Grand Island_SPCC Plan_Jan 2023_.pdf

Spill Prevention, Control, and Countermeasure Plan

Veterans A�airs Medical Center Grand Island, Nebraska

Prepared for:

United States Department of Veterans A�airs Nebraska-Western Iowa Health Care System Omaha, Nebraska

January 2023 Prepared by:

Scout Environmental 169 Saxony Road, Suite 214 Encinitas, CA 92024

Phone: (833) 726-8836

SPILL PREVENTION, CONTROL, AND

COUNTERMEASURE PLAN

Veterans Affairs Medical Center - Grand Island 2201 North Broadwell Avenue

Grand Island, Nebraska

Prepared for:

United States Department of Veterans Affairs Nebraska-Western Iowa Health Care System

Omaha, Nebraska

Prepared by:

Scout Environmental, Inc.

Encinitas, CA

January 2023

Veterans Affairs Medical Center - Grand Island, NE Spill Prevention, Control, and Countermeasure Plan

January 2023 Page i

FOREWORD

This document comprises the Veterans Affairs Medical Center (VAMC) – Grand Island, NE, Spill Prevention, Control, and Countermeasure (SPCC) Plan. The Plan was prepared to conform with the requirements of 40 Code of Federal Regulation (CFR) 112 and the Oil Pollution Act. This SPCC Plan documents the procedures for the prevention, response, control, and reporting of spills of oil and hazardous substances at the VAMC

– Grand Island. This document applies to all organizations and contractors at the Grand Island facility with the exception of construction and other contractors with temporary operations at the facility who are required to develop and implement their own SPCC Plans if oil storage capacity exceeds SPCC thresholds.

All spill incidents should immediately be reported to the Boiler Plant (308) 395-3400 and Veterans Affairs Police (308) 389-5198.

Specific roles, responsibilities, and procedures are included in the body of this document, including the VAMC – Grand Island Spill Response Procedures (Table 1) and Emergency Response Notification List (Table 2).

January 2023 Page ii

MANAGEMENT APPROVAL AND COMMITMENT CERTIFICATION

In accordance with 40 Code of Federal Regulations 112.7, the Veterans Affairs Medical Center (VAMC) – Grand Island, NE, is committed to the implementation of the procedures outlined in this Spill Prevention, Control and Countermeasure (SPCC) Plan and the prevention of releases of oil to navigable waters of the United States. I certify that the necessary manpower, equipment, and materials required to expeditiously control and remove any quantity of discharged oil will be provided. This SPCC Plan will be implemented as herein described. A copy of this SPCC Plan shall be maintained at the VAMC - Grand Island, NE, facility at all times and will be made available to the United States Environmental Protection Agency Regional Administrator for onsite review during normal working hours.

Signature

Printed Name

Date

Title

Robert Hailey

1/25/2023

Chief of Engineering

PROFESSIONAL ENGINEER CERTIFICATION

I hereby certify that I arn familiar with the requirements of 40 CFR 112.3; I or my ag 0 nt hav,� v,:,,t,,d ,md examined the facility; this SPCC Plan was prepared in accordance with good engine ring prar:t,o!, 1 rl d1n9 consideration of applicable industry standards and with the requirements of 40 CFR 112 3, p, oc >durP� required inspections and testing have been established; at the time of the inspection, no dcf1c1 nr1e'.J ✓1P.,e noted with respect to current SPCC regulations; and this SPCC is adequate for the VAM - Grand !�land facility.

Signature

Printed Name

Date

Registration No.

Registration State

January 2023

J�e Werner, PE

JI ?)p f 7,D2A

49309

Washington f'J � lll

January 2023 Page iv

CERTIFICATION OF THE APPLICABILITY OF THE SUBSTANTIAL HARM CRITERIA

Facility Name: Veterans Affairs Medical Center - Grand Island Facility Address: 2201 North Broadwell Avenue Grand Island, NE

1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons? Yes No _X _

2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest above-ground oil storage tank plus sufficient freeboard to allow for precipitation within any aboveground oil storage tank area? Yes No _X _

3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? Yes No _X _

4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance such that a discharge from the facility would shut down a public drinking water intake1? Yes No _X _

5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a reportable oil discharge in an amount greater than or equal to 10,000 gallons within the last 5 years? Yes No _X _

Certification

I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate, and complete.

