POLICY_VAMHCS AST UST 2022.pdf

ABOVE GROUND AND UNDERGROUND STORAGE TANK MANAGEMENT

MCP 512-001/OPS-S-026

VA Maryland Health Care System (VAMHCS) Baltimore, Maryland 21201

Rescinded Document:

MCP 512-001/OPS-026

Above Ground and Underground Storage Tank Management, dated July 31, 2021

Signatory Authority:

Director, VA Maryland Health Care System

Effective Date:

February 1, 2022

Responsible Owner:

Chief, Safety and Occupational Health

Recertification Date:

February 28, 2027

1. PURPOSE

To establish the requirements for registration, inspection, testing, maintenance, filling and spill response for above ground storage tanks (AST) and underground storage tanks (UST) on VA Maryland Health Care System (VAMHCS) property.

2. POLICY

It is the policy of the VAMHCS to protect human health and the environment by managing a comprehensive tank compliance program in accordance with all laws and regulations set forth by the U.S. Environmental Protection Agency (EPA), the U.S.

Department of Transportation (DOT), the Maryland Department of the Environment (MDE), the National Fire Protection Association (NFPA) and the American Petroleum Institute (API).

3. SCOPE

Procedures set forth in this policy apply to all tanks on VAMHCS property which store petroleum-based products used for generator and boiler plant supply fuel, vehicle refueling and/or waste oil collection.

4. RESPONSIBILITIES

a. The Director, VAMHCS, is responsible for development and implementation of this policy.

b. Chief, Facilities and Engineering Service is responsible for providing appropriate information and training to all Facilities & Engineering Service (FES) personnel and for ensuring that all procedures, including inspections, recordkeeping, repairs and completion of the attendant documentation are followed.

c. Chief, Safety and Occupational Health Service is responsible for the overall compliance and management of the VAMHCS UST and AST program.

d. Project Engineers are responsible for ensuring proper notification to the GEMS Office and to the appropriate regulatory agency prior to tank installation and/or repairs as well as maintaining all significant documents during any project, which includes tank

February 1, 2022 MCP 512-001/OPS-S-026 installation and removal as well as entering appropriate equipment into the VAMHCS Preventive Maintenance (PM) program. All communication with regulatory agencies (if by VAMHCS personnel or VAMHCS Contractor MUST include the VAMHCS GEMS Coordinator.

e. Projects Engineers; Maintenance and Operations Engineers and Shops Foreman are responsible for ensuring proper notification to the GEMS Office and to the appropriate regulatory agency prior to tank installation and/or repairs as well as maintaining all significant documents during any Maintenance project, which includes tank installation and removal as well as entering/maintaining appropriate equipment into the VAMHCS Preventive Maintenance (PM) program. All communication with regulatory agencies (if by VAMHCS personnel or VAMHCS Contractor MUST include the VAMHCS GEMS Coordinator.

f. Green Environmental Management (GEMS) Coordinator(s), VAMHCS, is/are responsible for advising the project engineers of regulatory requirements and notifications associated with any tank replacement project and for advising Facilities & Engineering Service of regulatory requirements associated with the operation of a compliant tank management program. The GEMS Coordinator(s) is/are responsible for maintaining an updated Spill Prevention Control and Countermeasures (SPCC) plan or Integrated Contingency Plan (ICP).

5. ACTIONS

a. Above ground storage tanks (COMAR 26.10.01.01 through .12; 26.10.01.16- 21 and 26.10.03.02)

(1) Installation and Registration

(a) Above ground storage tanks with a capacity of 10,000 gallons or more must be installed with a continuous dike or wall capable of effectively holding the total volume of the largest storage container located within the area enclosed by the dike or wall. The floor and walls of the holding areas shall have a permeability of 10-4 cm/second as measured by an MDE-approved test method. Secondary containment should be large enough to contain the entire contents of the tank/container (or largest tank/container where there are multiples in one secondary containment system) with “sufficient freeboard” to account for precipitation. Industry standard has been noted as 110% secondary containment of fuel tanks, in addition to a double walled tank design.

MDE may require oil storage tanks/facilities of less than 10,000 gallons to be diked if the tank is in a location likely to pollute waters of the state. Construction of ASTs, dikes, or walls within the tidal wetlands or within the 100-yr floodplain is prohibited unless a state wetlands permit is first obtained through MDE.

(b) The tank fuel lines must also have secondary containment/spill protection. If any section of piping will be located underground, ensure all requirements of COMAR

26.10.03.02 and COMAR 26.10.05.02 are met.

(c) Each pipeline connected to a tank below the liquid level shall have valves located immediately adjacent to the storage tank. Seams, rivets, nozzle connections, valves, pumps and pipelines directly connected to above-ground storage tanks shall be visually examined at least once a month for any oil leaks and any leaks shall be promptly corrected. Any oil-contaminated surface drainage leaving the containment area shall be passed through an MDE-approved oil separating system unless other oil pollution control measures acceptable to MDE are provided. Flapper-type drain valves may not be used to drain diked areas. Drain valves for dikes shall be kept in the closed position and shall be locked when not used to drain trapped water.

