ICP_Baltimore FINAL-August 2020_SIGNED.pdf

DEPARTMENT OF VETERANS AFFAIRS

BALTIMORE

VETERANS AFFAIRS MEDICAL CENTER

INTEGRATED CONTINGENCY PLAN

Revision .0 |

Prepared by:

POTOMAC-HUDSON ENGINEERING, INC.

, Maryland | www.phe.com

VERSION 4.0

August 2020

Baltimore, MD Veterans Affairs Medical Center

INTEGRATED CONTINGENCY PLAN

Prepared by:

Potomac-Hudson Engineering, Inc.

Rockville, Maryland

Integrated Contingency Plan Baltimore VAMC August 2020 i

TABLE OF CONTENTS

Section/Title Page No.

TABLE OF CONTENTS................................................................................................... I

LIST OF FIGURES.......................................................................................................... V

LIST OF TABLES ..........................................................................................................VI

APPENDICES...............................................................................................................VII

ABBREVIATIONS AND ACRONYMS.........................................................................VIII

MANAGEMENT APPROVAL ........................................................................................ IX

REVIEW AND REVISION HISTORY .............................................................................. X

PROFESSIONAL ENGINEER’S REVIEW/CERTIFICATION ........................................XI

1.0 INTRODUCTION

1.1 Purpose

1.2 SPCC Plan Requirements

1.3 RCRA Contingency Plan Requirements

1.4 Facility’s Compliance with Rule Requirements

1.5 Cross Reference with SPCC Provisions

1.6 Plan Update and Amendment

1.7 Plan Location

1.8 Certification of the Applicability of the Substantial Harm Criteria Checklists

2.0 FACILITY OVERVIEW

2.1 Facility Name, Address and Location

2.2 Facility Operations

2.3 Facility Oil Storage (112.7(a)(3)(i))

2.4 Hazardous Waste Storage

2.5 Universal Waste Storage

August 2020 ii

3.0 POTENTIAL SPILL PREDICTIONS, VOLUMES, RATES, AND CONTROL

3.1 Hospital (Building 1)

3.2 Oil-Filled Operating Equipment

3.3 Underground Storage Tanks (USTs)

3.4 Drum Storage

3.5 Grease Storage

3.6 Hazardous and Universal Waste Storage

4.0 DRAINAGE PREVENTION, DIVERSIONARY STRUCTURES, AND

CONTAINMENT

5.0 IMPRACTICALITY OF SECONDARY CONTAINMENT

6.0 INSPECTIONS/RECORDKEEPING

7.0 PERSONNEL TRAINING AND SPILL PREVENTION PROCEDURES

7.1 Personnel Instructions

7.2 Designated Person

7.3 Spill Prevention Briefings

8.0 SITE SECURITY

8.1 Fencing and Gates

8.2 Flow and Drain Valves Secured

8.3 Starter Controls Secured

8.4 Pipeline Loading/Unloading Connections Secured

8.5 Lighting Adequate to Detect and Deter Spills

9.0 FACILITY TANK CAR LOADING/UNLOADING OPERATIONS

9.1 Tank Car and Truck Loading/Unloading Operations

9.2 Adequate Secondary Containment for Vehicles

9.3 Warning or Barrier System for Vehicles [40 CFR 112.7(e) (4) (iii)]

9.4 Vehicles Examined for Lowermost Drainage Outlets before Leaving

August 2020 iii

10.0 BRITTLE FRACTURE OR OTHER CATASTROPHE OF FIELD-

CONSTRUCTED TANKS

11.0 CONFORMANCE WITH OTHER APPLICABLE REQUIREMENTS

12.0 DRAINAGE CONTROL

12.1 Drainage from Diked Storage Areas

12.2 Valves Used on Diked Storage Areas

12.3 Plant Drainage Systems from Undiked Areas

12.4 Final Discharge of Drainage

12.5 Facility Drainage Systems and Equipment

13.0 BULK STORAGE CONTAINERS

13.1 Diked Area Inspection and Drainage of Rainwater

13.2 Corrosion Protection of Buried Metallic Storage Tanks

13.3 Corrosion Protection of Partially Buried Metallic Tanks

13.4 Aboveground Tank Periodic Integrity Testing

13.5 Control of Leakage through Internal Heating Coils

13.6 Liquid Level Sensing Devices

13.7 Observation of Disposal Facilities for Effluent Discharge

13.8 Visible Oil Leaks Corrected from Tank Seams and Gaskets

13.9 Appropriate Position of Mobile or Portable Oil Storage Tanks

14.0 FACILITY TRANSFER OPERATIONS

15.0 DESIGNATION OF RESPONSIBILITY

15.1 Safety Office/GEMS Coordinator

15.2 Shop Supervisor

15.3 VAMC Employees

16.0 CONTINGENCY PLAN

16.1 Key Responsibilities and Communication (40 CFR 109.5(a), (b) (2-3), and (d)(2-3)) ... 40

16.2 Spill Response Team (40 CFR 109.5(d) (1))

16.3 Critical Water Use Areas (40 CFR 109.5(b) (1))

16.4 Provisions for Spill Response (40 CFR 109.5(c))

16.5 Major Spill Response Procedures (40 CFR 109.5(b) (4) and (d) (4-5))

August 2020 iv

16.6 Minor Spill Response Procedures (40 CFR 109.5(d) (4-5))

16.7 Disposal of Contaminated Response Material

16.8 Spill Response Termination (40 CFR 109.5(e))

16.9 Spill Response Review (40 CFR 109.5 (d) (1)

16.10Spill Response Contractor

16.11Arrangements with Local Authorities

16.12Evacuation Plan

17.0 REPORTING

17.1 Federal Reporting

17.2 State Reporting

18.0 EMERGENCY RESPONSE EQUIPMENT

18.1 Testing and Maintenance of Emergency Equipment

19.0 FACILITY UPGRADES

August 2020 v

LIST OF FIGURES

Figure 2-1. Site Location Map

Figure 3-1. ASTs No. 1, 2 and 3 (Emergency Generator Room)