Signature

Printed Name

Date

Title

1 For the purposes of 40 CFR part 112, public drinking water intakes are analogous to public water systems as described at 40 CFR 143.2(c).

Robert Hailey

1/25/2023

Chief of Engineering

January 2023 Page v

TABLE OF CONTENTS

1.0 INTRODUCTION

SPCC Rule Cross-Reference

2.0 FACILITY LAYOUT AND OPERATIONS

Oil Use and Storage

2.1.1 Building 1 Basement

2.1.2 Building 7 Boiler Plant

2.1.3 Building 8 Maintenance Building ASTs

2.1.4 Building 17 AST

2.1.5 Building 17 Emergency Generator and Day Tank

2.1.6 Building 18 Emergency Generator and Day Tank

2.1.7 Portable Generator

2.1.8 Transformers

2.1.9 Fuel Delivery Truck Unloading Areas

3.0 SPILL PREVENTION MEASURES AND SYSTEMS

Building 1 Basement Building 7 Boiler Plant Building 17 AST Building 17 Emergency Generator Building 18 Emergency Generator Portable Generator Transformers Fuel Delivery Truck Unloading Areas

4.0 SPILL RESPONSE

Building 1 Basement Building 7 Boiler Plant Building 17 AST Building 17 Emergency Generator Building 18 Generator Portable Generator Transformers Fuel Delivery Truck Unloading Areas

5.0 SPILL REPORTING PROCEDURE

Internal Reporting Requirements External Reporting Requirements

6.0 CERTIFICATION OF THE APPLICABILITY OF SUBSTANTIAL HARM CRITERIA

7.0 INSPECTIONS AND RECORDS

Underground Storage Tanks Aboveground Storage Tanks Day Tanks Grease Trap Transformers Spill Response Equipment

January 2023 Page vi

Post-Spill Response Equipment Inspection

8.0 PERSONNEL TRAINING AND DISCHARGE PREVENTION BRIEFINGS

Emergency Coordinators/Facility Response Team Discharge Prevention Briefings

9.0 SPCC PLAN REVIEW, AMENDMENTS AND EXCEPTIONS

Tank Alterations Exceptions

9.2.1 Hydraulic Elevators

10.0 SECURITY

TABLES

Table 1 Spill Response Procedures Table 2 Emergency Response Notification List Table 3 Contracted Supplier and Disposal Companies Table 4 Facility Oil Storage Summary Table 5 Storage Tanks Details

ATTACHMENTS

Attachment A Notification Action Summary Attachment B Spill/Release Report Attachment C SPCC Plan Review and Revision Document Log Attachment D Waste Disposal Plan Attachment E Monthly Inspection Form Attachment F Employee Training Acknowledgement Record

APPENDICES

Appendix A Completed Spill/Release Reports Appendix B Completed Monthly Inspection Forms Appendix C Completed Employee Training Acknowledgement Records

January 2023 Page 1

1.0 INTRODUCTION

This Spill Prevention, Control, and Countermeasure (SPCC) Plan has been prepared in accordance with Title 40 Code of Federal Regulations (CFR) Part 112 and revisions (effective October 14, 2010) for the Veterans Affairs Medical Center (VAMC) - Grand Island located at 2201 North Broadwell Avenue in Grand Island, Nebraska (Facility). The purpose of this SPCC Plan is to establish procedures, methods, and measures to prevent the discharge of oil and/or oil products at the Facility into or upon the navigable waters of the United States per 40 CFR Part 112. In addition, this SPCC Plan outlines containment, clean up, and reporting protocols following a discharge of oil and/or oil products at the Facility.