(d) Provide leak detection system such as a high liquid level gauge, a high-level alarm system (such as a whistle) on the tank, or a pump cut-off device shall be installed on any oil storage tank that MDE considers an overflow of oil is possible. The use of these emergency devices shall be considered supplementary to the use of personnel engaged in transfer operations. Before each filling of an existing oil storage system, the liquid level shall be gauged and the measurement shall be recorded in writing. The gauging records shall be maintained for 30 days and shall be made available for reasonable inspection by MDE. This requirement does not apply to any oil storage system installed before April 21, 1978, without provisions for the measurement of content. A chart for sticking the tank to manually confirm the height of the fuel in the tank is preferable and a visual tank gauge is required.

(e) Proper grounding for tank per NFPA 780 must be provided:

1. A tank shall be connected without insulated joints to a grounded metallic piping system.

2. A vertical cylindrical tank shall rest on earth or concrete and shall be at least 20 ft (6 m) in diameter or shall rest on bituminous pavement and shall be at least 50 ft (15 m) in diameter.

3. A tank shall be grounded through a minimum of two grounding electrodes at maximum 100 ft (30 m) intervals along the perimeter of the tank.

4. A (metal) tank shall be grounded by one of the following methods:

a. A tank shall be connected without insulated joints to a grounded metallic piping system.

b. A vertical cylindrical tank shall rest on earth or concrete and shall be at least 20 ft (6 m) in diameter or shall rest on bituminous pavement and shall be at least 50 ft (15 m) in diameter.

c. A tank shall be grounded through a minimum of two grounding electrodes, as described in Section 4.13, at maximum 100 ft (30 m) intervals along the perimeter of the tank.

d. A tank installation using an insulating membrane beneath for environmental or other reasons shall be grounded as in NFPA 780.

e. Tanks that have the steel outer wall with the thermal insulation in the interstice are recommended.

(f) No field-erected tanks OR Underground Storage Tanks (USTs) unless prior approval from VAMHCS GEMS Coordinator has been provided to VAMHCS COR.

(g) If Tank (Primary and Day Tank); Oil Container(s); and/or Wet Transformer(s) contain 55gal or more of oil, contractor will be required have a professional engineer (P.E.) add them to the facility’s Integrated Contingency Plan and added to the Facility’s Oil Operations Permit and must coordinate this with COR and GEMS Coordinator at VAMHCSGEMSProgram@va.gov.

(h) With the installation of any new AST, notification must be made to MDE by the GEMS Coordinator prior to tank installation. A notification for alterations in the facility Oil Operations Permit must be completed and submitted to ensure the tank is properly registered with the State. Additionally, the new AST must be added to the facility Integrated Contingency Plan (ICP) or Spill Prevention Countermeasures and Control (SPCC) plan by a Professional Engineer within six months after installation.

(i) Tank design shall comply with all API design criteria, as well as Petroleum Equipment Institute (PEI) NFPA, EPA, MDE and VA Physical Security (“Mission Critical”) requirements.

(j) Tank warranty information shall be obtained from the installation contractor and kept in the project files.

(k) A copy of all documents related to tank registration and installation shall be maintained by the GEMS Coordinator.

(l) Tanks must have regulatorily-required signage (NFPA 704 diamond) easily readable by emergency responders. Signs should specify the Tank ID, tank contents, volume and phone number for spill response. Signs should be visible and readable. For areas where a tank is located close to patients/personnel, “No Smoking” signage should also be displayed.

(2) If Tank design must adhere to VA Physical Security (“mission critical”) standards, the following requirements include but are not limited to:

(a) All requirements for oil-filled equipment (tanks, day tanks, transformers, containers) listed in this policy apply to VA mission critical design.

(b) No Underground Storage Tanks shall be installed.

(c) To keep the Aboveground Storage tank status, the tank can be designed into a vault, but it may have underground piping which will fall under the Underground Storage Tank (UST) regulations. Therefore, it MUST BE:

1. Designed with double-walled piping in accordance with COMAR 26.10.03.02:

a. Precision tested at installation in accordance with MDE regulations (fact sheet attached).

b. Designed to have safe suction per COMAR 26.10.05.02:

mailto:VAMHCSGEMSProgram@va.gov

(1) Suction Piping. Underground piping that conveys regulated substances under suction shall be tested for tightness at least every 2 years with a precision test performed for 1 hour at a pressure between 5 and 15 pounds per square inch that detects a 0.1 gallon per hour release, or be monitored monthly in accordance with Regulation .04F—I of this chapter. Release detection and precision testing are not required for suction piping when:

(2) The piping operates at less than atmospheric pressure;

(3) The piping is sloped so that the contents of the pipe will drain back into the storage tank if the suction is released;

(4) A single check valve is included in each suction line; - Each suction line can

ONLY HAVE ONE CHECK VALVE.

(5) The check valve is located directly below and as close as practical to the suction pump; and

(6) A method for visual inspection to determine compliance is provided—PLEASE

PUT A VIEW PORT OR SITE GLASS ON ALL SUMPS ASSOCIATED WITH FUEL

PIPING

(7) Secondary containment piping shall be tested by using the manufacturer's test protocol, or PEI/RP 1200, "Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities" and every five years thereafter.

(a) For new, upgraded, or replaced piping before operation of the UST system and completion of the underground oil storage facility; and

(b) Every five years thereafter.

(3) Leak Detection System (Automatic Tank Gauge) that is considered an MDE approved method by National Workgroup on Leak Detection Evaluations (NWGLDE).

