ICP_Loch Raven VAMC FinalAugust2020_v6r1eSigsreducedAD sign - SIGNED.pdf

DEPARTMENT OF VETERANS AFFAIRS

LOCH RAVEN

VETERANS AFFAIRS MEDICAL CENTER

SPILL PREVENTION CONTROL AND

COUNTERMEASURES PLAN

Revision 4.0 | August 2020

Prepared by:

POTOMAC-HUDSON ENGINEERING, INC.

Rockville, Maryland | www.phe.com http://www.phe.com/

Loch Raven

Veterans Affairs Medical Center

INTEGRATED CONTINGENCY PLAN

Baltimore, Maryland

Prepared by:

Potomac-Hudson Engineering, Inc.

Rockville, Maryland

August 2020

Integrated Contingency Plan

Loch Raven VAMC

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TABLE OF CONTENTS

Section/Title Page No.

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

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

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

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

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

3.0 POTENTIAL SPILL PREDICTIONS, VOLUMES, RATES, AND CONTROL

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3.1 AST-1 (Southwest of Main Hospital Building)

3.2 DT-1 (Emergency Generator Day Tank in Main Hospital Building)

3.3 Oil-Filled Operating Equipment

3.4 Underground Storage Tank

3.5 Drum Storage Areas

3.6 Grease Storage

4.0 DRAINAGE PREVENTION, DIVERSIONARY STRUCTURES, AND

CONTAINMENT

5.0 IMPRACTICALITY OF SECONDARY CONTAINMENT

6.0 INSPECTIONS/RECORDKEEPING

6.1 SPCC Inspections

6.2 Hazardous Waste Inspections

7.0 PERSONNEL TRAINING

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

10.0 BRITTLE FRACTURE OR OTHER CATASTROPHE OF FIELD

CONSTRUCTED TANKS

11.0 CONFORMANCE WITH OTHER APPLICABLE REQUIREMENTS

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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 Maintenance Shop Supervisor

15.3 VAMC Employees

16.0 OIL SPILL CONTINGENCY PLAN

16.1 Key Responsibilities and Communication (40 CFR 109.5(a), (b)(2-3), and (d)(2-3)). 39

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 Oil Spill Response (40 CFR 109.5(c))

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

16.6 Minor Oil 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))

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

16.10 Spill Response Contractor

16.11 Arrangements with Local Authorities

16.12 Evacuation Plan

17.0 DISCHARGE REPORTING

17.1 Federal Reporting

17.2 State Reporting

18.0 EMERGENCY CONTROL EQUIPMENT

18.1 Testing and Maintenance of Emergency Equipment

19.0 FACILITY UPGRADES

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LIST OF FIGURES

Figure 2-1. Site Location Map

Figure 3-1. AST-1 – Near Main Hospital Building

Figure 3-2. DT-1 located at the Emergency Generator

Figure 3-3. Mobile Generator – Near Main Hospital Building

Figure 3-4. Hazardous and Universal Waste Storage Building

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

Figure 16-2. GEMS Coordinator Responsibilities Chart for Major Spill

Figure A-1. General Location of Bulk Storage Containers and

Oil-Filled Operational Equipment ........................................................................................ A-1

Figure A-2. Potential Spill Pathways and Piping for AST-1, DT-1, and Mobile Generator ..... A-2

Figure A-3. Potential Spill Pathways for Hydraulic Reservoirs ................................................ A-3

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

LIST OF TABLES

Loch Raven VAMC

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Table 2-1. Aboveground Storage Tank Inventory

Table 2-2. Oil-Filled Operating Equipment Inventory

Table 3-1. Potential Discharge From AST-1

Table 3-2. Potential Discharge From DT-1

Table 3-3. Potential Discharge from the Mobile Generator

Table 14-1. VAMC Oil Loading/Unloading Procedures

Table 16-1. Spill Response Contacts

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

APPENDICES

Loch Raven VAMC

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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 Table 302.4

Appendix H Summary of Hazardous Waste Accumulation and Storage Areas

Appendix I Arrangements with Local Responders

Appendix J RCRA Contingency Plan Quick Reference Guide

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ACRONYMS

API American Petroleum Institute

AST aboveground storage tank

BG&E Baltimore Gas and Electric

BMP best management practice

CAA Central Accumulation Area

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFR Code of Federal Regulations

