D.7 VA WEST LOS ANGELES SPCC PLAN_2020.01.pdf

Spill Prevention, Control and Countermeasure Plan

VA Greater Los Angeles Healthcare System West LA Facility

11301 Wilshire Boulevard Los Angeles, CA 90073

ORIGINAL: January 2020

SPCC Plan January 7, 2020 VA Greater Los Angeles – West LA SLR International Corporation

Prepared for:

West LA Facility 11301 Wilshire Blvd.

Los Angeles, California 90073

This document has been prepared by SLR International Corporation.

VA Greater Los Angeles - West LA SLR International Corporation i

CONTENTS

1. PLAN CERTIFICATION AND APPROVAL

1.1 Professional Engineer’s Certification

1.2 Management Approval

2. INTRODUCTION

2.1 General Site Information

2.2 Preparation and Implementation

2.3 SPCC Plan Maintenance

2.4 Agency Required Amendment of the SPCC Plan

2.5 General Review and Plan Amendment

2.6 Conformance with SPCC Rules

2.7 Substantial Harm Determination

2.8 Conformance with State Regulations

2.9 Planned Changes at The Facility

3. SITE CHARACTERISTICS

3.1 Site Description

3.2 Industrial Activities Description

3.3 Site Drainage

4. OIL INVENTORY

4.1 Bulk Storage Containers

4.1.1 Underground Storage Tank

4.1.2 Partially Buried Storage Tank

4.1.3 Internal Heating Coils

4.2 Oil-Containing Equipment

4.3 Stormwater and Wastewater Treatment Equipment

4.4 Potential for Equipment Failure

4.4.1 Above Ground Storage Tanks

4.4.2 Portable Storage Containers

5. DISCHARGE PREVENTION MEASURES

5.1 General Prevention Measures

5.2 Secondary Containment

5.2.1 Secondary Containment Drainage

5.2.2 Loading and Unloading Secondary Containment

5.3 Materials and Compatibility

5.4 Inspections and Tank Integrity Testing

5.5 Material Transfer Procedures

5.6 Personnel Training

5.7 Security Measures

5.8 Engineering Prevention Methods

CONTENTS (CONTINUED)

VA Greater Los Angeles - West LA SLR International Corporation ii

6. SPILL RESPONSE PROCEDURES

6.1 Notifications and Reporting

6.2 Identification and Inventory of Spill Response Equipment

6.2.1 Spill Clean-Up Materials

6.2.2 Fire Extinguishers

7. RECORDKEEPING REQUIREMENTS

FIGURES

Figure 1 SITE LOCATION MAPS

TABLES

Table 1 SPCC REGULATION CROSS REFERENCE TABLE Table 2 OIL-CONTAINING CONTAINER INVENTORY TABLE

APPENDICES

Appendix A: RECORD OF SPCC PLAN REVIEW AND AMENDMENT Appendix B: CERTIFICATION OF THE APPLICABILITY OF THE SUBSTANTIAL HARM

CRITERIA

Appendix C: INSPECTION CHECKLISTS, FORMS & RECORDS Appendix D: SPILL RESPONSE PROCEDURES Appendix E: SPILL REPORT FORM Appendix F: EMERGENCY NOTIFICATION CONTACTS Appendix G: TRAINING ATTENDANCE FORM

1. PLAN CERTIFICATION AND APPROVAL

1.1 PROFESSIONAL ENGINEER’S CERTIFICATION

I, Nicolas Serieys, a Professional Engineer (P.E.) in the State of California, attest that I am familiar with the provisions of Title 40 of the Code of Federal Regulations (CFR), Part 112, and I or my agent have visited and examined the VA Greater Los Angeles - West LA Facility. I certify that this Spill Prevention, Control and Countermeasure Plan has been prepared in accordance with good engineering practices, applicable industry standards, and with the requirements of 40 CFR 112. Procedures for required inspections and testing have been established, and this SPCC Plan is adequate for this facility with Compliance Items noted on the reverse of this page.

The plan is valid for five years from the date noted below.

Printed Name of P.E.: Nicolas Serieys, P.E.

Signature of P.E.:

Registration Number: M 36315

Date: 01/07/20

Seal and Signature of Professional Engineer:

1.2 MANAGEMENT APPROVAL

I hereby certify that this Spill Prevention, Control and Countermeasure Plan has the full approval of management and that I have the management authority to commit the necessary resources toward spill prevention. I further certify that should a spill escape secondary containment systems, VA Greater Los Angeles - West LA Facility will commit the necessary manpower, equipment, and materials required to expeditiously control and remove harmful quantities of the spilled product.

Printed Name of Official: Joseph P. Olson

Title of Official: Environmental Engineer

Signature of Official:

2. INTRODUCTION

2.1 GENERAL SITE INFORMATION

Facility Name: VA Greater Los Angeles - West LA Facility

Facility Address: 11301 Wilshire Blvd.

City and State: Los Angeles, California 90073

Facility Telephone Number: (310) 478-3711

Facility Type: Healthcare Facility

NAICS Codes: 622110 and 621399

Facility Size (Acres): Approximately 350 Acres

Facility Oil Storage Capacity: Approximately 180,595 gallons

Environmental Engineer: Joseph Olson

Chief, Occupational Safety and Health: Ben Spivey

The Facilities Manager reports directly to environmental management and is responsible for discharge prevention by maintaining and implementing this SPCC Plan.

2.2 PREPARATION AND IMPLEMENTATION

This Spill Prevention, Control and Countermeasures (SPCC) Plan is required by the United States Environmental Protection Agency (USEPA) regulations contained in Title 40 of the Code of Federal Regulations, Part 112 (40 CFR 112 – SPCC Rules). This Plan meets the requirements of the updated rule published in the July 17, 2002 Federal Register and any amendments up to the date of this plan. These regulations are applicable 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 into or upon the navigable waters of the United States or adjoining shorelines.