For example, systems that are noted on the NWGLDE website: http://www.nwglde.org/ should be installed by an MDE-certified UST contractor:

(a) MUST have sensors that go into

1. The tank

2. The interstice of the tank

3. All sumps associated with the tank and piping and sensors must be able to distinguish between “product” (e.g., fuel) and water

(b) Must have a high-high alarm that senses when the vault sump or other secondary containment has liquid.

(c) Provide a chart for sticking the tank to manually confirm the height of the fuel in the tank.

http://www.nwglde.org/

(d) Visual tank gauge

(e) All other aboveground storage tank requirements listed prior to the VA mission-critical design information shall be required.

(f) If vaulted, above ground storage tank will be designed:

1. The vault itself must have uplift protection from hydrostatic pressure, this will need to be calculated and submitted to the VAMHCS COR

2. The vault will need to have de-watering equipment with a fuel sensor or oil-water separator (design approved by VAMHCS COR).

3. To provide VAMHCS COR with an Industrial Scientific M40 Confined Space Entry Kit with Calibration Kit

4. To provide active or passive ventilation of the space

5. To perform blast analysis of this storage vault unless the manufacturer states the tank is ballistic-resistant. The manufacturer ballistic resistant information should be submitted with the design.

(4) Maintenance, Inspection and Testing

(a) Monthly Inspections – Seams, rivets, nozzle connections, valves, pumps and pipelines directly connected to the AST shall be visually examined by FES personnel at least once per month for any oil leaks. The check-off list for AST monthly inspection is included in the facility’s SPCC or ICP as well as in the Facilities and Engineering Liquid Fuel Systems (Standalone and for Utilities) SOP-138/ENG-023, Liquid Fuel Systems (StandAlone and for Utilities).pdf (sharepoint.com). Completed inspection sheets shall be submitted to the GEMS Coordinator or Industrial Hygienist at each facility, who will then determine corrective actions and monitor correction(s).

(b) Integrity Testing – The Boiler Plant Field-Erected AST at the Perry Point campus must receive an integrity test every 10 years, or whenever material repairs are made. Record of these tests must be maintained with one “Master Copy” of the SPCC or ICP in the Safety and Occupational Health Office and an electronic copy saved in the Engineering/GEMS Shared folder.

(c) Any trouble alarms on tank overfill or leak panels shall receive immediate response. If it is determined that the alarm condition is the result of a leaking tank or overfill, refer to the facility’s SPCC or ICP, or the “spill or release response” section of this policy. Notify the Safety and Occupation Health Office immediately.

(d) Leak detection and overfill alarms shall be kept in reliable working condition.

(e) Diked storage areas must be kept secured to prevent discharge into the drainage system. The valves are to be kept secured and closed until rainwater accumulation is visually inspected for contamination. Any sheens or releases within the containment area must be properly removed before the rainwater may be drained and noted in Tank Inspection logbook. Valves are to be re-secured after drainage is https://gcc02.safelinks.protection.outlook.com/ap/b-59584e83/?url=https%3A%2F%2Fdvagov.sharepoint.com%2Fsites%2FVHAVAMHCS%2Fnursing1%2FPolicies%2FVAMHCS%2520Policies%2520and%2520SOPs%2FLiquid%2520Fuel%2520Systems%2520(StandAlone%2520and%2520for%2520Utilities).pdf&data=04%7C01%7C%7Cd830cc21b4a140c2120108d9d1db773e%7Ce95f1b23abaf45ee821db7ab251ab3bf%7C0%7C0%7C637771562787921205%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=jPyazAuqJ8Ci2ZF1SYKbaaH2USMI4dRJuD4TGbqDryg%3D&reserved=0 https://gcc02.safelinks.protection.outlook.com/ap/b-59584e83/?url=https%3A%2F%2Fdvagov.sharepoint.com%2Fsites%2FVHAVAMHCS%2Fnursing1%2FPolicies%2FVAMHCS%2520Policies%2520and%2520SOPs%2FLiquid%2520Fuel%2520Systems%2520(StandAlone%2520and%2520for%2520Utilities).pdf&data=04%7C01%7C%7Cd830cc21b4a140c2120108d9d1db773e%7Ce95f1b23abaf45ee821db7ab251ab3bf%7C0%7C0%7C637771562787921205%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=jPyazAuqJ8Ci2ZF1SYKbaaH2USMI4dRJuD4TGbqDryg%3D&reserved=0 complete. The tank custodian must keep records of discharges from secondary containment structures and forward these records to the Safety and Occupational Health Office.

(f) In accordance with NFPA 110 Standards for Emergency and Standby Power Systems, FES personnel must complete an ASTM-approved annual fuel quality test for all ASTs that supply fuel for emergency and standby power systems.

(5) Removal and Repair

(a) Any time an AST is removed or shut down, please notify the Safety and Occupational Health Office. The Safety and Occupational Health Office will notify MDE.

The facility Oil Operations Permit and the SPCC/ICP must be modified to reflect tank removal.

(b) If any leftover petroleum product is removed from the tank, a manifest must be maintained, indicating transfer and disposal route. Any contractor transferring petroleum product must have proper DOT certification. This documentation must be provided to the Safety and Occupational Health Office/GEMS Coordinator.