Figure 3-2. UST-1

Figure 3-3. Drum Storage Area

Figure 3-4. Grease Storage

Figure 16-1. Initial Spill Discovery and Response Flow Chart for Major Spill

Figure 16-2. Responsibilities for Major Spill

Figure A-1. UST, AST, and Waste Accumulation Location Plan .............................................. A-1

Figure A-2. Potential Spill Pathways and Piping for ASTs ........................................................ A-2

Figure A-3. Potential Spill Pathways and Piping for UST 1 and Diesel Fuel Drums ............... A-3

Figure A-4. Potential Spill Pathways for Hazardous Waste Storage .......................................... A-4

Figure A-5. Potential Spill Pathways for Universal Waste Storage ........................................... A-5

Figure A-6. Potential Spill Pathways for Grease Storage ........................................................... A-6

Figure A-7. Potential Spill Pathways for Electrical Transformers ............................................. A-7

Figure A-8. Potential Spill Pathways for Used Oil Drum .......................................................... A-8

August 2020 vi

LIST OF TABLES

Table 2-1. Aboveground Storage Tank Inventory

Table 2-2. Underground Storage Tank Inventory

Table 3-1. Potential Discharge From 300-Gallon Diesel Fuel ASTs (ASTs No. 1, 2, and 3)

Table 3-2. Inventory of Regulated Transformers

Table 3-3. Potential Discharge From UST-1

Table 3-4. Potential Discharge From Drum Storage Area

Table 3-5. Potential Discharge From Grease Drums

Table 14-1. VAMC Oil Loading/Unloading Procedures

Table 16-1. Emergency Response Numbers

Table 16-2. State and Federal Agency Phone Numbers

Table 16-3. Other Important Phone Numbers

Table 16-4. Spill Response Contractor

Table 18-1. Location of VAMC Spill Response Equipment

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APPENDICES

Appendix A Facility Diagrams and Spill Pathway Figures

Appendix B Inspection Records/Forms

Appendix C Training Records

Appendix D Spill Report Log Form/Records

Appendix E Substantial Harm Criteria Checklist

Appendix F Regulatory Requirements Summary and Cross-Reference Matrix

Appendix G 40 CFR 302.4 Table 302.4

Appendix H Summary of Hazardous Waste Accumulation and Storage Areas

Appendix I Arrangements with Emergency Responders

Appendix J RCRA Contingency Plan Quick Reference Guide

August 2020 viii

ABBREVIATIONS AND ACRONYMS

API American Petroleum Institute

AST Aboveground Storage Tank

ATG Automatic Tank Gauging

CAA Central Accumulation Area

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFR Code of Federal Regulations

CMU Concrete Masonry Unit

COMAR Code of Maryland Regulations

CWA Clean Water Act

EPCRA Emergency Planning & Community Right-To-Know Act

FRP Facility Response Plan

GEMS Green Environmental Management System

ICP Integrated Contingency Plan

LEPC Local Emergency Planning Committee

LQG Large Quantity Generator

MDE Maryland Department of the Environment

NFPA National Fire Protection Association

PE Professional Engineer

PEI Petroleum Equipment Institute

QRG Quick Reference Guide

RC Response Coordinator

RCRA Resources Conservation and Recovery Act

SAA Satellite Accumulation Area

SOP Standard Operating Procedure SPCC Spill Prevention, Control, and Countermeasure

USEPA United States Environmental Protection Agency

UST Underground Storage Tank

VAMC Veterans Affairs Medical Center

VAMHCS Veterans Affairs Maryland Healthcare System

August 2020 ix

MANAGEMENT APPROVAL

The 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 to this plan. This Integrated Contingency Plan (ICP) has the full approval of VA management. The VAMC has committed the necessary resources to implement the measures described in 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.

Date

Date

Date

Date

Mr. Robert Deinert Safety and Health Program Manager, VA Maryland Health Care System

Mr.

Chief, Facilities and Engineering

Service, VA Maryland Health Care System

12/2/2020

1/21/2021

1/21/2021

Robert W.

Deinert 458787

Digitally signed by Robert W. Deinert 458787 Date: 2020.12.02 07:54:48 -05'00'

ADAM S LETKE

180749

Digitally signed by ADAM S

LETKE 180749

Date: 2021.01.21 10:41:02 -05'00'

MATTHEW S.

ORENSTEIN 729739

Digitally signed by MATTHEW

S. ORENSTEIN 729739

Date: 2021.01.21 12:07:20 ______________________________-05'00'

Mr.