This SPCC Plan is specifically written to cover operations at the Facility supporting on-going health care operations identified herein. Implementation of this SPCC Plan will be the overall responsibility of the Facility and the Veterans Affairs Nebraska-Western Iowa Health Care System. This SPCC Plan must be available for on-site review by representatives of the United States Environmental Protection Agency (USEPA) during normal working hours. In addition, copies of this SPCC Plan must be available for access to persons responsible for administration of this SPCC Plan. There are currently no deviations at the Facility from this SPCC Plan requirements.

SPCC Rule Cross-Reference

As required by 40 CFR 112.7, the following, provides a cross-reference to the requirements listed in 40 CFR 112 and the equivalent requirements in this plan.

Regulation Description Page #

§112.3(a)(1) or (b) SPCC Plan prepared prior to facility becoming operational (effective 11/10/2010)

§112.3(d) Professional Engineer (PE) certification including five elements iii

§112.5(a) Amendment of SPCC Plan 24

§112.5(b) Review of Plan at least every 5 years with documentation (i.e. a log) 24/Att. C

§112.7 General Requirements for SPCC Plans for All Facilities & All Oil Types

§112.7 Management approval of Plan ii

§112.7 Discussion of facilities, procedures, methods or equipment not yet fully operational with details of installation and operational start-up

§112.7(a)(1) General requirements; discussion of facility’s conformance with rule requirements

§112.7(a)(2) Deviations from Plan requirements 1

§112.7(a)(3) Facility description and diagram, type of oil and capacity of each container, transfer stations and piping, buried containers on diagram

5-9

§112.7(a)(3)(ii) Discharge prevention measures 10-12

§112.7(a)(3)(iii) Discharge drainage controls 10-12

§112.7(a)(3)(iv) Countermeasures for discharge discovery, response and cleanup 13-15

§112.7(a)(3)(v) Methods of disposal of recovered materials in accordance with legal 13, Att. D

January 2023 Page 2

Regulation Description Page # requirements

§112.7(a)(3)(vi) Contact list and phone numbers for facility response coordinator, National Response Center, cleanup contractors, all Federal, State, and local agencies who must be contacted in case of a discharge

Table 2

§112.7(a)(4) Spill reporting information 16-18

§112.7(a)(5) Discharge procedures 13-15

§112.7(b) Failure prediction (sources, quantities, rates, and directions) 13-15

§112.7(c) Secondary containment for all areas from which a discharge of oil could occur (i.e. mobile refuelers, loading/unloading areas, transformers, oil filled operational equipment, etc.) other than bulk containers

5-9, 10-12

§112.7(d) Explanation of impracticability of secondary containment NA

§112.7(d)(1) Oil spill contingency plan per part 109 NA

§112.7(d)(2) Commitment of manpower, equipment & materials to remove a discharge ii

§112.7(e) Written procedures for inspections and tests 20-22, Att. E

§112.7(e) Records of inspections and tests signed and kept 3 years App. B, App. E

§112.7(f)(1) Employee training 23

§112.7(f)(2) Designated individual accountable for discharge prevention Table 2

§112.7(f)(3) Discharge prevention briefings scheduled and conducted annually 23

§112.7(g) Security: How oil handling, processing and storage areas are secured and access is controlled

§112.7(g) Security: How master flow and drain valves of containers are secured 5-9

§112.7(g) Security: How unauthorized access to starter controls on oil pumps is prevented

5-9

§112.7(g) Security: How out-of-service and loading/unloading connections of oil pipelines are secured

NA

§112.7(g) Security: Appropriateness of security lighting to both prevent acts of vandalism and assist in the discovery of oil discharges is addressed

§112.7(h) Loading/unloading rack (excluding offshore facilities) NA

§112.7(h)(1) Containment for contents of largest compartment NA

§112.7(h)(2) Warning light/sign, barrier system, wheel chocks, or break interlock system to prevent departure with connected lines