(c) A certificate of storage tank disposal shall be obtained and kept on file in the Safety and Occupational Health Office for any tank that is removed.

b. Underground Storage Tanks [Must comply with all UST requirements in COMAR 26.10.03 through 26.10.16 (including all sub-requirements in each section of these regulations)]

(1) Design and Performance Standards for New UST Systems (COMAR 26.10.03.01, 26.10.03.02, and 26.10.03.06)

(a) USTs

Each tank shall be properly designed and constructed, have secondary containment and be protected from corrosion, in accordance with one of the following:

1. A tank that is constructed of fiberglass-reinforced plastic shall be listed by Underwriters Laboratories or approved by the American Society of Testing and Materials; or

2. A tank that is constructed of steel and cathodically protected shall be coated with a suitable dielectric material and shall:

a. Be protected with an impressed current system

b. Designed and installed to allow determination of electrical current operation and approved by a corrosion expert; or

c. Have a manufacturer-installed cathodic protection system which is approved by the Steel Tank Institute or is listed with Underwriters Laboratories.

A tank that is constructed of a steel-fiberglass-reinforced-plastic composite shall be listed by Underwriters Laboratories or approved by the Steel Tank Institute. Alternative methods of tank construction and corrosion protection may be approved by MDE to be designed to prevent the release or threatened release of any stored regulated substance in a manner that is no less protective of human health and the environment than the requirements outlined above.

(b) UST piping [COMAR 26.10.03; 26.10.04; 26.10.05]

Piping that routinely contains a petroleum vapor or regulated substance and is installed, upgraded, or replaced on or after January 26, 2005 shall be:

1. Installed in a UL listed or MDE-approved secondary containment system that:

a. Contains the petroleum vapor or regulated substance released from the primary piping until it is detected and removed; and

b. Prevents the release of the petroleum vapor or regulated substance to the environment;

2. Connected to the UST in a liquid tight containment sump that is maintained clean and liquid free;

3. Terminated, when a product dispenser is part of the UST system, in an under-dispenser containment sump that is maintained clean and liquid free; and

4. Connected, if an intermediate sump is used, in liquid tight containment that is maintained clean and liquid free.

5. Piping that is in contact with the ground shall be properly designed, constructed and protected from corrosion in accordance with one of the following:

a. Piping and connectors that are constructed of fiberglass-reinforced plastic or flexible piping shall be listed by Underwriters Laboratories as appropriate piping for the regulated substance stored and for use in an UST system;

b. Piping that is constructed of steel shall be:

6. Coated with a suitable dielectric material and installed with a cathodic protection system designed by a corrosion expert, or

7. Protected by an impressed current system which is designed to allow determination of current operating status as required in COMAR 26.10.04.02.

8. Alternative methods of piping construction and corrosion protection may be approved if determined by MDE to be adequate to prevent the release or threatened release of any stored regulated substance in a manner that is not less protective of human health and the environment than the requirements of COMAR 26.10.03.01.

9. Fiberglass-reinforced plastic piping systems may not be used:

a. For direct fill lines; or

b. Aboveground or above grade.

10. Flexible piping systems may not be used for any of the following when new, upgraded, or replaced UST systems are installed after January 1, 2009:

a. Direct fill lines;

b. Vent lines; or

c. Stage II vapor recovery lines.

11. UST system piping which is below the ground surface shall be placed on a 6-inch bedding of appropriate backfill material per MDE requirements. The following clearances shall be maintained when piping is installed:

a. At least 4 inches between all piping and between piping and electrical conduit;

b. At least 6 inches between piping and excavation side walls; and

c. At least 18 inches between piping and the surface of the ground.

d. Piping shall rise 1/8 inch for each lateral foot from the tank to the piping end point.

12. Manufacturer specifications and installation requirements shall be followed when installing piping. Piping carrying a regulated substance shall be connected to the tank and the dispensing equipment at the end of the piping run by an Underwriters Laboratory-listed flexible connector, installed in accordance with manufacturer specifications. Flexible connectors may not be used at any other point in the piping.

Pressurized product piping which dispenses motor fuels shall have an Underwriters Laboratory-listed shear valve placed and be properly anchored at the dispenser.

Electrical conduit and other apparatus such as water and air piping unrelated to the UST system may not be installed in the UST piping trenches.

13. Vent lines above the ground surface shall be:

a. Constructed with at least schedule 40 steel;

b. Protected from traffic;

c. Properly anchored; and

d. Protected from weather and debris.

14. Vents for UST systems storing flammable liquids shall terminate 12 feet above the ground surface and 2 feet above any attached building. Vents for UST systems storing combustible liquids shall terminate at least 3 feet above the ground surface.

(2) Installation and Registration

(a) The Safety and Occupational Health Service shall be notified by the COR a minimum of 30 days prior to installation of any new underground storage tank.

(b) Any new UST must be registered with MDE. A Maryland New Tank Installation form shall be submitted to MDE by the VAMHCS no less than 30-days prior to the start of tank installation. This form must be reviewed and approved by the Safety and Occupational Health Office. The form shall be completed by the certified tank installer (in accordance with COMAR 26.10.03.09) with a copy being submitted to the Safety and Occupational Health Office. A copy of the UST registration shall be displayed by the UST Automatic Tank Gauge or readily available.