A facility is subject to the SPCC Rules if the total aboveground storage capacity of oil and oil products exceeds 1,320 gallons; or if the underground storage capacity exceeds 42,000 gallons;

and if, because of its location, the facility could reasonably be expected to discharge oil into navigable waters of the United States. Oil-filled containers and oil-filled equipment with a capacity of less than 55 gallons are not included in the total storage capacity of the facility and are exempted from requirements under the SPCC Rules. The West LA Facility stores over 10,000 gallons of oil-based products and discharges could potentially reach the Sawtelle Channel, Ballona Creek, or the Santa Monica through storm sewer drains onsite.

2.3 SPCC PLAN MAINTENANCE

The Occupational Safety and Health Operations at the Site will maintain the most updated copy of this SPCC Plan and will also be responsible for ongoing maintenance of the Plan. SPCC Plan review and amendment is further explained in Sections 2.4 and 2.5. Copies of the Plan will also be available, upon request, to the USEPA Regional Administrator or a duly authorized representative for onsite review during normal working hours. The facility will submit copies of this SPCC Plan to the USEPA and to the California Environmental Protection Agency (CalEPA) appointed Certified Unified Program Agency (CUPA) upon request. The plan can also be obtained from electronic storage on the VA Greater Los Angeles network.

2.4 AGENCY REQUIRED AMENDMENT OF THE SPCC PLAN

The USEPA Regional Administrator may require the facility to modify its SPCC Plan in response to a spill event, if the spill meets either of the following conditions:

Discharge from a single spill event exceeding 1,000 gallons; or

Discharge from two spill events within a 12-month period that are in excess of 42 gallons, as defined in 40 CFR Part 112.1(b).

In the event of a spill, always contact a supervisor, so the proper notifications can be made, within the required times, as described in Section 6.1. When spills meet the above criteria, in addition to the notifications described in Section 6.1, the following information must be provided to the USEPA Regional Administrator and California Environmental Protection Agency (CalEPA), within 60 days from the time the facility became subject to this requirement:

1. Name of the facility.

2. Name of the owner, or operator, of the facility.

3. Location of the facility.

4. Maximum storage or handling capacity of the facility and normal daily throughput.

5. The corrective actions or countermeasures taken, including an adequate description of equipment repair or replacement.

6. Description of the facility, including maps, flow diagrams, and topographical maps.

7. The cause(s) of the spill, including a failure analysis of systems or subsystems.

8. Additional preventive measures taken or contemplated to minimize the possibility of recurrence.

9. Other information pertinent to the Plan or spill event that the Regional Administrator may reasonably require.

Upon review, the USEPA may require the facility to amend the SPCC Plan. Within 30 days from receipt of such notice, the facility would be required to submit an acceptance or appeal of the proposed amendment. If the facility accepts the amendment, the SPCC Plan would be revised within 30 days after receiving notice or at another specified date. If the amendment is appealed, the USEPA may request additional information and then render a decision within 60 days of receiving the appeal. The West LA Facility would be notified of the decision so that necessary actions may be taken.

2.5 GENERAL REVIEW AND PLAN AMENDMENT

This SPCC Plan will be amended within six (6) months of a change in the facility design, construction, operation or maintenance occurs which materially affects the facility’s potential for the discharge of oil into or upon the navigable waters of the United States or adjoining shorelines. An amendment will be prepared within six (6) months, and implemented as soon as possible, but not later than six (6) months following preparation of the amendment. Examples of non-technical amendments and technical amendments, which require Professional Engineer (PE) review and certification, are identified in the list below.

Non-Technical Amendments

Examples of changes may include, but are not limited to, phone numbers, name changes, any non-technical text change(s) and any facility reconfiguration that facility management determines does not materially affect the facility’s potential to discharge oil.

A PE does not certify non-technical amendments.

Technical Amendments

A PE must certify technical amendments.

Examples of changes may include, but are not limited to, commissioning or decommissioning containers; replacement, reconstruction or movement of containers;

reconstruction, replacements or installation of piping systems; construction or demolition that might alter secondary containment structures; changes of product or service; or addition/deletion of standard operation or maintenance procedures related to discharge prevention measures. It is the responsibility of the facility to determine and confirm with the regulatory authority as necessary, what constitutes a technical amendment. The preamble of the rule states that an amendment is required only "when there is a change that materially affects the facility’s potential to discharge oil" (67 FR 47091).

An amendment made under this section will be prepared within six (6) months of the change and implemented as soon as possible but not later than six (6) months following preparation of the amendment.

Technical amendments affecting various pages within the plan can be PE certified on those pages, certifying those amendments only and will be documented on the log form located in Appendix A.

2.6 CONFORMANCE WITH SPCC RULES

This SPCC Plan incorporates all applicable parts of the SPCC Rules. The Plan is organized to present the required information in a concise and understandable format, easily understood by spill responders at the facility. A SPCC Plan Checklist and Cross-Reference table has been included as Table 1.

2.7 SUBSTANTIAL HARM DETERMINATION

The facility has been inspected and reviewed with respect to the Applicability of the Substantial Harm Criteria described in 40 CFR 112.20(e). The “Certification of the Applicability of the Substantial Harm Criteria” form has been completed and included as Appendix B. The facility does not meet the substantial harm criteria and therefore, is not required to prepare a Facility Response Plan.

2.8 CONFORMANCE WITH STATE REGULATIONS

This facility has submitted a Hazardous Materials Business Emergency Plan to Los Angeles County Fire in accordance with California Health and Safety Code Chapter 6.95 Section 25504

(b) and 19 CCR Section 2729-2732.

Fuel tank installations meet California Fire Code Article 79 requirements for installation of temporary and permanent aboveground fuel tanks located outside of buildings. These requirements include:

Hazardous Materials Signage and Labeling: Warning and identification signs shall be posted to clearly identify hazards. All piping shall be labeled. (CFC §7901.9 & 7902.1.3.2)

Additional Signage: A sign shall be placed at the main electrical shut-off box identifying type and location of all normal and emergency power sources connected at that location.

(CEC §702-8a)

Fire Protection: At least one 40:BC portable fire extinguisher shall be provided near and within sight of the equipment. (UFC Standard 10-1)

Access: The required width of a fire apparatus access road (25’) shall not be obstructed in any manner, including the siting of generator/tank assemblies. (CFC §902.2.4.)