NA

§112.7(h)(3) Inspect drains and outlets of vehicles NA

§112.7(i) Brittle fracture or catastrophic failure evaluation requirements NA

§112.7(j) Conformance with state requirements 17-18

§112.7(k)(2)(i) Inspection procedures or monitoring program 20-22, January 2023 Page 3

Att. E

§112.7(k)(2)(ii)(A) Oil spill contingency plan per part 109 NA

§112.7(k)(2)(ii)(B) Written commitment of resources ii

§112.8, §112.12 Requirements for Onshore Facilities (excluding production)

§112.8(a), §112.12(a)

Meet general and specific requirements 1-25

§112.8(b)(1), §112.12(b)(1)

Facility drainage: Restrain drainage from diked areas; inspect accumulation NA

§112.8(b)(2), §112.12(b)(2)

Facility drainage: Manual valves to drain diked areas, inspect before discharging into watercourse

NA

§112.8(b)(3), §112.12(b)(3)

Facility drainage: Undiked drainage with a potential for a discharge designed to flow to ponds, lagoons, or catchment basins

NA

§112.8(b)(4), §112.12(b)(4)

Facility drainage: Final discharge of ditch drainage controlled NA

§112.8(b)(5), §112.12(b)(5)

Facility drainage: Where pump transfer is needed, two lift pumps installed with one installed permanently

NA

§112.8(c), §112.12(c)

Bulk storage containers: 5-9, Tables 4 and 5

§112.8(c)(1), §112.12(c)(1)

Containers compatible with material and conditions of storage 5-9, Tables 4 and 5

§112.8(c)(2), §112.12(c)(2)

Secondary containment for capacity of largest container and sufficient freeboard for precipitation

5-9, Tables 4 and 5

§112.8(c)(3), §112.12(c)(3)

Not allow drainage of rainwater from diked areas unless inspected, records kept of drainage events

NA

§112.8(c)(4), §112.12(c)(4)

Completely buried metallic containers corrosion protected, leak testing conducted

NA

§112.8(c)(5), §112.12(c)(5)

Partially buried containers corrosion protected NA

§112.8(c)(6), §112.12(c)(6)

Integrity testing, visual plus non-destructive shell testing, comparison records kept

20-22

§112.8(c)(7), §112.12(c)(7)

Internal heating coils monitored NA

§112.8(c)(7), §112.12(c)(7)

Internal heating coils monitored NA

§112.8(c)(8), §112.12(c)(8)

Containers engineered to prevent discharges 5-9, Tables 4 and 5

§112.8(c)(8)(v), Liquid level sensing devices tested to ensure proper operation 20-22, January 2023 Page 4

§112.12(c)(8)(v) Att. E

§112.8(c)(9), §112.12(c)(9)

Observe effluent treatment facilities to detect system upsets NA

§112.8(c)(10), §112.12(c)(10)

Correct visible leaks and remove accumulations of oil 20-22, Att. E

§112.8(c)(11), §112.12(c)(11)

Secondary containment for mobile/portable containers with capacity of largest container & sufficient freeboard for precipitation

5-9, Tables 4 and 5

§112.8(d), §112.12(d)

Facility transfer operations, pumping and facility process: NA

§112.8(d)(1), §112.12(d)(1)

Buried piping installed or replaced after 8/16/02 corrosion protected NA

§112.8(d)(2), §112.12(d)(2)

Terminal connections capped/blank flanged when not in service or in standby service for an extended time

NA

§112.8(d)(3), §112.12(d)(3)

Pipe supports properly designed NA

§112.8(d)(4), §112.12(d)(4)

Inspect aboveground piping, integrity and leak test buried piping NA

§112.8(d)(5), §112.12(d)(5)

Warn vehicles of aboveground piping NA

§112.20(e) Completed and Signed Certification of Substantial Harm Form iv

January 2023 Page 5

2.0 FACILITY LAYOUT AND OPERATIONS

The VAMC - Grand Island consists of a central five-story building (Building 1) and eleven smaller outbuildings situated on approximately 27.26 acres. The Facility’s buildings are primarily brick and mortar construction. The Facility includes asphalt and concrete parking lots, asphalt and concrete driveways and a grassy and landscaped lawn area. A Site Vicinity Plan is provided as Figure 1 and a detailed Site Plan is provided as Figure 2.