(c) UST System Installation must comply with the latest version of the requirements in COMAR 26.10.03.04. Tank design shall comply with all API design criteria, as well as Petroleum Equipment Institute (PEI) NFPA, EPA, MDE and VA Physical Security (“Mission Critical”) requirements.

(d) A tank and line tightness test and a hydrostatic test of both the fill bucket and mechanical sumps shall be included as part of the scope of work for the tank installation project. All tests must obtain a passing result before the tank installation is accepted by the VAMHCS. Record of these tests shall be maintained in the project file, on the engineering share drive with a copy submitted to the Safety and Occupational Health Service.

(e) Tank warranty information shall be obtained from the contractor and kept in the project files and scanned to the engineering share drive.

(f) All UST systems shall be installed with at least two field monitoring wells.

(g) All USTs shall be installed with some type of overfill protection that will automatically shut off flow into the tank when the tank reaches 95% full.

(h) All USTs shall be installed with containment sumps.

(i) The tank fill must be installed with a lockable cap. The tank capacity and product type should be indicated somewhere at the fill. The fill cap must be painted in accordance with the product type.

(j) The spill bucket or “spill catchment basin” or “fill bucket” at the tank fill must have a minimum 5-gallon capacity.

(k) All UST systems must be installed with a vent. The vent riser shall be constructed of steel and have a vent cap. The pipe must extend 12-feet above the ground and 2-feet above any attached building. The vent shall be installed with regulatory-compliant overfill protection.

(l) All tanks must be installed with a drop tube which ends no more than 1-foot from the tank bottom. Drop tubes shall be installed with a flapper valve.

(m) All UST projects shall specify both a “double-wall” tank and “double-wall” piping per MDE UST regulations in COMAR 26.

(3) Maintenance, Inspection and Testing

(a) The following table outlines MDE UST maintenance, inspection and testing requirements as well as their required intervals based on the regulations, COMAR 26.10.01-26.10.11, at the publishing date of this policy.

MDE UST Requirement (per

COMAR 26.10.02—26.10.11)

Responsible Party and Duties

Required Interval to Complete MDE Requirement

UST MDE Triannual Inspection

GEMS Coordinator will coordinate with an MDE-certified contractor to perform inspection and will maintain inspection records

Every THREE Years

Drop Tube (Should be Included in UST Triannual Inspection) [Overfill Prevention Equipment]

Facilities & Engineering will coordinate with an MDE-certified contractor to perform overfill prevention equipment inspection and will maintain inspection records and provide a copy to the GEMS Coordinator.

Every THREE Years

Tank & Line Tightness Test

Facilities & Engineering will coordinate with an MDE-certified contractor to perform test and will maintain test records and provide a copy to the GEMS Coordinator.

Every Two Years

Tank Sump Hydrostatic Test Facilities & Engineering will coordinate with an MDE-certified contractor to perform test and will maintain test records and provide a copy to the GEMS Coordinator.

Every Year

Spill Bucket Hydrostatic Test (aka, “fill bucket”; “spill catchment basin” or “spill containment manhole”)

Facilities & Engineering will coordinate with an MDE-certified contractor to perform test and will maintain test records and provide a copy to the GEMS Coordinator.

Every Year

Automatic Tank Gauge (ATG) Calibration and Certification & Equipment Calibration.

Facilities & Engineering will coordinate with an MDE-certified contractor to perform test and will maintain calibration records and provide a copy to the GEMS Coordinator.

Every Year

Fuel Quality Test per NFPA 110 (not MDE requirement but Joint Commission element of performance)

Facilities & Engineering will coordinate with a certified contractor to perform test and will maintain test records and provide a copy to the GEMS Coordinator.

Every Year

MDE UST Requirement (per

COMAR 26.10.02—26.10.11)

Responsible Party and Duties

Required Interval to Complete MDE Requirement

Dip Stick Reading Electrical Shop will perform reading and record results, maintain records and provide this as part of the monthly UST inspection records to the GEMS Coordinator.

Monthly

Fuel Level Electrical Shop will perform reading and record results, maintain records and provide this as part of the monthly UST inspection records to the GEMS Coordinator.

Monthly

Amount of Fuel Used Electrical Shop will record amounts used and maintain records and provide this as part of the monthly UST inspection records to the GEMS Coordinator.

Monthly

Water Level-Tank Bottom Water Reading (If ATG is calibrated annually, the ATG can provide these readings;

otherwise, tank finding past and measuring stick required to perform this reading)

Facilities & Engineering will coordinate with an MDE-certified contractor to perform test and will maintain test records and provide a copy to the GEMS Coordinator.

Monthly

Fuel Delivery date and Amount

Electrical Shop will record dates/amount, maintain records and provide to the GEMS Coordinator

As Delivered

Trouble Alarm on Tank Overfills or Leak Panels

Facilities & Engineering will record alarms, implement overfill/spill procedures, maintain records and provide to the GEMS Coordinator.

Upon Discovery (Suspected Leak, Spill, or Overfill)

UST Operator Training Documents/Certifications

Facilities & Engineering will ensure appropriate staff receives and maintains UST Operator training and will maintain training records and provide to the GEMS Coordinator.