COMAR Code of Maryland Regulations

CWA Clean Water Act

DBL/FRP double-walled fiberglass-reinforced plastic

EPCRA Emergency Planning & Community Right-To-Know Act

FMS Facilities Maintenance Service

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

PE Professional Engineer

QRG Quick Reference Guide

RC Response Coordinator

SAA Satellite Accumulation Area

SPCC Spill Prevention, Control, and Countermeasures

STI Steel Tank Institute

USEPA United States Environmental Protection Agency

UST underground storage tank

VA Department of Veterans Affairs

VAMC Veterans Affairs Medical Center

VAMHCS Veterans Affairs Maryland Health Care System

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MANAGEMENT APPROVAL

The Loch Raven Veterans Affairs Medical Center is committed to preventing discharges of oil 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 Spill Prevention, Control, and Countermeasures 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.

Mr. Robert Deinert

Safety and Health Program Manager, VA Maryland Health Care System

12/2/2020

Date

Mr. Adam Letke

Acting Chief, Facilities and Engineering Service, 1/21/2021

Mr. Matthew Orenstein

Acting Associate Director

1/21/2021

Mr. Jonathan Eckman

Director

1/22/2021

Jonathan R. Digitally signed by Jonathan R.

Eckman 110742

Eckman 110742 Date: 2021.01.22 11:13:36 -05'00'

MATTHEW S.

Digitally signed by MATTHEW

S. ORENSTEIN 729739

ORENSTEIN 729739 Date: 2021.01.21 12:09:46 -05'00'

ADAM S LETKE Digitally signed by ADAM S

180749

LETKE 180749

Date: 2021.01.21 10:36:50

-05'00'

Robert W.

Deinert 458787

Digitally signed by Robert W.

Deinert 458787

Date: 2020.12.02 08:02:44

-05'00'

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REVIEW AND REVISION HISTORY

A review and evaluation of this plan is conducted at least once every five years. As a result of this review and evaluation, the Veterans Affairs Medical Center (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) such technology has been field-proven at the time of review.

This plan will also be amended within six months after a change in the facility design, construction, operation, or maintenance occurs which materially affects the facility’s potential for oil discharge 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 October 2006

Original ICP developed as combined plan for Loch Raven CLRC and Baltimore VAMC.

October 2006

2.0 January 2013

Created facility-specific SPCC plan. Updated to address new AST.

February 2013

3.0

October 2017

Updated contact information; closed AST-1 (5,000-gallon AST), corrected building information for elevator equipment; updated state regulatory requirements, updated name of facility from CLRC to VAMC, other minor changes.

October 2017

4.0

July 2020

Update with new AST-1 and DT-1; removal of UST-1; upgrade from SPCC Plan to Integrated Contingency Plan by incorporating required elements of a RCRA Contingency Plan.

July 2020

NOTE: Anyone may propose changes to the Plan. All changes are reviewed for final publication. Proposed changes and updates should be provided to the VAMHCS Safety Office.

---.. -.. --w ;..c,; ...;, C o --;. y-

PROFESSIONAL ENGINEER"S REVIEVV/CERTIFICATION

I hereby certify that my agent: has visited and examined th e Loch Raven Veter ans Affair Med ical Center located at 3900 Loch Raven Boulevard , Baltimor,e Maryland. Being f amiliar vvith: th e pr ovsi ions of 40 CFR 112, Environrnenral Protecrion Agency Regularions on Oil Pollution Preventio,n I attest: th at thsi Integr ated Cont:jngency P lan for th: e f a c ili ty has b e e n p r ep ar ed in a c cor d a n c e w ith g o od e ng in e er ing p r a c ti c e , in c lud ing c o ns id er a t io n of app l i ca b le ind us try s ta nd ar ds, a nd w ith the r e q uri e m e n ts of' th is part thatpr ocedures forr equri ed inspections and testing haveb een estab lish ed; and that thsi p lansi 1 12 .3 (d).

adeq ua te for th e fac ility ac cord ing t:o 4 0 CFR

..........b ···MA ·,:,•1.,-:' ,,',, ·

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1.0 INTRODUCTION

1.1 Purpose

The purpose of the Integrated Contingency Plan (ICP) is to establish procedures, methods, and other requirements for equipment 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

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[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 plan 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, 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.

• 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, along with other information as detailed in Section 6.11, 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 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

P a g e | 3 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.

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 upgrades addressed 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

P a g e | 4 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 ICP 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 facility will generally comply with the revision requirements listed in this section. A Professional Engineer should certify technical changes to this plan before they go into effect. The ICP for the VAMC 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.” 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;

• 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 VA Maryland

Healthcare System (VAMHCS) Green Environmental Management System (GEMS) Coordinator will “complete a review and evaluation of the 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.