The Facility’s main building, Building 1, is the Facility’s central five-story medical care building. Additional facility operations occupy the Boiler Plant Building (Building 7), Maintenance Building (Building 8), and Engineering Building (Building 6), with maintenance areas located on the southeast portion of the Facility.

Building identification numbers are provided on the Site Plan.

Onsite operations consist of outpatient and limited inpatient medical care for United States military veterans. The VAMC - Grand Island offers a Community-Based Outpatient Clinic (CBOC), which provides primary health care services, some specialty health care services, and mental health services to veterans in the Grand Island area. Additionally, the Grand Island Facility offers a 65-bed Community Living Center, which provides extended care services, rehabilitation, geriatric care, palliative care, respite care, supportive/restorative care, long-term care, and general nursing home care. The Grand Island Facility also offers a Residential Substance Abuse Unit.

There are currently no facilities, procedures, methods, or equipment that is not yet fully operational at the facility.

Oil Use and Storage

Certain on-site operations require the storage and use of various oil and petroleum-based products.

Specifically, in the event of an emergency power outage, the Facility operates emergency generators which use diesel fuel as the primary fuel source. The Facility stores reserve diesel fuel in two, 20,000-gallon underground storage tanks (USTs) (exempt from the SPCC Rule requirements) adjacent to Building 7, and one, 1,000-gallon aboveground storage tank (AST) adjacent to Building 17. Additionally, the Facility operates several oil-containing electrical transformers and stores small quantities of oil and petroleum-based products throughout the Boiler Plant and Building 1 basement. Oil and petroleum-based AST and UST details are provided in Table 4 and Table 5. The following subsections describe materials storage for the Facility.

2.1.1 Building 1 Basement

The Building 1 sub-basement, located beneath the C17 Basement, contains a 300-gallon grease trap. The grease trap captures spent cooking grease generated during Facility food preparation and is serviced and emptied by a contractor at least once annually. Records of service to the grease trap are located in the Boiler Plant.

The sub-basement area is locked at all times and are only accessible to authorized Facility personnel.

Figure 1 Site Loca on and Overview

Updated: February 21, 2020

Approximate Subject Property Boundary

Legend

Department of Veteran Affairs Grand Island VA Health Care Facility

2201 North Broadwell Avenue Grand Island, Nebraska

Vicinity Map

Source: Google Satellite, 2020. Site boundary provided by VA.

Prepared by: JAW 2/20/2020

Prepared by / Date: JAW 2/21/2020

Sources: Site reconnaissance performed by Jason Strayer and Dean Bender on October 10, 2019, plot plan provided by Department of Veterans Affairs.

Portable Generator Storage 500-gallon belly tank

(Diesel)

20,000-gallon USTs (Diesel) EXEMPT

Figure 2

Site Plan

Updated: October, 2022

75-gallon Day Tank (Diesel)

(Underground) ie

January 2023 Page 8

2.1.2 Building 7 Boiler Plant

The Boiler Plant (Building 7), is located on the southeast portion of the medical center Facility and is accessible via North Wheeler Avenue. The Facility’s two, 20,000-gallon diesel USTs are located immediately west of the Boiler Plant Building and are used as the primary fuel source for the Boiler Plant emergency generator and as a secondary fuel source for the Facility’s three boilers. The two diesel USTs were installed in 1981 and are constructed of fiberglass reinforced plastic with double-walled steel piping. According to Facility operations staff, the tanks are kept at full capacity with diesel fuel at all times.