MD Class A, B and C UST Certified Operator Certificates/Class C Checklists for Class C UST Operators/Emergency Contacts/Manual

** ALL OF THE ABOVE RECORDS SHALL BE KEPT ONSITE FOR AT LEAST 5 YEARS**

Sumps and spill buckets/ catchment basins shall be kept dry and free of debris. Sump caps should be removed and inspected for water once per month. The fill bucket should be inspected monthly and before any fills. For the Baltimore location, monthly UST inspection records are maintained in the Generator Log and the electronic Emergency Generator Fuel Report.

(b) Any water that is found in the spill bucket/ catchment basins shall not be drained back into the tank. The Water should be pumped out with a hand pump. If the water is mixed with a fuel it should be collected for disposal by the Safety and Occupational Health Service.

(c) Sumps shall be hydrostatically tested annually. Records of this testing shall be maintained by Facilities & Engineering Service on the share drive and the Safety and Occupational Health Service.

(d) Spill buckets/catchment basins shall be hydrostatically tested annually. Records of this testing shall be maintained by Facilities & Engineering Service on the share drive and the Safety and Occupational Health Service.

(e) The tank and tank lines shall undergo a tightness testing with the initial installation. Subsequent tightness testing is required after 15 years and every 2 years for the Baltimore VAMC thereafter.

(f) Trouble alarms on tank overfill or leak panels shall be responded to immediately.

If determined the alarm condition is the result of a leaking tank or overfill incident, the response procedures outlined in the SPCC/IPC plan shall be followed. As an alternative, responders may refer to the “Spill or Release Response” section of this policy. The Safety and Occupational Health Service shall be notified immediately upon discovery of a leaking tank or overfill.

(g) If the cause of the alarm is determined to be non-critical, proceed with the necessary steps to investigate and correct the alarm condition. Even though the alarm isn’t “critical,” this investigation and corrective action should be a priority.

(h) Leak detection and overfill alarms shall be kept in reliable working condition. In accordance with COMAR 26.10.05.04, daily inventory control as described in COMAR

26.10.04.01 should be performed. In addition, one of the following methods of release detection shall be performed on a monthly basis:

1. Statistical Inventory Reconciliation

2. Manual Tank Gauging

3. Precision Tightness Testing

(4) UST Repairs Allowed (COMAR 26.10.04.04)

(a) Owners and operators of UST systems shall ensure that repairs will prevent releases due to structural failure or corrosion as long as the UST system is used to store regulated substances. Repairs to UST systems shall be properly conducted in accordance with the standards incorporated in COMAR 26.10.02.06.

(b) Repairs to fiberglass-reinforced plastic tanks shall be made in accordance with the manufacturer's specifications. All repairs shall be conducted under the supervision of a certified underground storage system technician certified under COMAR 26.10.06.

(c) A tank may not be repaired by installing an internal liner unless written approval is received from MDE.

(d) Metal pipes that have sections or fittings that have released a regulated substance as a result of corrosion or other damage shall be replaced. Fiberglass pipes and fittings shall be repaired in accordance with the manufacturer's specifications.

(e) Repaired tanks and piping shall be tested for tightness with a precision test before being placed back into service.

(f) Within six months following the repair of any cathodically-protected UST system, the cathodic protection system shall be tested to ensure that it is operating properly.

(g) UST system owners and operators shall maintain records of each repair for the remaining operating life of the UST system that demonstrate compliance with the requirements of this regulation.

(5) Recordkeeping

(a) UST owners/operators of the UST system shall allow MDE access to inspect the site, review documents pertaining to the UST or recovery system and retrieve environmental samples; and allow responsible parties access to the site to conduct remedial activities.

(b) UST owners/operators shall submit the following information to MDE:

1. Registration for all UST systems;

2. Reports of all releases of a regulated substance;

3. Reports of all corrective actions planned or taken;

4. Notification before permanent closure or change-in-service.

(c) UST owners/operators shall maintain the following information:

1. A corrosion expert's analysis of site corrosion potential if the analysis is required by MDE as part of an alternative method of corrosion protection;

2. Records of operation of corrosion protection equipment;

3. Records of UST system repairs pursuant to Regulation .04G of this chapter;

4. Records of compliance with release detection required by COMAR 26.10.05.06;

5. Results of the site investigation conducted at permanent closure pursuant to

COMAR 26.10.10.05;

6. Records of UST system upgrades pursuant to COMAR 26.10.03.08; and

7. An as-built diagram that includes a layout of the system tanks and piping for UST systems installed after January 1, 2006.

(d) UST owners/operators shall keep the records required either:

1. At the UST site and immediately available for inspection; or

2. At a readily available alternative site and these records shall be provided for inspection to MDE upon request.

(e) In the case of permanent closure records required under COMAR 26.10.10.05, owners and operators are also provided with the additional alternative of mailing closure records to the MDE if they cannot be kept at the site or an alternative site.

(6) Training for UST Operators. Owners of underground storage tank facilities that store, motor fuel, used oil and hazardous substances in underground storage tank (UST) systems as well as facilities that have bulk storage or operate emergency generators shall designate individuals to serve as Class A, B and C operator(s) for the facility. Class A/B/C operators shall successfully complete the required training and maintain knowledge of the skills and training requirements for UST operators in accordance with COMAR 26.10.16.