2.9 PLANNED CHANGES AT THE FACILITY

There are no current plan changes at the facility.

3. SITE CHARACTERISTICS

3.1 SITE DESCRIPTION

The West LA Facility’s primary mission is to provide medical care and services to America’s military Veterans. Services on campus include medical, surgical and quality of life needs for Veterans.

FACILITIES FOR PATIENTS AND STAFF:

Hospital & Research Labs Laundry Gardens Housing Athletic Field Golf Course Radiation Therapy Pharmacy Cafeteria Dental Facility Mental Health Chapel Bird Sanctuary Theater Newsstand Baseball Park Pharmacy Basketball Court

ON CAMPUS SUPPORT FACILITIES:

Garages Oil Storage and Grounds Water Treatment Plant Engineering Shops Supply Sheds Recycling Center Maintenance Shops Elevated Water Storage Hazardous Fluid Storage Police Stations Tanks Steam Plant

Activities which require on site oil storage:

Emergency generators are each equipped with a double-walled aboveground diesel storage tank.

Gas fueling station equipped with a diesel underground storage tank and a gasoline underground storage tank.

Solar Panel Electrical Transformers each hold transformer oil.

Electrical substations/transformers each hold transformer oil.

Steam Plant underground storage tanks hold diesel oil.

Portable emergency generators are each equipped with a double-walled aboveground diesel storage tank.

A summary of all oil product storage in underground storage tanks, above ground storage tanks, transformers, and in 55-gallon containers and larger, is included in Table 2. Discharge prevention measures for each container are identified. Container locations identified in the Table 2 are shown on the site map.

Total Storage = 180,595 gallons

* Rooms, buildings or areas used for the storage of hazardous materials liquid in individual containers having a capacity of more than 55-gallons or when the aggregate of multiple containers exceeds 1,000 gallons are provided with spill control or prevent the flow of liquids to adjoining areas. Floors in indoor locations and similar surfaces in outdoor locations will be constructed to contain a spill from the largest single vessel by one of the following methods:

• Liquid tight sloped or recessed floor in indoor locations or similar outdoor locations;

• Liquid tight floors provided with liquid-tight raised sills or dikes; or

• Sumps and collection systems.

Floors, sills, dikes and sumps will be constructed of noncombustible material, and the liquid-tight seal shall be compatible with the material stored.

3.2 INDUSTRIAL ACTIVITIES DESCRIPTION

The West LA Facility’s is classified by the North American Industry Classification System (NAICS) under codes 622110 and 621399. The facility is a full-service medical care center for America’s military Veterans.

3.3 SITE DRAINAGE

Storm water inlets and catch basins located on the Western and Southern area of the facility flow into lines managed by the Los Angeles County Flood Control District. Catch basins located in the southwest region of the property connect with lines managed by the City of Los Angeles.

These connections can be seen in the site maps in Appendix C. Surface drainage from the site is conveyed through storm water drainage prior to being discharged to city storm drain lines on Sawtelle Blvd and to the Los Angeles County Flood Control District lines at South Barrington Avenue. The lines discharge to the Sawtelle Channel and the Ballona Creek watershed area which eventually empties to the Santa Monica Bay.

4. OIL INVENTORY

4.1 BULK STORAGE CONTAINERS

Bulk storage containers are defined as any container used to store oil for the purpose of storing oil prior to use, while being used, or prior to further distribution in commerce. Typical bulk storage containers are aboveground storage tanks (ASTs), underground storage tanks (USTs), totes, and drums. Bulk storage containers can also be mobile or portable oil containers. Oil-filled electrical equipment and manufacturing equipment are not considered bulk storage containers.

See Section 4.2 of this SPCC Plan for the oil-containing equipment located at the facility.

Specific information for each bulk storage container including secondary containment and predicted flow at the facility is included in Table 2. Locations of oil containing areas are shown on Figure 1.

4.1.1 UNDERGROUND STORAGE TANK

There are 11 USTs located at the West LA Facility. The USTs are double walled, continuously monitored for leaks and are cathodically isolated to protect against corrosion.

4.1.2 PARTIALLY BURIED STORAGE TANK

There are no partially-buried storage tanks at the facility.

4.1.3 INTERNAL HEATING COILS

There are no internal heating coils in tanks at the facility.

4.2 OIL-CONTAINING EQUIPMENT

Oil-containing equipment such as hydraulic units, vacuum pump seal oil systems, and electrical transformers are subject to the SPCC Rules; however, oil-containing equipment is not subject to the secondary containment requirements for bulk storage containers as defined in 40 CFR 112.8(c). Specific information for the oil-containing equipment at the facility is included in Table 2 and approximate locations are shown on Figure 1. The West LA Facility may have mobile power equipment including forklifts, trucks, man-lifts, and automobiles; however, these pieces of equipment are exempt from SPCC Requirements (according to EPA-550-F-06-009). Mobile emergency generators are included as part of this plan.

4.3 STORMWATER AND WASTEWATER TREATMENT EQUIPMENT

There are no stormwater or wastewater treatment systems in place at the West LA Facility.

4.4 POTENTIAL FOR EQUIPMENT FAILURE

There are several types of equipment failure or accidents which could result in the discharge of oil from the site operations. Hypothetical releases based on general facility operations, are discussed in the following sections. Spills and releases from the West LA Facility would typically be contained within the double-walled containment, onsite buildings, or secondary containment (berms, walls, or trenches).

4.4.1 ABOVE GROUND STORAGE TANKS

Tank Failure or Leak: Failure of a fuel AST could be caused by damage to a pump, pipe, or fitting; accidental puncture; natural disaster; or other catastrophic accidental event. The total quantity that could be released varies based on the total volume of the tank, as indicated in Table 2. The rate of flow depends on the type of failure.

Damage to pump, pipe, or fitting: The rate of flow from damage to a pump, pipe, or fitting could range from a drip, up to possibly 50 gallons per minute (gpm) if flow from a tank is unobstructed.