These USTs are managed in accordance with the requirements of 40 CFR 280, Technical Standards and Corrective Action Requirements for Owners and Operators of Underground Storage Tanks and are therefore exempt from the SPCC Rule requirements; however, VA management has elected to include them as part of their SPCC plan inspection program as a “best management practice.”

2.1.3 Building 8 Facilities Maintenance ASTs

Building 8 is located in the southeast corner of the property and serves as the facility maintenance building.

Two ASTs are located off the southeast corner of the building and include a 300-gallon unleaded gasoline AST and a 300-gallon diesel AST. The ASTs are located on a concrete pad, are double-walled tanks, and are used exclusively to fuel facility vehicles and grounds maintenance equipment.

2.1.4 Building 17 AST

Building 17, an approximately 1,700-square foot building adjoining the east-central portion of Building 1, is also used to support Facility operations. The Facility’s 1,000-gallon diesel AST is located within a fenced enclosure immediately east of Building 17. The AST was installed in 1994, is constructed of double-walled steel, and is vaulted and mounted on a cement pad.

2.1.5 Building 17 Emergency Generator and Day Tank

The eastern portion of Building 17 houses the emergency generator for Building 1, and the associated double-walled steel, 75-gallon capacity diesel day tank. The day tank is maintained at full capacity with diesel fuel at all times to provide an immediate fuel source for the Building 1 emergency generator. Building 17 is locked at all times and is only accessible to authorized Facility personnel. No floor drains are present in Building 17.

2.1.6 Building 18 Emergency Generator and Day Tank

Building 18 is a small building located adjacent to the northeast corner of the Boiler Plant and houses the Boiler Plant emergency generator. Double-walled steel piping routes diesel fuel from the two diesel USTs to a double-walled steel, 75-gallon capacity diesel day tank present in Building 18. The day tank is maintained at full capacity with diesel fuel at all times to provide an immediate fuel source for the Boiler Plant emergency generator.

2.1.7 Portable Generator

The Facility maintains a portable generator with an integrated (i.e., belly tank) 500-gallon diesel tank which is utilized as needed across the Facility. The portable generator has a steel, double-walled diesel tank.

When not in use, the generator is stored within Building 8.

January 2023 Page 9

2.1.8 Transformers

The Facility maintains a total of five pad-mounted, mineral oil-containing electrical transformers, in separate locations around the Facility, and have been assigned the following numerical designations.

Transformer Number Location Transformer

Type Oil Capacity

(gallons) Oil Type

1 Outside, South of Building 17 Pad mounted 453 Mineral oil 2 Outside, South of Building 17 Pad mounted 455 Mineral oil 3 Outside, West of Building 11 and 4 Pad mounted 310 Mineral oil 4 Outside, East of Building 18 Pad mounted 260 Mineral oil 5 Outside, Southeast of Building 7 Pad mounted 423 Mineral oil

2.1.9 Fuel Delivery Truck Unloading Areas

Petroleum product transfers occur in the driveway west of the Boiler Plant (in the area of the USTs), in the driveway east of Building 17 (AST area), and near the shipping and receiving docks present on the east-central side of Building 1. If needed, other petroleum products are delivered in totes or drums and transported by fork trucks or dollies. One storm sewer drain, routed to the municipal storm sewer, is located in the paved driveway area approximately 20 feet the USTs in the fuel unloading area.

January 2023 Page 10

3.0 SPILL PREVENTION MEASURES AND SYSTEMS

Pursuant to 40 CFR 112.7(b), this SPCC Plan identifies machinery, storage containers, and/or operations that could reasonably result in failure. Further, pursuant to 40 CFR 112.7(c), this SPCC Plan documents the appropriate containment and/or diversionary structures or equipment to prevent a discharge of oil in the event of such failure. Containment systems (including walls and floor) must be capable of containing discharged oil and constructed so a discharge will not escape the containment system before cleanup can occur. Additionally, the Facility has implemented a monthly inspection program to support spill prevention efforts (see Section 7.0 and Attachment E).