(a) Class A Operators

1. The Class A operator shall have the knowledge, skills and training to perform their primary responsibilities associated with the operation and maintenance of a UST system. This includes managing resources and personnel who will maintain compliance with regulatory requirements. To achieve a level of proficiency, an individual must have a general knowledge of UST requirements as set forth in 40 CFR 280 and COMAR

26.10.02 – 26.10.16. The Class A operator shall have proficiency in the areas of:

a. Spill prevention and reporting

b. Overfill prevention

c. Release detection

d. Corrosion protection as it is related to the tank systems involved

e. Emergency response actions

f. Product and equipment compatibility

g. Financial responsibility

h. Maryland UST registration requirements

i. Temporary and permanent closure requirements

j. Operator training and certification

k. Recordkeeping requirements

2. The Class A operator shall be immediately accessible by telephone when the facility is operating for a suspected or confirmed release, unusual operating conditions, emergencies and equipment failures. The operator shall be on-site within 24 hours of a request to respond to the facility by emergency response personnel or the MDE (or within a time approved by MDE).

(b) Class B Operators. The Class B operator shall have the knowledge, skills and training to perform their primary responsibilities associated with the operation and maintenance of a UST system. The Class B operator shall have proficiency in the areas of:

1. How to verify testing of release detection methods and release prevention equipment

2. The inspection of spill prevention, overfill prevention and corrosion protection equipment for proper operation

3. Performance of UST equipment system tests

4. Evaluation of compliance with UST equipment manufacturers and third-party performance standards

5. Emergency response and reporting procedures

6. Records completion and retention to demonstrate compliance

7. Class C operator training requirements

(c) Class C Operators.

1. Class C operators must be trained to properly monitor dispensing of regulated substances and to respond properly to a suspected or confirmed release, unusual operating conditions, emergencies and equipment failures within a UST system.

2. The Class C operator shall be immediately accessible by telephone when the facility is operating for a suspected or confirmed release, unusual operating conditions, emergencies and equipment failures. For an attended facility, the Class C operator shall be on-site and readily available whenever the facility is operating. For an unattended facility, the Class C operator shall be immediately accessible for consultation by telephone with emergency response personnel or MDE; and be on-site within 2 hours of a request to respond to the facility by emergency response personnel or the MDE or within a time approved by the MDE.

3. A Class C operator certification is facility-specific and is not valid at another regulated substance storage facility.

4. Any training required by VAMHCS will be performed on-duty time.

c. Product Delivery – UST and AST Systems

(1) Ensure that both the tank and truck are properly grounded. Ensure delivery vehicle is locked secure in place with the wheels chocked.

(2) Ensure that spill response equipment is available and all steps outlined in the SPCC/IPC have been taken.

(3) Check the condition of all equipment and piping to make sure all is in proper working order before pumping fuel.

(4) Check the fuel level of the receiving tank to prevent overfill. Document the level of the receiving tank.

(5) Connect loading/unloading hose properly. Make sure the connection is secure.

Open the discharge valve on the pump to begin fuel offloading.

(6) After delivery, shut down the pump, close the discharge valve and inspect the condition of all equipment and piping.

(7) Check the final fuel level of receiving tank. Check pre-loading value and supply slip to ensure the proper amount of fuel has been placed in the tank.

(8) Ensure all hoses or other connecting devices are drained and vented to remove any remaining liquid prior to disconnecting. Use a drip pan when breaking connections from an AST fill,

(9) Notify GEMS Coordinator/Safety and Occupational Office 45 days in advance of a planned UST closure.

d. Spill Response – UST and AST Systems

(1) Class I Spill – a spill that can be easily cleaned up by personnel at the site of the spill without risk to personal safety or the environment.

(a) If the spill begins spreading to a storm drain or surface water, it is no longer a Class I spill. Refer to Class II spill instructions.

(b) If there is a potential life, health, fire or other safety hazard, specific emergency response agency notification may be required. Refer to Class II spill instructions below.

(c) Stop the leak, prevent the spill from spreading and take steps to prevent ignition.

(d) Notify the immediate supervisor. The supervisor must notify the Safety and Occupational Health Service. Refer to Attachment A for Emergency Contact Numbers.

(e) Contain the spill using onsite containment equipment and materials.

(f) Begin steps to recover any spilled product and to clean up affected soil, groundwater and surface water.

(g) Place waste materials in a bucket for disposal by the Safety and Occupational Health Service.

(2) Class II Spill – a spill that cannot easily be cleaned up or one that may endanger human health or the environment.

(a) Remove anyone directly exposed to the spilled material, if it can be done safely, without jeopardizing your own safety.

(b) Call the VAMHCS Emergency Number (depending on location – Baltimore or Loch Raven, 911 or ext. 56999, or Perry Point, 911 or ext. 22222, see Attachment A).

Be prepared to report the following information:

1. Exact location of the spill or leak;

2. Time the spill or leak occurred, or was identified;

3. Number of injured persons, if any;

4. Name of spilled material;

5. Rate of discharge, if known;

6. Estimate of the total volume of spilled material;

7. Source of spilled material;

8. Cause of the release; and

9. Containment and clean-up action initiated.

(c) Remove all sources of ignition. Do not allow smoking, open flames or equipment operation that may generate sparks or static electricity.

(d) Stop the source of the spill when it is possible to do so without risk of personal injury. This may include shutting off valves in a pipeline and closing secondary containment valves around an above ground storage tank.

(e) Contain the spill, if possible, using on-site equipment and materials. Prevent the spill from entering storm drains or surface water.