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The contact list and phone numbers provided in this document (see Section 5.0) will be updated when necessary (and at least every five years). Keeping the contact list current will be the responsibility of GEMS Coordinator. 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 review and 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 CFR 112.3 (e), a complete copy of this ICP is maintained at a location which is occupied during normal business hours. A copy is also maintained by each of the following VA representatives:

• Safety and Health Program Manager

• GEMS Coordinator

• VAMHCS Emergency Manager

• Facility Police Department

• Facilities and Engineering Maintenance and Operations Supervisor

1.8 Certification of the Applicability of the Substantial Harm Criteria Checklists

The VAMC does not store more than one million gallons of oil and does not have the potential to cause substantial harm based on the criteria in Attachment C-II in Appendix C 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 shutdown 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: Loch Raven Veterans Affairs Medical Center

MAILING ADDRESS: 3900 Loch Raven Boulevard

Baltimore, MD 21218

FACILITY STREET ADD: 3900 Loch Raven Boulevard

Baltimore, MD 21218

TELEPHONE: (410) 642-2411 x25227

OWNER: U.S. Department of Veterans Affairs

CONTACT NAME: Jennifer Dallaire, GEMS Coordinator

LOCATION: The VAMC is located on Loch Raven Boulevard, north of its intersection with The Alameda in the city of Baltimore, MD.

FACILITY DESCRIPTION: The VAMC specializes in providing rehabilitation and post-acute care for patients in the VA Maryland Health Care System. The center coordinates the delivery of rehabilitation services, including physical therapy, occupational therapy, kinesiotherapy, and recreation therapy, to Maryland’s veterans. The VAMC also provides hospice and nursing home care to veterans requiring non-acute inpatient care, as well as offering specialized treatment for patients with

Alzheimer’s disease and other forms of dementia. In late 2020, construction of a new pharmacy at the facility will completed. When the pharmacy becomes operational, the facility will begin to operate as an MDE-defined Fully Regulated Generator (FRG; equivalent to

RCRA LQG). In anticipation of that, this ICP has been prepared to include the requirements of a RCRA Contingency Plan.

TOTAL BULK STORAGE: The VAMC maintains a 2,000-gallon diesel fuel aboveground storage tank (UST) and 75-gallon day tank which provide fuel for the facility’s boiler as well its emergency generator. A mobile diesel emergency generator with a 574-gallon belly tank is located on the west side of Building 1. The facility also maintains four hydraulic fluid reservoirs associated with elevators in Building 1 with a total combined volume of approximately 880 gallons. The total bulk aboveground storage for the facility is 3,529 gallons. A facility diagram and other site figures are included in Appendix A.

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North

The VAMC campus is located on the west side of Loch Raven Boulevard, approximately 4 miles north-northeast of downtown Baltimore (see Figure 2-1). The VAMC occupies approximately

22.8 acres of land, nearly all of which is developed or consists of landscaped lawn areas. The facility slopes moderately from northeast to southwest with an elevation of approximately 240 feet above mean sea level along the northern property boundary and sloping down to the southwest to approximately 184 feet above mean sea level along The Alameda. The geographic coordinates for the VAMC are 39° 20’ 10” latitude and 76° 35’ 45” longitude. These coordinates correspond to the center of the property.

Figure 2-1. Site Location Map

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2.2 Facility Operations

The VAMC is a Department of Veterans Affairs (VA) facility that provides rehabilitation services and inpatient and outpatient care services. It is comprised primarily of a large, centrally located inpatient residence and rehabilitation building (Building 1), a community based outpatient clinic

(Buildings 5/6), a research building (Building 7), the FMS/Police Department building (Building

4), and two other ancillary buildings (Buildings 2 and 14).

VAMC operations involving oil are limited to the storage and use of diesel fuel for heating and running emergency generators. The facility is not involved in any oil production, drilling, or work over operations.

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

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

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-wide bulk oil storage at the VAMC is summarized in Tables 2-1 and 2-2 including, as applicable, location, contents, construction material, containment, and capacity. The locations of each of the ASTs and hydraulic fluid reservoirs are shown in Figure A-1.

Table 2-1. Aboveground Storage Tank Inventory

Tank No.