Associate Director

VA Maryland Health Care System

VA Maryland Health Care System Director

August 2020 x

REVIEW AND REVISION HISTORY

A review and evaluation of this ICP is conducted at least once every 5 years. As a result of this review and evaluation, the VAMC will amend the plan to include more effective prevention and control technology if: (1) such technology will significantly reduce the likelihood of a spill event from the facility, and (2) if such technology has been field-proven at the time of review.

This plan will also be amended within 6 months after a change in the facility design, construction, operation, or maintenance occurs which materially affects the facility’s potential for the discharge of oil into or upon the navigable waters of the United States or adjoining shorelines.

Any technical amendment to this plan shall be certified by a Professional Engineer.

Record of Revisions

VERSION

NUMBER

DATE OF

REVISION

SECTION NUMBERS REVISED

(Comments) DATE ENTERED

1.0 August 2006 Original ICP Developed October 2006

2.0 December 2012 Updated hazardous and universal waste

operations; updated diagrams January 2013

3.0 October 2017

Updated hazardous and universal waste operations; updated diagrams; updated location of grease storage; added Quick

Reference Guide

October 2017

4.0 July 2020 Updated hazardous and universal waste

operations; minor administrative changes. July 2020

NOTE: Anyone may propose changes to the Plan. All changes are reviewed for final publication. Proposed changes and information updates should be hand-delivered to the VAMHCS Safety office.

August 2020 1

1.0 INTRODUCTION

1.1 Purpose

The purpose of this Integrated Contingency Plan (ICP) is to establish procedures, methods, and equipment requirements to prevent the discharge of oil and hazardous waste/material from non-transportation-related onshore and offshore facilities into or upon the navigable waters of the United States or adjoining shorelines. This document fulfills the following requirements:

Spill Prevention Control and Countermeasures (SPCC) Plan required by Title 40 Code of Federal Regulations (CFR) Part 112 (40 CFR 112) Resource Conservation and Recovery Act (RCRA) Contingency Plan required by 40 CFR Actions under the National Contingency Plan as required by 40 CFR 300 Area Contingency Plan required by the Oil Pollution Act of 1990 and Executive Order 12777 Code of Maryland Regulations (COMAR) 26.10.01.12 (Requirements for Above-Ground Oil Storage Facilities) and 26.13.05.04 (Contingency Plan and Emergency Procedures)

1.2 SPCC Plan Requirements

As defined by 40 CFR Part 112, Oil Pollution Prevention, oil includes all grades of motor oil, hydraulic oil, lube oil, fuel oil, gasoline and diesel fuel, automatic transmission fluid, waste oil, and transformer mineral oil. The definition of oil also includes non-petroleum oils such as animal oils, vegetable oils, and synthetic oils. Any facility with more than 1,320 gallons of oil stored aboveground is subject to the requirements of 40 CFR 112. The federal regulations were promulgated by the United States Environmental Protection Agency (USEPA) under the authority of Section 311(j)(1)(c) of the Clean Water Act (CWA), as amended by the Oil Pollution Prevention Act of 1990. The Oil Pollution Prevention Act establishes the requirements for SPCC Plans to prevent spills of oil by non-transportation-related on-shore facilities into waters of the United States or adjoining shorelines.

As applicable to the VAMC facility, 40 CFR 112.1 (General applicability and notification) states that the regulations apply to:

“Any owner or operator of a non-transportation-related onshore or offshore facility engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using, or consuming oil and oil products, which due to its location, could reasonably be expected to discharge oil in quantities that may be harmful, as described in part 110 of this chapter, into or upon the navigable waters of the United States or adjoining shorelines...” [Emphasis added].

On December 5, 2008, the Federal Register published USEPA's amendments to the SPCC rule in order to provide increased clarity, to tailor requirements to particular industry sectors, and to streamline certain requirements for those facility owners or operators subject to the rule, which should result in greater protection to human health and the environment. The December 5, 2008, amendments became effective on January 14, 2010.

The USEPA has promulgated regulations requiring the reporting of releases of Hazardous Substances (under the Comprehensive Environmental Response, Compensation, and Liability Act

August 2020 2

[CERCLA] in 40 CFR 302), Extremely Hazardous Substances (under Emergency Planning & Community Right-To-Know Act [EPCRA] in 40 CFR 355), and petroleum products under the CWA and associated SPCC plans. The procedures for determining when a reportable release has occurred and notifying the appropriate agencies are described in Section 17.0 of this plan.

This ICP provides guidance on the following key actions that VA must perform to comply with the SPCC rule:

Complete monthly and annual site inspections as outlined in the Inspection and Recordkeeping section of this plan (Section 6.0) using the inspection checklists included in Appendix B.

Perform preventive maintenance of equipment, secondary containment systems, and discharge prevention systems described in this plan as needed to keep them in proper operating condition.

Conduct annual employee training as outlined in the Personnel Training section of this plan (Section 7.0) and document training events on the log included in Appendix C.

Review the plan on an annual basis. Update the ICP to reflect any “administrative changes” that are applicable, such as personnel changes or revisions to contact information, including phone numbers. All changes must be documented in the plan review log, as discussed in Section 1.5 of this plan, but do not have to be certified by a Professional Engineer (PE).