(f) If the spill is small, begin steps to recover any spilled product and clean-up affected soil, groundwater and/or surface water.

(g) Mark the spill area off-limits to unauthorized personnel.

(h) Stand by to provide information and assistance to emergency response personnel.

6. REFERENCES

a. Executive Order 13834, Subject: Efficient Federal Operations, Energy and Environment.

b. U.S. Environmental Protection Agency, 40 CFR Part 280, Technical Standards and Corrective Action Requirements for Owners and Operators of Underground Storage Tanks

c. U.S. Environmental Protection Agency, 40 CFR Part 281, Approval of State Underground Storage Tank Programs

d. National Fire Protection Association (NFPA) 30, Flammable and Combustible Liquids Code

e. American Petroleum Institute, Standards 651 and 653

f. U.S. Department of Veterans Affairs, Veterans Health Administration, VA Maryland Health Care System, Baltimore VAMC Integrated Contingency Plan

g. U.S. Department of Veterans Affairs, Veterans Health Administration, VA Maryland Health Care System, Perry Point VAMC Integrated Contingency Plan

h. U.S. Department of Veterans Affairs, Veterans Health Administration, VA Maryland Health Care System, Loch Raven Medical Center Spill Prevention Control and Countermeasures Plan

i. Annotated Code of Maryland (COMAR) 26.10.01 through 26.10.16.

j. Facilities and Engineering Liquid Fuel Systems (Standalone and for Utilities) SOP-138/ENG-023, Liquid Fuel Systems (StandAlone and for Utilities).pdf (sharepoint.com)

7. RESCISSION

VAMHCS Policy Memorandum 512-001/OPS-S-026, Subject: Above Ground and Underground Storage Tank Management, dated July 2021.

8. REVIEW

This MCP must be reviewed at minimum at recertification and including when there are changes to the governing document (for example, national policy or a health care accreditation body mandate).

9. RECERTIFICATION

This MCP document is scheduled for recertification on/before the last day of February 28, 2027.

https://gcc02.safelinks.protection.outlook.com/ap/b-59584e83/?url=https%3A%2F%2Fdvagov.sharepoint.com%2Fsites%2FVHAVAMHCS%2Fnursing1%2FPolicies%2FVAMHCS%2520Policies%2520and%2520SOPs%2FLiquid%2520Fuel%2520Systems%2520(StandAlone%2520and%2520for%2520Utilities).pdf&data=04%7C01%7C%7Cd830cc21b4a140c2120108d9d1db773e%7Ce95f1b23abaf45ee821db7ab251ab3bf%7C0%7C0%7C637771562787921205%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=jPyazAuqJ8Ci2ZF1SYKbaaH2USMI4dRJuD4TGbqDryg%3D&reserved=0 https://gcc02.safelinks.protection.outlook.com/ap/b-59584e83/?url=https%3A%2F%2Fdvagov.sharepoint.com%2Fsites%2FVHAVAMHCS%2Fnursing1%2FPolicies%2FVAMHCS%2520Policies%2520and%2520SOPs%2FLiquid%2520Fuel%2520Systems%2520(StandAlone%2520and%2520for%2520Utilities).pdf&data=04%7C01%7C%7Cd830cc21b4a140c2120108d9d1db773e%7Ce95f1b23abaf45ee821db7ab251ab3bf%7C0%7C0%7C637771562787921205%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=jPyazAuqJ8Ci2ZF1SYKbaaH2USMI4dRJuD4TGbqDryg%3D&reserved=0

10. SIGNATORY AUTHORITY

Jonathan R. Eckman, P.E.

Director, VA Maryland Health Care System Date Approved: _____________________

NOTE: The signature remains valid until rescinded by an appropriate administrative action.

DISTRIBUTION: VAMHCS Medical Center Policies (MCP) and Standard Operating Procedures (SOPs) are available to VA employees on the VAMHCS Intranet at VAMHCS Policies, SOPs and Committee Charter SharePoint. NOTE: This is an Internal VA Web site that is not available to the public.

APPENDIX

A – Emergency Contact Numbers https://dvagov.sharepoint.com/sites/VHAVAMHCS/nursing1/Policies/VAMHCS%20Policies%20and%20SOPs/Forms/AllItems.aspx?ProcessQStringToCAML=1 https://dvagov.sharepoint.com/sites/VHAVAMHCS/nursing1/Policies/VAMHCS%20Policies%20and%20SOPs/Forms/AllItems.aspx?ProcessQStringToCAML=1

APPENDIX A

A-1

Emergency Contact Numbers Baltimore VAMC Contacts Phone Number

Spill or Fire Emergency 911 GEMS Coordinator 53053 Industrial Hygienist 53697 Safety Specialist 56316 Emergency Manager 57756

Perry Point VAMC Contacts Phone Number

Spill or Fire Emergency 22222 or 911 Chief, Safety and Occupational Health Svc 26499 GEMS Coordinator 25227 Industrial Hygienist 26499 Fire Chief 25208/25930 Safety Specialist 26915

Outside Agencies Phone Number

MDE, 24-hour Emergency response (866) 633-4686 National Response Center (800) 424-8802 U.S. EPA (Emergency response) (202) 267-2675 Baltimore City HAZMAT (410) 396-5684 or 9-911 Cecil County HAZMAT 9-911