Accidental puncture: The rate of flow from an accidental puncture could range from a drip, up to possibly 50 gpm if flow from a tank is unobstructed.

Tank Filling and Unloading Releases: Spills could occur during transfer of materials into and out of the two ASTs outside due to overfills, leaking piping connections, vehicular accident, or human error. The rate of flow and total quantity that could be released depends on the type of failure.

Overfills: The rate of flow from an overfill could be as high as 200 gpm, depending on the flow rate of the transfer pump. The total quantity that could be released depends on how long it takes to identify the overfill condition. Because delivery personnel continuously monitor transfers, it is assumed a discharge of oil would be detected and stopped within 15 seconds, limiting the total estimated quantity of discharged oil to 50 gallons.

Leaking Pipe Connections: The rate of flow from a leaking pipe connection could be as high as 1 gpm, depending on the flow rate of the transfer pump. The total quantity that could be released depends on how long it takes to identify the condition. It is assumed the leak would be detected within one hour; therefore, the estimated total quantity of oil that could be discharged is 60 gallons.

Vehicular Accident: The rate of flow from a vehicular accident could range from a minor drip to loss of the entire contents of a tanker truck or tanker truck compartment, depending on the severity of the accident.

Human Error: The rate of flow from a release caused by human error could range from a drip, to up to possibly 200 gpm if flow from a container or transfer pump is unobstructed.

4.4.2 PORTABLE STORAGE CONTAINERS

Portable Storage Containers: A release may occur due to corrosion, accidental puncture, natural disaster, or catastrophic natural event from a storage drum. Spills could also occur due to human error during material transfer. A spill from storage drums or other portable containers would flow as indicated in Table 2. The total quantity that could be released varies, based on the total volume of the container. The rate of flow depends on the type of failure.

Corrosion or Leaking Drum: The rate of flow from a corroded or leaking drum could be as high as 1 gpm.

Accidental Puncture: The rate of flow from an accidental puncture, depending on its size could range from a minor drip, to possible loss of entire contents of container

Natural Disaster or Catastrophic Accidental Event: The rate of flow could range from a drip, to the entire volume of the container being released immediately.

Human Error: The rate of flow from a release caused by human error could range from a minor drip, to possible loss of entire contents of container.

5. DISCHARGE PREVENTION MEASURES

5.1 GENERAL PREVENTION MEASURES

The following general discharge prevention measures are employed at the facility to prevent discharges from occurring.

Containment structures are kept empty of liquids and other material to provide maximum containment capacity.

When not in service or when in standby for an extended period of time, a transfer point will be securely capped or a blank-flange will be placed on the transfer point.

Piping supports have been designed to minimize abrasion and corrosion and allow for expansion and contraction.

Aboveground valves, piping, and appurtenances are inspected regularly to assess the general condition of the item. These inspections occur concurrently with the monthly visual inspections of areas and equipment (See Section 5.4)

Materials are transferred to, and removed from, ASTs only while the truck driver and/or facility employees are present and monitoring the transfer activity.

Facility employees receive training in the safe handling of oil and spill prevention and response procedures as required by their assigned jobs as described in Section 5.6.

Upon discovery, if it is safe to do so, employees will promptly take action to shut off equipment, close valves, etc. to stop any visible discharge. Any evidence of leaking seams, gaskets, piping, fittings, valves, pumps, rivets or bolts in association with a bulk storage container will be reported to supervisors, and appropriate corrective actions will be taken.

No ASTs are filled without first measuring the reserve volume (manually or through visual gauges).

To prevent accidental vehicle contact, all ASTs are completed surrounded by fences and/or concrete posts with signs identifying them.

5.2 SECONDARY CONTAINMENT

Secondary containment and the expected drainage for each bulk storage container and oil-containing equipment is described in Table 2.

In addition, the following secondary containment is typically available at the facility for most portable containers and tanks. The facility will keep all secondary containment free of debris and water.

Portable Containers: Oil containers, such as drums, are stored indoors. Drums are stored on secondary containment pallets. Secondary containment is designed in accordance with 40 CFR part 112.7(c) and will employ either “passive” or “active” design.

ASTs: ASTs are located within secondary containment that is designed in accordance with 40 CFR part 112.7(c) and will employ either “passive” or “active” design. All onsite ASTs are equipped with containment structures designed to contain the total volume of the tank to prevent release to surface water.

5.2.1 SECONDARY CONTAINMENT DRAINAGE

Drainage from containment in storage areas is detained until inspected. If there are visible signs of contamination (sheen on surface, odor, or discoloration), secondary containment will be pumped, contained in a waste drum, and disposed of as universal waste oily water in accordance with the California environmental regulations.

5.2.2 LOADING AND UNLOADING SECONDARY CONTAINMENT

There are no petroleum tank car or tank truck loading and unloading racks at the facility. The industry standard definition of a tank car/tank truck loading rack is a loading rack such as would be found at a petroleum bulk distribution terminal; therefore, secondary containment for loading and unloading areas is not required at the facility.

5.3 MATERIALS AND COMPATIBILITY

All bulk storage containers used at the facility are constructed of materials that are compatible with the materials stored in the container, under the temperatures and pressures encountered under normal operating conditions. The petroleum ASTs are non-pressurized (atmospheric) tanks constructed of welded steel.

5.4 INSPECTIONS AND TANK INTEGRITY TESTING

A visual inspection program has been established for the aboveground storage tanks at the Facility. The SPCC Designated Person(s) or designee conducts and documents a monthly inspection of all oil storage tanks. All shop-built containers with 30,000 gallons or less, that are elevated so that all sides are visible, will be visually inspected on a monthly basis.

Oil-containing tanks, drums and other portable, temporary containers are stored within secondary containment structures, indoors or in area that would prevent a release. Based on experience and good engineering practices, monthly visual inspections using the Monthly Inspection checklist, are performed on oil-filled containers at the site. An example inspection form is provided in Appendix C. Blank monthly inspection checklists are maintained onsite.

Once completed, the inspection checklists will be maintained for a period of at least three years and per internal record retention practices.