Review the plan at least once every 5 years and amend it to include more effective prevention and control technology, if such technology will significantly reduce the likelihood of a spill event and has been proven effective in the field at the time of the review. Plan amendments, other than administrative changes, must be recertified by a PE in accordance with the requirements addressed in Section 1.5 of this plan.

Amend the plan within 6 months of a change in facility design, construction, operation, or maintenance that materially affects the facility’s spill potential. The revised plan must be recertified by a PE.

Submit the plan to the USEPA Region 3 Regional Administrator and the Maryland Department of the Environment (MDE), along with other information as detailed in Section

6.11 of this plan, if either of the following occurs:

o The facility discharges more than 1,000 gallons of oil into or upon the navigable waters of the United States or adjoining shorelines in a single spill event; or o The facility discharges oil in a quantity greater than 42 gallons in each of two spill events within any 12-month period.

1.3 RCRA Contingency Plan Requirements

The Code of Maryland Regulations (COMAR) Chapter 26.13.05 requires generators of hazardous waste to maintain and operate facilities, and to maintain a contingency plan and emergency procedures to minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water. These requirements apply to all facilities in Maryland that generate at least 100 kilograms of hazardous

August 2020 3 waste each month. One element of the regulations (COMAR 26.13.05.04(C)(2)) allows owners or operators with an existing SPCC Plan to incorporate the hazardous waste management provisions required by the State into the SPCC Plan. The combined plan is called an Integrated Contingency Plan (ICP). This ICP has been written to satisfy the state requirements for the storage of hazardous waste. These requirements are identical to those in 40 CFR 262, Subpart D (RCRA Contingency Plan), only requiring additional notification to the MDE.

This plan has been developed to incorporate the Contingency Plan requirements under COMAR

16.13.05 and 40 CFR 262, Subpart M (as referenced from 262.17(a)(6)). In accordance with these regulations, the contingency plan must address the following elements:

Emergency procedures that facility personnel must take in response to fires, explosions, or any release of hazardous waste to air, soil, or surface water. Section 16 of this plan details the emergency procedures that would be followed in the event of an emergency.

A coordinated emergency services plan agreed to by local police departments, fire departments, hospitals, contractors, and state and local emergency response teams. The VA has coordinated with the Baltimore City Fire and Police Departments in regard to emergency response.

A list of emergency coordinators that includes names, addresses, and phone numbers (office and home/cell) of all personnel qualified to act as emergency coordinators. Section 16 of this plan lists the emergency coordinator and alternates.

A list of emergency equipment (such as fire extinguishing systems, spill control equipment, communications and alarm systems, and decontamination equipment), where the equipment is required. Section 18 of this plan lists the emergency response equipment that is maintained to address spills of oil and hazardous waste.

An evacuation plan where there is a possibility evacuation could be necessary, including signals to be used to begin evacuation, evacuation routes, and alternate routes. The VAMC’s evacuation plan is discussed in Section 15.5 of this plan.

A “quick reference guide” of the RCRA-related aspects of the ICP that is designed to provide easy access for emergency responders to the most critical information during an immediate response to an event. This is discussed in Section 15.4 of this plan and included as Appendix J.

Documentation of arrangements made with, or attempted to be made with, applicable local emergency responders as discussed in Section 15.4 of this plan. Documentation of these arrangements is provided in Appendix I.

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1.4 Facility’s Compliance with Rule Requirements

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.

This plan conforms to the requirements listed in 40 CFR Part 112, except for the additional facility procedures and upgrades that are summarized in Section 19.0 of this plan.

1.5 Cross Reference with SPCC Provisions

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.

This plan does not follow the exact order presented in 40 CFR 112. Section headings identify, where appropriate, the relevant section(s) of the SPCC rule. Table F-1, in Appendix F, presents a cross-reference of plan sections relative to applicable parts of 40 CFR Part 112.

1.6 Plan Update and Amendment

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).

Pursuant to 40 CFR 112.5, the VAMC will comply with the revision requirements listed in this section. The plan will be amended when there is a “change in facility design, construction, operation, or maintenance that materially affects the facility’s potential to discharge oil.” A Professional Engineer must certify these types of changes before they go into effect. Such changes include, but are not limited to:

Commissioning or decommissioning of tanks;

Replacement, reconstruction, or movement of tanks;

Reconstruction, replacement, or installation of piping systems;

August 2020 5

Construction or demolition that might alter secondary containment structures; or

Revision of standard operation or maintenance procedures at the facility.

In addition to revising the plan to compensate for physical or procedural changes, the VAMC will “complete a review and evaluation of the SPCC plan … five years from the date your last review was required under [40 CFR 112(b)].” As a result of this review and evaluation, the plan will be amended (within six months) to include more effective prevention and control technology if such technology:

Will significantly reduce the likelihood of a spill; and

Has been field-proven at the time of the review.

The contact list and phone numbers provided in this document (see Section 16.0) will be updated when necessary (and at least every five years). Keeping the contact list current will be the responsibility of the Facilities and Engineering Services office. Changes to the contact list do not have to be reviewed or certified by a Professional Engineer.

The facility’s management, and a Professional Engineer when necessary, will approve the VAMC ICP, and any revisions.

1.7 Plan Location

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.