Location Capacity (gallons)

Product Hi-Level Alarm

Containment and Spill Control Features

AST-1

Building 1 (exterior)

2,000 Diesel fuel Yes Double-walled steel tank

DT-1

Emergency generator day tank

Diesel fuel

No

Double-walled

Mobile Generator

Building 1

Diesel fuel

Yes

Double-walled

Total Volume 2,649

Table 2-2. Oil-Filled Operating Equipment Inventory

Hydraulic Reservoir

ID

Location Product Capacity (gallons)

G9-1 Building 1, Room G9 Hydraulic Fluid 100

G9-2 Building 1, Room G9 Hydraulic Fluid 100

B7-3 Building 1, Room B007 Hydraulic Fluid 340

B7-4 Building 1, Room B007 Hydraulic Fluid 340

Total Volume 880

The VAMC maintains three regulated bulk storage tanks: a 2,000-gallon AST (AST-1), a 75-gallon day tank (DT-1), and a mobile generator with a 574-gallon belly tank.

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Both AST-1 and DT-1 are located adjacent to the facility’s emergency generator. AST-1 provides fuel to DT-1 (for the emergency generator) and to the boilers in Building 1. Both tanks became operational on April 1, 2020.

The VAMC also maintains a mobile emergency generator with a 574-gallon belly tank on the west side of Building 1, along the driveway/access road.

The facility recently closed and removed one 1,000-gallon UST formerly containing diesel fuel.

This tank was utilized for onsite heating by the facility’s boiler and also served as the fuel supply for the onsite emergency generator. This UST was replaced by AST-1.

The VAMC also currently maintains four hydraulic fluid reservoirs associated with elevators in

Building 1. Two reservoirs are located in Room B007 (approximately 100 gallons each) and two in Room G9 (approximately 340 gallons each).

The highest risk to the environment from a spill would be at AST-1, DT-1, or the Mobile Generator during filling operations. The lowest risk would be associated with the elevator hydraulic fluid reservoirs, since they are located inside Building 1 (which provides secondary containment) and are filled infrequently in relatively small amounts. The worst-case scenario, although highly unlikely, would be a structural failure at AST-1, resulting in a complete spill of its entire volume.

It is also possible that a structural failure could occur in the fuel delivery truck (while filling AST-

1), resulting in a substantial release.

Bulk storage containers are described in detail in the Section 3, and locations are shown in the general location and potential spill pathway diagrams (Figures A-1 through A-4) provided in

Appendix A.

2.4 Hazardous Waste Storage

As of July 2020, the Loch Raven VAMC continues to be registered and operate as a small quantity generator (SQG) of hazardous waste. However, impending changes to the facility, including the construction of an onsite pharmacy, will result in the facility becoming a fully-regulated generator

(FRG), most likely beginning in late 2020 or early 2021. This future change in site operations has created the need for a RCRA Contingency Plan and is the primary reason for upgrading the previous 2017 SPCC plan to this ICP.

The VAMC generates and accumulates hazardous waste at multiple satellite accumulation areas

(SAAs) located throughout the facility, which are listed in Appendix H.

When the facility becomes an FRG, it will designate and maintain one 90-day central accumulation area (CAA) for the onsite storage of hazardous waste prior to offsite shipment. The CAA will be established in a regulatorily-compliant outdoor hazardous waste storage building. The two possible locations for this storage building are shown on Figures A-1 and A-4 of Appendix A.

2.5 Universal Waste Storage

Universal waste fluorescent lamps and ballasts are currently stored in a small concrete building adjacent to Building 4; however, this will be moved to the CAA building (described in Section

2.4) once it is established. Universal waste batteries are stored in Room G-12 of Building 1.

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3.0 POTENTIAL SPILL PREDICTIONS, VOLUMES, RATES, AND CONTROL

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.

Experience indicates a reasonable potential for equipment failure that could result in a discharge of oil. 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 aboveground bulk oil storage containers with capacities greater than 55 gallons are described in this section.

The VAMC is situated on a localized topographic high point that is centered on the far northeastern end of the site. As a result, stormwater runoff at the VAMC primarily flows towards the south-southwest across the property towards The Alameda. The closest downgradient water body to the

VAMC is Lake Montebello located approximately one mile south-southeast of the facility.

Site-specific stormwater drainage primarily consists of a series of interconnected storm drains that discharge offsite. A discharge of oil from VAMC that is not contained at the site of the spill will flow into the storm drain system. Under wet weather conditions such a spill has the potential to eventually reach one of the nearby receiving waters.

