36C26119Q0918-006.docx

Health Care System Memorandum No. 138-18-25 May 25, 2018

VETERANS AFFAIRS PALO ALTO HEALTH CARE SYSTEM

3801 Miranda Avenue Palo Alto, CA 94304-1290

Effective Date: Unknown Issue Date: May 25, 2018

HEALTH CARE SYSTEM MEMORANDUM No. 138-18-25

SUBJECT: MONITORING REQUIREMENTS FOR PETROLEUM STORAGE AND DISPENSING TANKS

1. SUMMARY: Health Care System Memorandum (HCSM) No. 138-14-25, dated May 13, 2014, is rescinded. Minor changes have been made.

2. PURPOSE: To establish policy and procedures for monitoring and testing of petroleum leak monitors and alarm systems for underground storage tanks (UST), above ground storage tanks (AST), and fuel dispensing stations (see Attachment A).

3. POLICY: It is the policy of the VA Palo Alto Health Care System (VAPAHCS) to adhere to all environmental regulatory agency requirements governing petroleum UST, AST, and fuel dispensing stations.

4. PROCEDURES:

a. Engineering Service shall be responsible for inspections, testing, certification, and maintenance/repairs of all petroleum UST, AST, and fuel dispensing and monitoring stations.

b. Inspections: Inspections, testing procedures, and documentation shall be performed on a daily, weekly, monthly, annual, and tri–annual basis as per federal, state, and local authority having jurisdiction requirements and regulations as outlined below.

(1) Weekly Inspections: Pump pressurized fuel product lines located at the Palo Alto Division in Buildings 103 and 41; Menlo Park Division Building 114; and Livermore Division Building 6.

(2) Monthly Inspections: All petroleum UST and AST tanks, fuel piping, monitoring systems, and fuel dispensing stations for all locations are listed in Attachment A.

(3) Annual Inspection/Testing: All petroleum USTs shall be annually inspected by local authority mandated inspection requirements, and/or other entities that have legal jurisdiction, and authority to inspect. Components annually inspected and/or certified shall include but are not limited to, fuel system delivery systems, source testing, tank integrity, monitoring of tanks and related piping, vapor recovery, documentation compliance, and review of training requirements.

(4) Tri-annual Inspections: All UST tanks following California Code (CA) 2637 secondary containment testing.

c. Documentation: Inspections, testing, certification, and the maintenance and repair of petroleum UST, AST, and fuel dispensing stations shall be recorded, documented, and maintained by the Designated Underground Operator and Engineering Service. All records shall be in compliance and in accordance with federal, state, and local authorities having jurisdictional requirements. All records and documentation shall be maintained for a minimum of 36 months.

d. In case of an unauthorized spill/release, the Safety Officer, Chief Engineer, and the facility Green Environmental Management System (GEMS) Coordinators will be notified immediately and given the location, type, and approximate amount of material released. All remedial actions and efforts will comply with the facility’s spill prevention control and countermeasure plan. Environmental deficiencies noted during inspections shall be reported to the GEMS Coordinator upon notice from the local authority having jurisdiction.

e. Qualified Employees: Engineering Service shall designate the following positions and associated duties as follows:

(1) The designated underground storage tank operator is responsible for training facility employees and conducting monthly visual inspections of USTs. The designated operator shall possess a current certificate issued by the International Code Council (ICC) indicating that he or she has passed the California UST System Operator exam.

(2) The facility employee is an employee on site who may be called upon to respond to spills, overfills, or other problems associated with the operation of the USTs.

f. Training: On a bi-annual basis, the Designated Operator shall document that he or she has a current certificate issued by the ICC indicating that he or she passed the California UST System Operator exam. On an annual basis, employees who have responsibility associated with the operation and/or maintenance of UST’s shall be trained in the operation of UST systems, employee’s role in monitoring the UST equipment, spill and overfill response plan, and emergent notification processes.

5. RESPONSIBILITIES:

a. The Chief, Engineering Service, will be responsible for the overall functions, compliance, and employee training of petroleum UST, AST, and fuel dispensing stations/systems.

b. The Engineering Compliance Manager or his or her designee shall be responsible for oversight of all petroleum UST, AST, and fuel service stations inspections, testing, certification, maintenance and repair, and documentation.

c. The Engineering Compliance Manager and Boiler Plant Supervisor or their designees shall be responsible for the implementation, scheduling, and reporting of UST and AST repairs/maintenance; daily and weekly inspections; and monitoring of product level, product quality, and emergent response to alarms under their direct supervision or responsibility.

d. The Engineering Compliance Manager or designee shall be responsible for Bay Area Air Quality Management District (BAAQMD) oversight of fuel dispensing stations. The Compliance Manager or designee shall schedule and verify inspections and repairs and maintain records documenting compliance of BAAQMD standards and requirements.

e. The Chief of Operations or designee shall be responsible for the ordering, delivery, and scheduling of petroleum UST/AST fuel tank refilling. Filling procedures shall comply with the Facilities Spill Prevention, control, and countermeasure plan. Tanks shall be maintained at eighty percent or greater capacity at all times.

f. The Facility GEMS Coordinators shall be responsible for reviewing and reporting any unauthorized spills/leaks to the proper authorities and coordinating the cleanup and proper disposal of any hazardous material.

6. REFERENCES:

a. 40 Code of Federal Regulations (CFR) 260, Hazardous Waste Management System.

b. 40 CFR 262, Standards Applicable to Generators of Hazardous Waste.

c. 40 CFR 280, Technical Standards and Corrective Action Requirements for Owners and Operators of Underground Storage Tanks.

d. 40 CFR 282, Approved Underground Storage Tank Programs.

e. BAAQMD, Regulation 8, Rule 7, Gasoline Dispensing Facilities.

f. 40 CFR 112, Spill Prevention Control and Countermeasure Plan.

7. RESCISSION DATE: May 31, 2021.

8. RESPONSIBLE OFFICIAL: Chief, Engineering Service.

Thomas J. Fitzgerald III Director

Attachment