All aboveground storage tanks at the site are less than 1,100 gallons and are provided with sized secondary containment. Therefore, industry standards require routine visual inspections.

Certified integrity inspections are not required for the ASTs onsite. All USTs are inspected monthly by a certified California UST Designated Operator, with the monitoring systems certified annual and the secondary containment testes every three years in accordance with CCR Title 23.

5.5 MATERIAL TRANSFER PROCEDURES

The West LA Facility has implemented the following measures to protect oil transfer operations.

If the tanker truck hose connection is not contained, absorbent drip pads will be placed beneath the hose connection point with the truck.

Before filling any tank, onsite employees measure the volume remaining in the tank with a dip stick or other means of measurement and then oversees the entire transfer of material.

5.6 PERSONNEL TRAINING

The West LA Facility employees receive training in the safe handling of oil and spill prevention and response procedures as required by their assigned jobs. This training covers site-specific information including implementation of the facility’s SPCC Plan. New oil handling personnel receive appropriate training within a reasonable time frame upon employment. Refresher training sessions are held for facility employees that manage/handle oil annually. Training received is documented and the records kept for a minimum of three years and per internal record retention practices.

The training program is conducted or arranged by the West LA Facility environmental staff or designees. The training program addresses the correct actions to take in the event of a spill, the appropriate people to be contacted, and other pertinent information is presented in this Plan. At a minimum, the following topics are discussed:

Overall components and goals of the SPCC Plan and regulation;

Materials management and spill prevention and control practices including locations of spill control and cleanup equipment (spill kits);

Procedures for routine handling of oil products

Emergency response procedures;

Visual inspection procedures, schedules, and recordkeeping

Good housekeeping and preventive maintenance.

The training record form is located in Appendix G and completed forms are maintained with this SPCC Plan, or stored electronically, for a minimum of three years.

5.7 SECURITY MEASURES

The following security measures are employed at the West LA Facility.

The facility is monitored 24 hours a day, 7 days a week.

The facility is fully fenced, and gates are located at the entrances to the. Only authorized personnel are allowed on the facility.

The lighting design is adequate to detect spills and leaks at all storage and oil usage locations. Maintenance of light structures and bulb replacement is performed as required.

5.8 ENGINEERING PREVENTION METHODS

Engineering prevention measures, required by 40 CFR 112.8(c)(8), are used to prevent overfills during loading and unloading of bulk storage tanks and typically consist of automatic alarms, cutoffs, or leak detection system. However, these systems are not appropriate for the small ASTs and drums at the facility. The engineering prevention methods at the facility include the following.

Before filling any tank, onsite employees measure the volume remaining in the tank with a dip stick or other means of measurement and then oversees the entire transfer of material.

The large ASTs at the facility are equipped with visual level indicators; additionally all transfer operations are continually monitored by an onsite employee and/or the truck driver. Also, the tanks are filled or emptied by manually connecting the hose from the tanker truck to the top of the tank.

6. SPILL RESPONSE PROCEDURES

IN THE EVENT OF A SPILL OR THREAT OF A SPILL PLEASE REFER TO THE

APPROPRIATE RESPONSE PLAN.

6.1 NOTIFICATIONS AND REPORTING

The West LA Facility has spill response procedures for their facility; the procedures are provided in Appendix D of this SPCC Plan. The spill response procedures identify first responder emergency actions, in-house spill reporting and documentation procedures and external (agency) notifications to be made in the event of a spill. A spill report form is provided in Appendix E.

Emergency notification contacts for regulatory agencies are summarized in Appendix D and West LA Facility personnel are summarized in Appendix D and Appendix F.

6.2 IDENTIFICATION AND INVENTORY OF SPILL RESPONSE EQUIPMENT

6.2.1 SPILL CLEAN-UP MATERIALS

The West LA Facility uses spill clean-up kits as the most immediate countermeasure for management of a spill. Spill clean-up kits are strategically located throughout the facility to handle all types of spills, including oil, acid, bases, water soluble material, and solvents. The spill kits are inspected monthly by West LA Facility personnel to ensure that they are adequately stocked and easily accessible. All spills and clean-up materials will be properly managed according to their waste classification based on California regulations. Hazardous and non-hazardous wastes will be stored in compatible containers and transported offsite with an authorized transporter. The following manpower, equipment and materials are available as needed:

• Storm Drain Covers for drainage areas near oil containment areas

• Portable spill containment berms

• Sorbent material kits; and

• Subcontractor to provide material containment and clean-up in large quantities.

6.2.2 FIRE EXTINGUISHERS

Fire extinguishers are located throughout the facility. To comply with the Fire Code, fire extinguishers annually certified and are regularly checked to verify that they are operable.

7. RECORDKEEPING REQUIREMENTS

The West LA Facility has the following recordkeeping requirements as required by this SPCC Plan and the SPCC Rules. All records must be maintained onsite for a period of at least three years and per internal record retention practices. The facility shall maintain:

Secondary containment drainage visual inspection records (Section 5.2.1);

Monthly and annual visual inspection and integrity testing records (Section 5.4); and Annual SPCC training records (Section 5.6).

FIGURES

Figure 1 SITE LOCATION MAPS

NORTH ORIENTATION

Tank (AST)

Electric Transformer

UST

Storm Water Catch Basin

SPCC Site Map

North Campus

January 7, 2020

Note:

*Locations are Approximate

**Map is Not to Scale ***Unlabeled Items Unconfirmed

VA Greater Los Angeles

West LA Facility

11301 Wilshire Blvd., #2

#1

#6

#5

#3 #4

#7

#8

#34

#12 #11 #20

#19

#10

#16

#18 #17

#9

#28 #29

#27

#43

#26

#25

#13

#14

#23

#24 #15

#39

#44

#21

215G

TRANS 1&2

295 #1-4

#53 #55

#54

#56

#52

P1-9

Tank (AST)

Electric Transformer

UST

Storm Water Catch Basin

SPCC Site Map

South Campus

January 7, 2020

Note:

*Locations are Approximate

**Map is Not to Scale ***Unlabeled Items Unconfirmed

VA Greater Los Angeles

West LA Facility

11301 Wilshire Blvd., Sawtelle Ave.

#45

501 #1&2 #50

#46

#47 #51

#49

#48

January 7, 2020

SPCC Site Map

VA Greater Los Angeles

West LA Facility

11301 Wilshire Blvd., Los Angeles, CA 90073

West LA Facility

Santa Monica Bay

Ballonna Creek

TABLES

Table 1 SPCC REGULATION CROSS REFERENCE TABLE

Table 2 OIL-CONTAINING CONTAINER INVENTORY TABLE

Table 1 SPCC Regulation Cross Reference Table

Spill Prevention, Control and Countermeasure Plan

Plan Section 40 CFR Citation Description

§112.1 General Applicability

2.1 -- Operator and owner address and phone numbers

2.1* -- Facility contacts with phone numbers

3.2 -- Day-to-day operations and facility background

3.3 -- Receiving water/probable flow paths

2.2 112.1(b) Facility subject to Part 112

§112.3 Requirements to Prepare and Implement a Spill Prevention, Control and Countermeasure Plan

2.2 112.3 The facility is required to prepare in writing a SPCC Plan

1.1 112.3(d) A licensed PE has reviewed and certified the SPCC Plan

2.3 112.3(e)(1) A copy of the Plan is maintained at the facility

2.3 112.3(e)(2) A copy of the Plan is available to the Regional Administrator for review

§112.4 Amendment of Spill Prevention, Control, and Countermeasure Plan by Regional Administrator

2.4 112.4 Agency required amendment of the SPCC Plan

§112.5 Amendment of Spill Prevention, Control, and Countermeasure Plan by owners or operators

2.5 112.5 General review and amendment of the SPCC Plan

§112.7 General Requirements for Spill Prevention, Control, and Countermeasure Plan

1.2 112.7 Management approval

2.6 112.7(a)(1) Discussion of facility’s conformance with Part 112

2.6 112.7(a)(2) Must comply with the requirements of Part 112

3.1/4.1/4.2 112.7(a)(3) Describe physical layout (with diagram), which mark the location and contents of each container and include transfer stations

4.1/4.2 112.7(a)(3)(i) Address type of oil in each container and its storage capacity 5.1/5.5/5.8 112.7(a)(3)(ii) Address discharge prevention measures

5.2 112.7(a)(3)(iii) Address discharge and drainage controls (secondary containment) around containers and procedures for the control of discharge

6.2.1* 112.7(a)(3)(iv) Address countermeasures for discharge discovery, response, and cleanup 6.0* 112.7(a)(3)(v) Address methods of disposal of recovered materials

6.1* 112.7(a)(3)(vi) Include contact list and phone numbers for the facility response coordinator, NRC, cleanup contractors, and appropriate federal, state, and local agencies who must be contacted in case of a discharge

6.1* 112.7(a)(4) Provide information and procedures for reporting a discharge

6.0* 112.7(a)(5) Organize discharge procedures in a way that will make them readily available in case of an emergency

4.4/Table 2 112.7(b) Include a prediction of the direction, rate, and total quantity of oil that could be released as a result of each type of major equipment failure

5.2/Table 2 112.7(c) Provide appropriate containment and/or diversionary structures

NA 112.7(d) Description and justification for not meeting containment requirements (NA – Site meets secondary containment requirements)

5.4, 7.0 112.7(e) Conduct inspections and integrity testing, and maintain records 5.6, 7.0 112.7(f)(1) Train personnel in operations and maintenance to prevent discharge

2.1* 112.7(f)(2) Designate a person responsible for discharge prevention and reporting

5.6 112.7(f)(3) Schedule and conduct discharge prevention briefings for oil-handlers

5.7 112.7(g)(1) Fully fence each facility handling, processing, or storing oil and lock/guard the facility entrance when not in operation

Table 1 SPCC Regulation Cross Reference Table

Spill Prevention, Control and Countermeasure Plan

Plan Section 40 CFR Citation Description

5.7 112.7(g)(2) Ensure master flow and drain valves have adequate security measures and are in the closed position when not in use

5.7 112.7(g)(3) Lock the start control on each oil pump and have it accessible to only authorized personnel

5.7 112.7(g)(4) Securely cap or blank-flange loading/unloading connections or oil pipelines or facility piping

5.7 112.7(g)(5) Provide adequate facility lighting

5.2.2 112.7(h)(1) Design and install sufficient secondary containment for loading/ unloading operations

5.2.2 112.7(h)(2) Provide adequate warning/prevention systems at loading/unloading area to prevent vehicles from departing before transfer lines are disconnected

5.2.2 112.7(h)(3) Prior to filling and departure of tank car/truck, inspect for discharges of outlets to prevent liquid discharge during transit

NA 112.7(i) Evaluate field-constructed aboveground containers that undergoes maintenance for risk of discharge or failure (NA – No field-constructed oil tanks at the Site)

2.8 112.7(j) Include a complete discussion on conformance with State requirements §112.8 Spill Prevention, Control, and Countermeasure Plan Requirements for onshore facilities

5.2.1 112.8(b) & (c) Hold stored runoff in containment structure until visually inspected

5.3 112.8(c)(1) Oil storage container material compatible with content under operating pressure and temperature

5.2/Table 2 112.8(c)(2) Provide secondary containment for entire content of largest tank and sufficient freeboard to contain precipitation

5.2.1 112.8(c)(3) Do not allow drainage of uncontaminated rainwater from the diked areas into a storm drain or other surface water system

4.1.1 112.8(c)(4) Protect any completely buried metal tank from corrosion

4.1.2 112.8(c)(5) Protect any partially buried metal tank from corrosion

5.4 112.8(c)(6) Test each aboveground container on a regular schedule and when material repairs are made

4.1.3 112.8(c)(7) Control leakage through internal coils by monitoring

5.8 112.8(c)(8) Engineer or update each container installation in accordance with good engineering practice to avoid discharge

4.3 112.8(c)(9) Observe effluent treatment facilities frequently enough to detect possible system upsets