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

3.1 AST-1 (Southwest of Main Hospital Building)

A 2,000-gallon diesel fuel AST (AST-1) was installed at the facility and brought online in April

2020 (see Figure 3-1). This tank is double-walled, constructed of steel, and located on a concrete pad in an exterior area adjacent to the emergency generator and chillers. The tank provides fuel to both the boiler inside the Main Hospital Building and to an exterior day tank (DT-1) associated with the adjacent emergency generator. This tank is equipped with an audible/visual overfill alarm located at the fill port.

Fuel piping from AST-1 to DT-1 and from AST-1 to the remote fill port is all single-walled and completely aboveground. Piping from AST-1 to the boiler inside Building 1 consists of both single-walled, aboveground runs as well as double-walled, belowground runs. The total length of underground piping is approximately 25 feet.

The expected spill route of released material depends upon the exact location of the release. A release from the piping or tank itself would flow radially across the concrete pad and then to the south-southwest, downhill across the grassy area towards Buildings 5/6 and 7 approximately

30 feet away. A release at the remote fill would likely go in two directions, depending on the volume and exact manner of the release. Some product would likely flow west/northwest along the roadway and towards storm drains. A portion of the release would also likely flow downhill across the grassy area towards Buildings 5/6 and 7 (see Figure A-2 in Appendix A). Potential discharge volume and direction is summarized in Table 3-1.

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Table 3-1. Potential Discharge From AST-1

Potential Event Discharge Direction Spill Rate Volume

Discharged Secondary Containment and Control

Tank or piping rupture

South/southwest towards grassy area

Instantaneous

2,000 gal.

Double-walled tank. Spill kit for piping. Use soil to create a berm to prevent further migration of release.

Tank or piping leakage

South/southwest towards

1 gal./min.

10 gal.

Double-walled tank. Spill kit for piping. Use soil to create a berm to prevent further migration of release.

Tank overfill

West/northwest along roadway or south/southeast towards grassy area

5 gal./min.

50 gal.

Use absorbent to contain spills and leaks Use soil to create a berm to prevent further migration of release.

Figure 3-1. AST-1 – Near Main Hospital Building

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3.2 DT-1 (Emergency Generator Day Tank in Main Hospital Building)

DT-1 is a double-walled day tank (see Figure 3-2) associated with the emergency generator located outside Building 1. It was installed at the same time as AST-1 and became operational in April

2020. DT-1 is 75 gallons in capacity and is constructed of double-walled steel. The day tank is fed directly from AST-1 and is connected via single-walled aboveground piping to the emergency generator.

The expected spill route of the released material at this location would be radially across the concrete pad then to the south-southwest in the direction of an administrative building approximately 30 feet away and a cul-de-sac fronting the building (see Figure A-2 in Appendix

A). Potential discharge volume and direction is also summarized in Table 3-2.

Table 3-2. Potential Discharge From DT-1

Volume

Discharged Secondary Containment and Control

Tank or piping rupture

South/southeast towards

Instantaneous 75 gal.

Spill kit. Use soil to create a berm to prevent further migration of release.

Tank or piping leakage

South/southeast towards grassy area

1 gal./min. 10 gal.

Tank overfill South/southeast towards

1 gal./min. 10 gal.

Figure 3-2. DT-1 located at the Emergency Generator

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3.3 Mobile Generator

The mobile generator located on the south side of Building 1, across the roadway from AST-1. It is equipped with a 547-gallon double-walled belly tank containing diesel fuel.

The expected spill route of released material would likely flow west/northwest along the roadway and towards storm drains (see Figure A-2 in Appendix A). Potential discharge volume and direction is also summarized in Table 3-3.

Table 3-3. Potential Discharge from the Mobile Generator

Volume

Discharged Secondary Containment and Control

Tank or piping rupture

West/northwest along roadway

Instantaneous 547 gal. Double-walled tank.

Tank or piping leakage

West/northwest along roadway

1 gal./min. 10 gal. Spill kit.

Tank overfill West/northwest along roadway 5 gal./min. 50 gal. Spill kit.

Figure 3-3. Mobile Generator – Near Main Hospital Building

3.4 Oil-Filled Operating Equipment

The VAMC has oil-filled operational equipment 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 that may be harmful 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.

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The general containment requirements in 40 CFR 112.7 require that one of the following types of containment and/or diversionary structures or equipment are 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. The VAMC’s inspection program (see Section 6.0) addresses bulk containers as well as oil-filled operating equipment.