In accordance with 40 CRF 112.3 (e), a complete copy of this ICP is maintained at the Facilities and Engineering Services office. This office is occupied during normal business hours. A copy is also maintained by each of the following VA representatives:

Medical Center Director;

Chief Engineer;

VAMHCS Emergency Manager;

Mechanical Shop (Plumbing) Foreman;

Electrical Shop Foreman; and

Police Department

1.8 Certification of the Applicability of the Substantial Harm Criteria Checklists The VAMC does not store more than 1,000,000 gallons of oil and does not have the potential to cause substantial harm based on the criteria in Attachment E-II in Appendix E of 40 CFR 112.

The completed Substantial Harm Criteria Checklist is included in Appendix E. This facility does not have a high potential to cause injury to an environmentally sensitive area or shut down a public drinking water intake. Therefore, the facility is not subject to the Facility Response Plan (FRP) requirements in 40 CFR 112.20 and 112.21 and is not required to prepare an FRP.

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2.0 FACILITY OVERVIEW

40 CFR 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.

2.1 Facility Name, Address and Location

FACILITY NAME: Veterans Affairs Medical Center

MAILING ADDRESS: 10 North Greene Street Baltimore, MD 21201

FACILITY STREET

ADDRESS: 10 North Greene Street

Baltimore, MD 21201

TELEPHONE: (410) 642-2411 x 25227

OWNER: U.S. Department of Veterans Affairs

CONTACT NAME: Jennifer Dallaire, VA Maryland Health Care System (VAMHCS) Green Environmental Management System (GEMS) Coordinator

LOCATION: The Baltimore VAMC is located at 10 North Greene Street, at its intersection with West Baltimore Street, in the city of Baltimore, MD. The VAMC is located next to the University of Maryland Medical Center with a walkway connecting both facilities.

FACILITY DESCRIPTION: The Baltimore VAMC is the acute medical and surgical care facility for the VAMHCS and offers a full range of inpatient, outpatient and primary care services. The facility offers veterans state-of-the-art medical technology, clinical services and research programs.

TOTAL BULK STORAGE: The VAMC operates three, 300-gallon aboveground storage tanks (ASTs) and one, 10,000-gallon underground storage tank (UST) that provide diesel fuel for the emergency generators. The VAMC also maintains 11 oil-filled electrical transformers and several 55-gallon drums of new and used oil. The total bulk aboveground storage for the facility is approximately 3,532 gallons.

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The VAMC campus is located at 10 North Greene Street, within the northwest quadrant of the intersection of Green and Baltimore Streets, in downtown Baltimore, MD (see Figure 2-1). The VAMC occupies approximately 2.7 acres of land within a single approximate 625,000 square foot building. The facility is located in a densely populated business and commercial area, development of which dictates local and surrounding topographic relief. The subject site elevations range from approximately 76 feet above mean sea level near the northeast corner, sloping down to the southwest to approximately 58 feet above mean sea level. The geographic coordinates for the VAMC are 39° 71’ 23” latitude and 76° 37’ 14” longitude. These coordinates correspond to the center of the hospital building.

Figure 2-1. Site Location Map

2.2 Facility Operations

The VAMC is a Department of Veterans Affairs medical facility that is comprised of a single eight-story hospital facility. VAMC operations involving oil are limited to the storage and use of diesel fuel for fueling the emergency generators, grease from the cafeteria, limited drum storage of diesel fuel and antifreeze, and oil-filled operational equipment (i.e., electrical transformers).

The VAMC is not involved in any oil production, drilling, or work over operations.

Hazardous waste generation at the VAMC is comprised of unusable or expired facility maintenance chemicals, waste laboratory and maintenance shop chemicals, clinical and research lab hazardous waste, clinical hazardous wastes, expired pharmaceuticals, hygiene chemicals, and

North

August 2020 8 waste building material. The Baltimore VAMC is registered as a Large Quantity Generator (LQG) of hazardous waste under EPA ID Number MDD985422518. Hazardous waste is stored in the hazardous waste storage room (BB-134) in the basement level of the southwest corner of the building, as depicted on Figure A-1, prior to shipment for off-site disposal. The VAMC does not self-transport or package for transport any hazardous waste.

2.3 Facility Oil Storage (112.7(a)(3)(i))

40 CFR 112.7(a) (3) (i), You must also address in your Plan the type of oil in each container and its storage capacity.

40 CFR 112.8(c) (8), Engineer or update each container installation in accordance with good engineering practices to avoid discharges. You must provide a liquid level sensing device.

Facility oil storage is summarized in Table 2-1 for ASTs within the facility. As applicable, tank information provided in this table includes location, contents, overfill protection, containment and capacity of each tank. Table 2-2 summarizes the oil storage in USTs. The locations of each of the ASTs and UST are depicted in Figure A-1 in Appendix A. Each of the ASTs and USTs are described in detail in the following sections and all tank locations are shown in the Figures A-2 and A-3 provided in Appendix A.

Table 2-1. Aboveground Storage Tank Inventory Tank No. Location Capacity

(gallons) Product High-Level

Alarm Containment and Spill Control

Features AST 1 8th floor, Room 8A-101 300 Diesel Fuel No None

AST 2 8th floor, Room 8A-101

300 Diesel Fuel No None

AST 3 8th floor, Room 8A-101

300 Diesel Fuel No None

Total Volume 900

Table 2-2. Underground Storage Tank Inventory Tank No. Location Capacity

(gallons) Product High-Level

Alarm Containment and Spill Control

Features UST 1 Southeast exterior corner at intersection of North Greene St. and West

Baltimore St.