5.1* 112.8(c)(10) Promptly correct visual discharges 5.2/Table 2 112.8(c)(11) Position or locate portable oil storage containers to prevent a discharge

NA 112.8(d)(1) Provide protective coating and wrapping for buried pipes (NA – No buried oil pipes at the Site)

5.1 112.8(d)(2) Cap or blank-flange the terminal connection at the transfer point

5.1 112.8(d)(3) Properly design pipe supports

5.1 112.8(d)(4) Regularly inspect aboveground valves, piping, and appurtenances

5.1 112.8(d)(5) Warn vehicles entering the facility about aboveground piping and other oil transfer operations

§112.20 Applicability of Substantial Harm Criteria

2.7 112.20 Applicability of substantial harm criteria

* The Emergency Action Plan, Hazardous Waste Contingency Plan, and Chemical Spill and Release Notification Procedures plan include Site and department specific spill response procedures, internal reporting procedures, contacts and phone numbers, and the communication protocol.

TABLE 2

OIL-CONTAINING CONTAINER INVENTORY TABLE

Tank ID Location Tank Type Oil Type Capacity (gal) Containment Description Containment Volume (gal) Direction of Flow

Transformers

Tag #1 Outside Building 6 205 Cabinet

Transformer Oil 125.00 Concrete, spill kit 125.00 Into Containment

Tag #2 Inside Building 209

Room 3 Transformer R-temp 160.00 Floor, spill kit N/A None: interior tank

Tag #3 Outside of Building

210 at the NW corner Cabinet

Transformer Oil 175.00 Concrete, spill kit 175.00 Into Containment

Tag #4 Outside of Building

300 East Side Cabinet

Transformer Oil 360.00 Concrete, spill kit 360.00 Into Containment

Tag #5 Outside Building 158

East Side Cabinet

Transformer FR3 215.00 Concrete, spill kit 215.00 Into Containment

Tag #6 Outside Building 258 loading dock Cabinet

Transformer Oil 197.00 Concrete, spill kit 197.00 Into Containment

Tag #7 Outside Building 207 southwest Corner Cabinet

Transformer Oil 175.00 Concrete, spill kit 175.00 Into Containment

Tag #8 Outside Building 256

Southeast corner Cabinet

Transformer Oil 175.00 Concrete, spill kit 175.00 Into Containment

Tag #9 Outside Building 306

SE corner (post office) Cabinet

Transformer Oil 179.00 Concrete, spill kit 179.00 Into Containment

Tag #10 Outside Parking lot 18 next to train depot/ T-slid

Cabinet Transformer

Oil 64.00 Concrete, spill kit 64.00 Into Containment

Tag #11 Outside Building 116

Northwest side of building

Cabinet Transformer

Oil 254.00 Gravel/Concrete, spill kit 254.00 Into Containment

Tag #12 Outside Building 337 west side Cabinet

Transformer Oil 155.00 Concrete, spill kit 155.00 Into Containment

Tag #13 Outside Building 213

Northeast corner Cabinet

Transformer Oil 380.00 Concrete, spill kit 380.00 Into Containment

Tag #14 Outside Building 215 n/center of building

Cabinet Transformer

Oil 225.00 Concrete, spill kit 225.00 Into Containment

Tag #15 Outside Building 214 n/center of building

Cabinet Transformer

FR3 335.00 Concrete or Dirt, spill kit 335.00 Into Containment

Tag #16 Outside Building 114

NE side Cabinet

Transformer Oil 332.00 Concrete, spill kit 332.00 Into Containment

Tag #17 Outside Building 113 Cabinet

Transformer Oil 155.00 Concrete/Dirt, spill kit 155.00 Into Containment

Tag #18 Outside Building 113 SW corner of building

Cabinet Transformer

Oil 467.00 Concrete/Grass, spill kit 467.00 Into Containment

Tag #19 Outside Building 115 SE corner of building

Transformer Oil 220.00 Concrete, spill kit 220.00 Into Containment

Tag #20 Outside Building 115

SW Corner Transformer Oil 270.00 Concrete, spill kit 270.00 Into Containment

Tag #21 Outside Building 506 SW corner of building

Cabinet Transformer

Oil 165.00 Concrete, spill kit 165.00 Into Containment

Tag #23 Outside Building 218

NW corner Cabinet

Transformer Oil 273.00 Concrete/Grass, spill kit 273.00 Into Containment

Tag #24 Outside Building 217 East end of building

Cabinet Transformer

Oil 268.00 Concrete/Dirt, spill kit 268.00 Into Containment

Tag #25 Outside Building 224 SW corner of building

Cabinet Transformer

FR3 469.00 Concrete/Grass, spill kit 469.00 Into Containment

Tag #26 Outside Building 222 NW end of building

Cabinet Transformer

FR3 242.00 Concrete, spill kit 242.00 Into Containment

Tag #27 Outside Building 505

SW Corner of Davis & Constitution

Cabinet Transformer

Oil 194.00 Concrete/Grass, spill kit 194.00 Into Containment

Tag #28 Inside Building 508

SW door, Room 157 Transformer Oil 465.00 Floor, spill kit N/A None: interior tank

Tag #29 UCLA Ballfield/107

NW corner of parking lot 15

Transformer Oil 160.00 Dirt, spill kit 160.00 Into Containment

Tag #33 Outside Building 205 SW corner of building

Transformer FR3 218.00 Concrete, spill kit 218.00 Into Containment

Tag #34 Outside Building 257 SE corner of building

Transformer Oil 193.00 Concrete, spill kit 193.00 Into Containment

Tag #38 Outside Building 236 NW Corner of police station parking lot Transformer FR3 172.00 Concrete, spill kit 172.00 Into Containment

Tag #39 Outside Building 301 Transformer Oil 179.00 Concrete, spill kit 179.00 Into Containment