All personnel responsible for handling or dispensing petroleum products will participate in the spill prevention and control training program. Additional detail is provided in Section 9.0.

The VA Nebraska-Western Iowa Health Care System is committed to providing the required manpower, equipment, facilities, and materials to establish precautionary measures to expeditiously implement corrective actions, including the control and removal of a release of oil and oil product discharged from the Grand Island Facility.

Building 1 Basement

The Building 1 sub-basement has a maximum capacity of 300-gallons of oil-containing products at one time (i.e., the grease trap). Both the sub-basement and C17 basement areas are locked at all times and are only accessible to authorized Facility personnel.

Building 7 Boiler Plant

Several security and overfill protection measures are in place for the 20,000-gallon diesel USTs, including an automatic tank monitoring system, a locked fill port policy, a tank overfill alarm, and nighttime security lighting. Additionally, Veterans Affairs police officers and Facility operations staff members are present at the Facility twenty-four hours a day, seven days a week. Facility personnel provide oversight during any tank fueling operations.

Building 8 Facilities Maintenance ASTs

The two 300-gallon ASTs at Building 8 are double-walled tanks with internal fuel level gauges. The tanks are pad mounted and no storm drains are present within the immediate vicinity of the ASTs. Access to the area is secured via locked fencing. Additionally, police officers are present at the Facility twenty-four hours a day, seven days a week and provide regular visual inspections of the area.

Building 17 AST

The 1,000-gallon diesel AST present east of Building 17 is a vaulted double-walled steel tank and Underwriters Laboratories (UL) 2085 listed. The tank is pad-mounted. No storm drains are present within the immediate vicinity of the AST. Security and overfill protection measures in place at the 1,000-gallon diesel AST location include an automatic tank monitoring system, a locked fill port policy, security fencing, precautionary signage, a tank overfill alarm, and nighttime security lighting. Additionally, police officers and Facility operations staff members are present at the Facility twenty-four hours a day, seven days a week.

Facility personnel provide oversight during any tank fueling operations.

January 2023 Page 11

Building 17 Emergency Generator

The eastern portion of Building 17 houses the Building 1 emergency generator and a double-walled steel, 75-gallon capacity diesel day tank. Building 17 is locked at all times and is only accessible to authorized Facility personnel. No floor drains are present in Building 17.

Building 18 Emergency Generator

Building 18, the location of the Boiler Plant emergency generator and 75-gallon double-walled diesel day tank, is locked at all times and is only accessible to authorized Facility personnel. No floor drains are present in Building 18.

Portable Generator

The portable generator has an integrated 500-gallon steel, double-walled diesel tank. The generator is stored inside Building 8, in a secure area when not in use. Prior to use the generator is inspected for any degradation, corrosion, and/or leaks.

Transformers

The Facility maintains a total of five pad-mounted, oil-containing electrical transformers, in separate locations around the Facility, which have been assigned a numerical designation (1 to 5). Each transformer is located within a locked steel cabinet which is only accessible to the Facility’s electrician. Additionally, police officers and Facility operations staff members are present at the Facility twenty-four hours a day, seven days a week and regularly provide surveillance of these transformers.

Additional efforts to prevent, detect, and contain possible spills or maintenance issues include monthly transformer inspections (see Attachment E), impermeable concrete pads beneath transformers, and available spill kits.

Fuel Delivery Truck Unloading Areas

According to Facility operations staff, fuel deliveries to the Grand Island Facility are rare, as the diesel fuel stored in the on-site USTs and AST is only used in case of emergency. Though fuel deliveries occur less than once annually, designated employees are trained in spill control procedures associated with fuel delivery, as tank trucks brought on site for fuel deliveries could potentially hold up to approximately 9,000 gallons of diesel fuel.