10,000 Diesel Fuel No Double-walled polyurethane coated steel

Total Volume 10,000

2.4 Hazardous Waste Storage

The VAMC generates and accumulates hazardous waste within multiple satellite accumulation areas (SAAs) located throughout the facility. A summary table listing all SAAs onsite is included in Appendix H.

August 2020 9

The VAMC also maintains one 90-day central accumulation area (CAA) for the onsite storage of hazardous waste prior to offsite shipment. The CAA is located within Room BB134 near the southeast corner of the building as depicted on Figure A-1 of Appendix A. The approximate 120-square-foot storage room is constructed of concrete masonry unit (CMU) walls and concrete floor with an approximate three-and-half-inch berm at the entrance door. Hazardous waste accumulated in satellite accumulation areas (SAAs) throughout the building are brought to this room prior to transport offsite. The amount of waste stored in this room must be limited such that adequate aisle space is maintained to facilitate the weekly inspections.

Spill response equipment, which includes hazardous waste spill control media and granular absorbent, is stored within the CAA. The CAA is locked at all times. Signage has been posted with emergency contact telephone numbers. Telephone access at the CAA is available through personal cell phones, which employees are encouraged to carry with them at all times, or via a landline located throughout the building.

A potential spill or release that escapes from the CAA would flow to the north to a hydraulic lift basin located approximately 10 feet to the north as depicted on Figure A-4 in Appendix A.

2.5 Universal Waste Storage

The VAMC collects and stores universal waste batteries in several different areas of the facility, including at the Hazardous Waste CAA. Universal waste fluorescent light ballasts and batteries are stored in Room BD-118. Universal waste fluorescent light tubes (FLTs) are stored in Room 7D-100E, centrally located within the northern third of the seventh floor. Access to Room 7D-100E is limited to facility maintenance staff. The location of the universal waste storage areas are depicted on Figure A-1 of Appendix A. A potential spill or release from the universal waste FLTs storage could flow to a centrally located floor drain as depicted on Figure A-5 in Appendix A.

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3.0 POTENTIAL SPILL PREDICTIONS, VOLUMES, RATES, AND CONTROL

40 CFR 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.

Potential failures that could result in a discharge of oil from the VAMC are discussed in this section. In the event of a release, potential discharge directions, rates, and volumes for bulk storage containers with capacities greater than 55 gallons are described in this section.

The VAMC is situated near the southern tip of a small ridge trending north to south. Topographical relief in the area of the VAMC is gentle with local topography sloping to the southwest. Surface drainage in the area of the VAMC discharges to the southwest toward the Baltimore Harbor located approximately 1 mile due south and 0.75 mile to the southeast.

The VAMC lies along the boundary of two physiographic provinces; that is, areas in which the rocks and topography are similar throughout, and which differ considerably from those of the neighboring provinces. These provinces are, from east to west, the Western Shore Lowlands Region of the Coastal Plain and the Upland Section of the Piedmont Plateau. The portion of the Piedmont Plateau in which the VAMC is located is comprised of gently rolling terrain of low relief to very hilly topography, distinctive broad-bottomed valleys underlain by marble, and major streams incised into narrow, steep-sided valleys. The Coastal Plain province in the area of the VAMC is marked by a series of low fluvial and estuarine terraces, beaches, and drowned river mouths that fringe the Western Shore Uplands. The VAMC is underlain by the Middle River Lowland Formation which is composed of a relatively featureless lowland along the northwest shore of the Chesapeake Bay. The region has a very irregular coastline formed by the flooded mouths of the Bush, Gunpowder, Middle, Back, and Patapsco Rivers.

The surface water influx to the site is comprised solely of rainfall, as no surface water bodies enter the site. According to the National Weather Service, the annual precipitation at the site is approximately 41.9 inches based upon data collected from 1871 to 2019. The site hydrology is controlled by its topographic relief and impervious surface composition. Most stormwater runoff from the site flows east to west and north to south along drainage channels created by manmade structures that discharge to a separate storm sewer operated by the Baltimore City Bureau of Water and Wastewater. The stormwater sewer system ultimately discharges to Baltimore Harbor, located approximately 0.75 mile southeast of the VAMC. A discharge of oil from the VAMC that is not contained at the site of the spill could flow into the stormwater sewer system.

The remainder of this section provides an analysis of discharge scenarios for oil storage containers (55 gallons and larger) located at the VAMC. In addition, the remaining subsections summarize the potential types of equipment failure for the highest-risk oil and hazardous waste storage containers across the facility. As applicable, information provided in this section includes oil and hazardous waste storage container location, type of potential failure, release rate, surface receptor and spill direction, and containment.

3.1 Hospital (Building 1)

The VAMC maintains three, 300-gallon single-walled diesel fuel ASTs (ASTs No. 1, 2, and 3) located within the emergency generator room (Room 8A-101) on the eighth floor. These ASTs

August 2020 11 serve as day tanks that provide fuel for the adjacent emergency generators, which are used for both emergency power during outages and as an additional power source during periods of high demand. There is no integral secondary containment provided for these ASTs. The emergency generator room serves as secondary containment when floor drains are appropriately blocked.