Oil-filled operating equipment (i.e., hydraulic fluid reservoirs) are shown on Figure A-3. The

VAMC maintains four hydraulic fluid reservoirs associated with elevators in Building 1. Two reservoirs are located in Room B-7 (approximately 100 gallons each) and two in Room G-9

(approximately 340 gallons each). Each reservoir is equipped with a side-mount manometer for gauging the volume of hydraulic fluid in the reservoir. A shallow drip pan has been placed under each reservoir.

Six exterior pad-mounted electrical transformers and three pole-mounted transformers containing dielectric fluid are also located at the VAMC. All nine transformers are owned, operated, and maintained by Baltimore Gas and Electric (BG&E). The VAMC has obtained written confirmation from BG&E that the utility owns these transformers and as such, BG&E is responsible for the maintenance of these transformers as well as responding to any leaks or releases. However, VAMC personnel will contact BG&E in the event that a leak or release is identified and will attempt to control any identified leaks or releases until the arrival of BG&E or the local fire department.

3.4 Hazardous and Universal Waste Storage

As discussed earlier, the current universal waste storage areas are located in Room G-12 of

Building 1 (batteries) and in a concrete building adjacent to Building 4 (lamps and ballasts). A potential spill or release in Room G-12 would be contained within the building. A release that escapes from the concrete building could flow to the south across a paved parking area towards a storm drain.

The CAA will be established in a regulatorily-compliant outdoor hazardous waste storage building.

The two possible locations for this storage building are shown on Figures A-1 and A-4 of Appendix

A. The building will be equipped with secondary containment that will contain all spills. If a release did escape the unit, it would flow either westward along the driveway south of the main hospital building or southeasterly towards Loch Raven Boulevard, depending on the final location.

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Figure 3-4. Hazardous and Universal Waste Storage Building

3.5 Underground Storage Tank

There are currently no underground storage tanks at the Loch Raven VAMC. A UST was previously present onsite (UST-1) and provided diesel fuel for both the facility boilers and its emergency generator but was removed in 2019.

3.6 Drum Storage Areas

The Loch Raven VAMC does not currently store oil in drums.

3.7 Grease Storage

The Nutrition and Food Service Kitchen no longer uses cooking oil and therefore no longer generates used cooking grease. However, it does utilize a subsurface grease trap which is maintained on a regular basis.

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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.

The bulk storage containers at the VAMC have various forms of secondary containment to prevent discharged oil from reaching a waterway.

AST-1 has secondary containment in the form of being a double-walled tank. It is also equipped with a spill bucket to prevent spills during fueling operations. The underground piping runs are equipped with secondary containment. Two subsurface sumps are also designed to collect leaking product from underground piping and are equipped with liquid sensors. Spill kits are located near single-walled aboveground piping.

The day tank (DT-1) associated with AST-1 is also double-walled which provides secondary containment.

Mobile generator belly tank has secondary containment in the form of being a double-walled tank.

The elevator hydraulic fluid reservoirs are equipped with secondary containment through their placement within Building 1. See Section 19 (Facility Upgrades) for recommendations for addressing secondary containment.

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5.0 IMPRACTICALITY OF SECONDARY CONTAINMENT

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.

The VAMC considers secondary containment to be practical and has implemented secondary containment for bulk storage containers as described in Section 4.

The elevator hydraulic reservoirs, which are not equipped with secondary containment (aside from being located within the building, which acts a form of secondary containment), are managed per the Oil Spill Contingency Plan, included in Section 16.0.

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6.0 INSPECTIONS/RECORDKEEPING

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.

6.1 SPCC Inspections

Inspections of AST-1, DT-1, the mobile generator, and oil-filled operating equipment at the

VAMC are conducted on a regular basis. Formal inspections are conducted and documented on a monthly and annual basis. Cursory inspections are conducted on a more frequent basis as part of daily operations.

All liquid level, overfill equipment, and release detection sensing devices for AST-1 and DT-1 were tested upon installation. Moving forward, ensure these tests are conducted annually or in accordance with the manufacturer’s instructions for functionality verification. Mechanical devices should be tested by ensuring that the float device or float rod moves freely. The accuracy of liquid level sensing devices should be verified by comparing the liquid level registered on the device to a stick measurement of the product level. The testing documentation should be maintained with the master copy of this plan.

The monthly inspection checklists, included in Appendix B, are based on the Steel Tank Institute’s

(STI) “Standard for the Inspection of Aboveground Storage Tanks”, Standard SP001, 4th edition.

This…