Tag #43 Outside Building

305/Sub 4 across from Building 305

Transformer Oil 175.00 Concrete/Dirt, spill kit 175.00 Into Containment

Tag #44 Parking Lot 7 West of

Chapel/T-5L/5 Transformer Oil 123.00 Concrete, spill kit 123.00 Into Containment

Tag #45 Parking Lot 1 & 2

South of Building 501, west of Lot 1

Solar Panel Transformer

Plant Based Oil 336.00 Concrete enclosure with Gravel, spill kit 336.00 Into Containment

Tag #46 Parking Lot 4 NE side of lot Solar Panel Transformer

Plant Based Oil 259.00 Concrete enclosure with Gravel, spill kit 259.00 Into Containment

Tag #47 Parking Lot 3 & 5 SE corner of lot Solar Panel Transformer

Plant Based Oil 336.00 Concrete enclosure with Gravel, spill kit 336.00 Into Containment

Tag #48 Parking Lot 6 SE side of lot Solar Panel Transformer

Plant Based Oil 336.00 Concrete enclosure with Gravel, spill kit 336.00 Into Containment

Tag #49 Parking Lot 7 south central side of lot

Solar Panel Transformer

Plant Based Oil 161.00 Concrete enclosure with Gravel, spill kit 161.00 Into Containment

Tag #50 Parking Lot 8 NE corner of lot Solar Panel Transformer

Plant Based Oil 178.00 Concrete enclosure with Gravel, spill kit 178.00 Into Containment

Tag #51 HELIPORT* Not built yet, NE side of lot Solar Panel Transformer

Plant Based Oil 286.00 Concrete enclosure with Gravel, spill kit 286.00 Into Containment

Tag #52 Parking Lot 12/299

Across from NE corner of Building 46

Solar Panel Transformer

Plant Based Oil 161.00 Concrete enclosure with Gravel, spill kit 161.00 Into Containment

Tag #53 Parking Lot 38 SW

Corner Solar Panel Transformer

Plant Based Oil 286.00 Concrete enclosure with Gravel, spill kit 286.00 Into Containment

Tag #54 Parking Lot 20 west central side of lot Solar Panel Transformer

Plant Based Oil 286.00 Concrete enclosure with Gravel, spill kit 286.00 Into Containment

Tag #55 Parking Lot 49 NE

Corner near Vandergrift Ave.

Solar Panel Transformer

Plant Based Oil 205.00 Concrete enclosure with Gravel, spill kit 205.00 Into Containment

Tag #56 Parking Lot 18 north central side near Pershing Ave.

Solar Panel Transformer

Plant Based Oil 196.00 Concrete enclosure with Gravel, spill kit 196.00 Into Containment

SPCC PLAN

VA Greater Los Angeles - W. LA

SLR International Corporation

TABLE 2

OIL-CONTAINING CONTAINER INVENTORY TABLE

Tank ID Location Tank Type Oil Type Capacity (gal) Containment Description Containment Volume (gal) Direction of Flow

ASTs

Between Buildings 214 & 215 North of Parking

Area #9 AST Diesel 5,000 Double-walled tank, sorbent material, spill kit 5,000 Into Containment

116 Building 116 AST Diesel 200.00 Double-walled tank, sorbent material, spill kit 200.00 Into Containment

205 Building 205 AST Diesel 1000.00 Double-walled tank, sorbent material, spill kit 1000.00 Into Containment

205 (Belly Tank) Building 205 AST Diesel 75.00 Double-walled tank, sorbent material, spill kit 75.00 Into Containment

206 Building 206 AST Diesel 100.00 Double-walled tank, sorbent material, spill kit 100.00 Into Containment

207 Building 207 AST Diesel 100.00 Double-walled tank, sorbent material, spill kit 100.00 Into Containment

209 Building 209 AST Diesel 500.00 Double-walled tank, sorbent material, spill kit 500.00 Into Containment

210 Building 210 AST Diesel 100.00 Double-walled tank, sorbent material, spill kit 100.00 Into Containment

215G Building 215 AST Diesel 20000.00 Double-walled tank, sorbent material, spill kit 20000.00 Into Containment

222 Building 222 AST Diesel 1525.00 Double-walled tank, sorbent material, spill kit 1525.00 Into Containment

236 Building 236 AST Diesel 700.00 Double-walled tank, sorbent material, spill kit 700.00 Into Containment

236 (Belly Tank) Building 236 AST Diesel 75.00 Double-walled tank, sorbent material, spill kit 75.00 Into Containment

299 Transportation Yard AST Diesel 2000.00 Double-walled tank, sorbent material, spill kit 2000.00 Into Containment

Between

Building 256 & 232,351,354

AST Diesel 100.00 Double-walled tank, sorbent material, spill kit 100.00 Into Containment

Between

Building 256 & 257 AST Diesel 1000.00 Double-walled tank, sorbent material, spill kit 1000.00 Into Containment

300 Building 300 AST Diesel 75.00 Double-walled tank, sorbent material, spill kit 75.00 Into Containment

314 Building 314 AST Used Oil 300.00 Double-walled tank, sorbent material, spill kit 300.00 Into Containment

401 Building 401 AST Lubricant Oil 150.00 Floor, spill kit N/A None: interior tank

402 Building 402 AST Lubricant Oil 150.00 Floor, spill kit N/A None: interior tank

501 Building 501 AST Diesel 20000.00 Double-walled tank, sorbent material, spill kit 20000.00 N/A

P1 Storage Area near

Transportation Yard Portable

Generator Diesel 225.00 Double-walled tank, sorbent material, spill kit 225.00 N/A

P2 Storage Area near

Transportation Yard Portable

Generator Diesel 225.00 Double-walled tank, sorbent material, spill kit 225.00 N/A

P3 Storage Area near

Transportation Yard Portable

Generator Diesel 225.00 Double-walled tank, sorbent material, spill kit 225.00 N/A

P4 Storage Area near

Transportation Yard Portable

Generator Diesel 225.00 Double-walled tank, sorbent material, spill kit 225.00 N/A

P5 Storage Area near

Transportation Yard Portable

Generator Diesel 225.00 Double-walled tank, sorbent material, spill kit 225.00 N/A

P6 Storage Area near

Transportation Yard Portable

Generator Diesel 225.00 Double-walled tank, sorbent material,…