Figure 3-1. ASTs No. 1, 2 and 3 (Emergency Generator Room)

The ASTs are supplied by a 10,000-gallon UST located exterior to the southeast corner of the facility. Potential failures that could occur in the area of the ASTs are listed in Table 3-1. The expected spill route of the released material at this location is shown on Figure A-2, Appendix A.

Table 3-1. Potential Discharge From 300-Gallon Diesel Fuel ASTs (ASTs No. 1, 2, and 3)

Tank ID Potential Event

Discharge Direction Spill Rate

Volume Discharged

(gallons)

Secondary Containment and Control

AST 1

Tank Rupture

To two nearby floor drains Instantaneous 300

Block floor drains and use absorbent media and booms to control spill and recover fuel.

Tank Leakage

To two nearby floor drains 1 gal/min 300

Tank Overfill To two nearby floor drains 50 gal/min 500

AST 2

Tank Rupture

To a nearby floor drain Instantaneous 300

Tank Leakage

To a nearby floor drain 1 gal/min 300

Tank Overfill To a nearby floor drain 50 gal/min 500

AST 3

Tank Rupture

To a nearby floor drain Instantaneous 300

Tank Leakage

To a nearby floor drain 1 gal/min 300

Tank Overfill To a nearby floor drain 50 gal/min 500

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Design drawings for the AST and UST system were previously provided by the engineering department. According to the drawings, which are more than 30 years old, a float control activates the pump and the solenoid valve so that fuel is pumped to each AST (AST-1, AST-2, and AST-3) from the UST. The VAMC must perform routine maintenance and inspections on the float valve and solenoid valve in accordance with the manufacturer’s recommendations. For the solenoid valve, this means routine inspection and replacement on a designated frequency/schedule; for the float control, it should include inspection on annual basis and routine replacement The system is equipped with overflow piping that would result in product being sent back to the UST in the event of an overfill.

3.2 Oil-Filled Operating Equipment

The VAMC has oil-filled operational equipment comprised of electrical transformers that are regulated under 40 CFR 112 because they are oil-filled and 55 gallons or larger in size. The SPCC regulations allow owners and operators of facilities with regulated oil-filled operational equipment the option of preparing an Oil Spill Contingency Plan and a written commitment of manpower, equipment, and materials to expeditiously control and remove any oil discharged without having to make an individual impracticability determination as required in 40 CFR 112.7(d). If an owner or operator chooses this option, an inspection or monitoring program must be established (and documented) to detect equipment failure and/or a discharge in lieu of providing secondary containment.

The general containment requirements in 40 CFR 112.7 require that one of the following types of containment and/or diversionary structures or equipment be provided to prevent discharged oil from reaching a navigable watercourse:

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

Curbing;

Culverting, gutters, or other drainage systems;

Weirs, booms, or other barriers;

Spill diversion ponds; or Sorbent materials.

The VAMC has implemented an Oil Spill Contingency Plan (see Section 16.0) and also requires that the general containment requirements are met for all oil-filled operating equipment to the greatest extent practicable. In addition, the VAMC’s inspection program (see Section 6.0) addresses oil-filled operating equipment.

Table 3-2 lists all regulated electrical transformers. These containers are also shown on Figure A-1.

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Table 3-2. Inventory of Regulated Transformers Transformer ID Location Substance Quantity

(gallons) M163075 8th floor, Room 8D101 Dielectric Fluid 235 M163074A 8th floor, Room 8D101 Dielectric Fluid 226 M163074B 8th floor, Room 8D101 Dielectric Fluid 226 M163073H 1st floor Parking Garage, Room 1PD-101 Dielectric Fluid 195 M163073G 1st floor Parking Garage, Room 1PD-101 Dielectric Fluid 195 M163073A 1st floor Parking Garage, Room 1PA-101 Dielectric Fluid 195 M163073B 1st floor Parking Garage, Room 1PA-101 Dielectric Fluid 195 M163073C 1st floor Parking Garage, Room 1PB-101 Dielectric Fluid 195 M163073D 1st floor Parking Garage, Room 1PB-101 Dielectric Fluid 195 M163073E 1st floor Parking Garage, Room 1PC-100 Dielectric Fluid 195 M163973H 1st floor Parking Garage, Room 1PC-100 Dielectric Fluid 195

Total Volume 2,247

3.3 Underground Storage Tanks (USTs)

The VA operates one UST (see Table 3-3) that is not subject to SPCC requirements since it is regulated under federal and Maryland UST programs. The UST is constructed of double-walled polyurethane coated steel and is monitored via a Veeder Root automatic tank gauging (ATG) system for release detection. New subsurface, unsafe suction lines were installed between the UST and pumps in Room BA-115 in 2018. This piping is double-walled.

Spills that could be associated with the UST would most likely result from oil transfer operations.

Therefore, Table 3-3 summarizes potential spill pathways that would result from either the overfilling of the UST or the release of fuel from the fuel delivery vehicle. The potential spill pathway associated with the UST is depicted on Figure A-3 in Appendix A.

Figure 3-2. UST-1

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Table 3-3. Potential Discharge From UST-1

Potential Event Discharge Direction Spill Rate Volume Discharged

Secondary Containment and Control

UST overfill or leakage during fueling

East along West Baltimore St. to storm drains located along West Baltimore St.

and on Arch St. near its intersection with West Baltimore St.

