial for the berm to remain sufficiently impervious.

Because the PVC liner cannot be visually inspected, it is recommended that the VAMC perform a hydrostatic test of the berm to determine how long it is capable of retaining liquid. Section 112.7(c) of 40 CFR states that the entire secondary containment system, “including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system...will not escape containment before cleanup occurs.” The rule does not specify permeability, hydraulic conductivity, or retention time performance criteria for these provisions (i.e., “sufficiently impervious” does not necessarily mean indefinitely impervious).

Instead, the owner/operator and/or the certifying PE have the flexibility to determine how best to design the containment system to prevent a discharge to navigable waters or adjoining shorelines.

Depending on schedule of replacement, the proposed hydrostatic testing and detailed visual inspection of the berm may still need to be scheduled.

A “Fitness for Continued Service Certificate” was issued for Tank D 315 on 29 January 2019.

Although the Certificate indicated that numerous repairs had been

The only two outstanding items called out as additional deficiencies are:

1. Tank coating. The tank exterior coating system has greatly

Design of the replacement tank farm and secondary containment are 99% completed. Verifying schedule for construction of replacement

October 2021 71

Table 19 1. Summary of Required Facility Upgrades

Location Deficiency Upgrade Required Status made to the tank and it had received approval for continued service, it identified several other miscellaneous items which are recommended to be repaired to the tank, such as coatings and level gauges. These repairs should be addressed in accordance with the inspector’s recommendations.

exceeded its service life. The rusting of its exterior must be brought under control by completely repainting.

Level gauges. There is no overfill control for this tank. The tank must be upgraded with both an overfill alarm set to trip at 90% full by volume and an automatic shutdown of the receiving pump when the tank reaches 95% full by volume. In addition, the tank does not have any level indicator that is visible from either inside the plant or at the receiving station. The balanced float system on the tank cannot be upgraded for these purposes.

prior to pursuit of inspector recommendations.

VA is awaiting funding for tank coating deficiency.

Although the VA has instituted a process for manually checking the level of fuel in the tank during filling operations, the recommended upgrades regarding the level gauge, shutoff, and alarm should be considered if the tank cannot be replaced in a timely manner.

In the interim, the VA must ensure that all filling operations are continuously monitored manually.

Various Oil Filled Operational Equipment

Provide equivalent protection for ASTs and oil filled operational equipment that lack adequate secondary containment. These include:

Single walled emergency generator day tanks (DT 311 and

DT 365)

Hydraulic elevator reservoirs for which the room/building do not provide adequate secondary containment (4R, 17H, 22H, 24H, and 80H)

Spill kits must be located at each of these areas, and any adjacent floor drains should be covered or otherwise protected. Ensure that each kit is equipped to adequately contain the potential spill volumeof the associated tank.

Reservoir 4R is located in a small room…