Gradual to instantaneous 500 gal.

Use spill kit, temporary berms, or soil to divert flow from storm drains. Place covers over storm drains.

3.4 Drum Storage

A fuel supply pump for transferring diesel fuel from UST 1 to the 300-gallon ASTs on the eighth floor is located within room BA-115 near the southeast corner of the VAMC. Diesel fuel that is drained or collected from the pump during maintenance is collected in three 55-gallon drums. The location and the spill pathways of the drums are depicted in Figure A-3 in Appendix A.

The drums are located on a spill pallet approximately 20 feet from a floor drain. Spills that could be associated with the diesel fuel drums would most likely result from small spills during filling or retrieval.

Figure 3-3. Drum Storage Area (BA-115)

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Table 3-4. Potential Discharge from Drum Storage Area

Potential Event Discharge Direction Spill Rate Volume

Discharged (gallons)

Secondary Containment and Control

Drum tipping North approximately 20 feet to a floor drain Instantaneous 55 Spill pallet and spill kit

Drum leakage North approximately 20 feet to a floor drain <1 gal./min. 30* Spill pallet and spill kit

Spills during filling or emptying North 5 to 10 feet Instantaneous 5 Spill pallet and spill kit

*Based on observed and reported amount typically generated and stored during routine maintenance operations.

In addition to the above, one 55-gallon plastic drum of used oil is stored on the 7th floor in Room 7A-101. The drum is stored on a spill containment pallet. The most likely release would occur from tipping. The oil would most likely enter a floor drain located approximately 10 feet from it.

Figure 3-4. Used Oil Drum

Table 3-5. Potential Discharge from Drum Storage Area

Potential Event Discharge Direction Spill Rate Volume

Discharged (gallons)

Secondary Containment and Control

Drum tipping Across room approximately 10 feet to a floor drain

Instantaneous 55 Spill pallet and spill kit

Drum leakage Across room approximately 10 feet to a floor drain

<1 gal./min. 30 Spill pallet and spill kit

Spills during filling or emptying

Across room approximately 10 feet to a floor drain Instantaneous 5 Spill pallet and spill kit

August 2020 16

3.5 Grease Storage

The cafeteria stores grease in three, steel, 55-gallon drums. Grease is collected in containers and poured or funneled into the 55-gallon drums. The grease is then picked up by a grease recycling contractor. The location and the spill pathways of the drums can be seen in Figure A-6 in Appendix A.

The drums are located in the main loading dock area adjacent to the trash compactor. Spills that could be associated with the grease drums would most likely result from filling or retrieval operations and would flow to the east to the trench drain located along the lowest part of the loading dock ramp area.

Figure 3-5. Grease Storage

Table 3-6. Potential Discharge From Grease Drums

Potential Event Discharge Direction Spill Rate Volume

Discharged (gallons)

Secondary Containment and Control

Drum Tipping East approximately 8 feet to trench drain that drains to storm sewer

Instantaneous 55 Spill pallet and spill kit.

Drum Leakage East approximately 8 feet to trench drain that drains to storm sewer

<1 gal./min. 10 Spill pallet and spill kit.

Spills during filling or emptying

East approximately 8 feet to trench drain that drains to storm sewer

Instantaneous 5 Spill pallet and spill kit.

3.6 Hazardous and Universal Waste Storage

Long-term storage (up to 90 days) occurs within Room BB-134 near the southeast corner of the building on the basement level. A spill or release in this area would be contained entirely within the room due to the presence of a berm at the entrance door.

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Long-term storage of universal waste FLTs occurs with Room 7D-100E (7th floor) while batteries are stored in BB-134 and ballasts are stored in BD-115. Universal waste FLTs and ballasts are stored in closed containers and protected from breakage. Batteries are stored on secondary containment pallets; releases of acid from batteries would be contained within the pallets.

August 2020 18

4.0 DRAINAGE PREVENTION, DIVERSIONARY STRUCTURES, AND

CONTAINMENT

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:

The ASTs, drum storage areas, and waste storage areas are located inside the hospital. All drums are stored on spill pallets. The rooms in which the ASTs, hazardous/universal waste, diesel fuel drums, and parking level electric transformers are located provide secondary containment when floor drains are blocked. The hazardous waste storage area and, with the exception of room 1PD- 102, the parking level electrical transformer rooms are equipped with berms at the entrances which increase the overall containment volume of the rooms. There are no floor drains in the hazardous waste storage room.

The VAMC ASTs are located indoors with no open, integrated secondary containment. As such, there is no discharge of accumulated stormwater.

Secondary containment at storage and transfer sites is designed to help control any discharge and hold most spills on site. The diesel fuel ASTs, waste storage areas, and electrical transformers are located inside the VAMC building. As such, secondary containment is provided by the rooms in which they are located as long as the floor drains are adequately blocked. In addition, sorbent materials (spill kits) are stored in the electrical transformer rooms and near the 300-gallon diesel fuel ASTs. Hazardous material neutralizing spill kits are maintained in the hazardous waste storage room in the event of a discharge. Due to the terrain, the distance to the nearest body of water, and because the facility is continually manned, there is sufficient time to contain and collect a discharge.

August 2020 19

5.0 IMPRACTICALITY OF SECONDARY CONTAINMENT

40 CFR 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…