When it does occur, tank trucks are used to deliver diesel fuel to the Facility’s USTs and AST. The Grand Island Facility typically contracts with private fuel supply and delivery companies. Prior to tank truck fuel deliveries, Grand Island Facility staff members will 1) review and approve the fuel contractor’s Spill Control Plan or other appropriate procedures, and 2) inspect the tank truck driver’s spill containment equipment. If the fuel delivery contractor fails to provide the Facility with its Spill Control Plan or fails to demonstrate possession of adequate spill containment equipment, the fuel delivery may not proceed. Only Grand Island Facility SPCC-plan trained employees oversee the fueling operations.

The following highlights the general tank unloading procedures that will be implemented at the Facility:

• Driver will engage brake interlock at all times during delivery.

January 2023 Page 12

• Driver will use dipstick or other direct measuring method to confirm amount of material to be delivered/pick-up.

• Driver will deploy spill containment equipment as required by their procedures during delivery/pick-up.

• Driver will never leave the truck unattended and will stamp delivery ticket to confirm amount.

• Driver will ensure no smoking or ignition sources are present during delivery.

• Driver will report any spills to Grand Island Facility staff and their respective dispatch desk immediately.

• Driver’s Spill Control Plan will be initiated if necessary.

The contents of the USTs and AST will be measured prior to unloading to prevent overfilling. Truck drivers will be directed to immediately shut off all pumping equipment and contact one of the Emergency Coordinators (see Table 2) if any overfilling should occur.

Facility loading/unloading procedures require all hoses to be properly connected and disconnected to avoid spills or leaks. Non-facility delivery personnel cannot load or unload materials without notification of site personnel immediately responsible for that area. The delivery vehicles will be required to be temporarily immobilized before hose connections can occur. Departure of delivery vehicles will not be allowed until hose connections or drain ports are properly disconnected and capped. Inspections prior to departure will be required to identify potential leaks from the drain outlet of an unloading vehicle to avoid leaks while in transit.

January 2023 Page 13

4.0 SPILL RESPONSE

Pursuant to 40 CFR 112.7(b), this SPCC Plan identifies the machinery, storage containers, and/or operations that could reasonably result in failure (see also Section 3.0 of this SPCC). Spill response activities outlined herein to address such failures include the anticipated direction and rate of flow in the event of a release, duration of the spill, and the potential for reaching navigable waters, and total quantity of oil which could be discharged from the Facility as a result of major equipment or container failure.

The Plan contains Spill Response Procedures (Table 1), Emergency Response Notification List (Table 2), Notification Action Summary (Attachment A), a Disposal Plan (Attachment D), and a Spill/Release Report (Attachment B).

Operations at the Grand Island Facility have been designed to minimize the potential spread and effects of oils and related petroleum materials in the case of equipment failure resulting in spills. Total quantity of material that could be discharged, the rate and direction of flow, duration of the spill, and the potential for reaching navigable waters vary depending on the type of equipment failure. Spill response activities for the identified oil storage areas, are summarized below.

The Facility’s emergency spill kits shall have enough materials to handle the potential amount of oil released from a single oil storage area. The spill kits contain loose absorbent materials; sorbent mats, pillows, and socks; goggles and nitrile gloves; garbage bags, stickers, and markers; an emergency response guidebook;

and a shovel and broom. Details regarding potential spill events and specific containment measures are detailed in the following subsections.

All spent or spilled used or virgin oil product will be handled as non-Resource Conservation Recovery Act (RCRA) special waste. Solid absorbent materials used in the cleanup of spilled oil will be containerized separately and will be disposed of as such. In the event of a simultaneous release of oil and solvents in which the materials became mixed, the oil/solvent mix spilled materials would be containerized separately from other spilled materials and disposed of in a way that reflects criteria of the higher class of waste, i.e., RCRA Hazardous Waste pursuant to 40 CFR 261. Additional information regarding disposal procedures for spent or contaminated materials is provided in Attachment D.

Building 1 Basement

The Building 1 sub-basement contains a 300-gallon capacity grease trap. The sub-basement floor space and associated walls are adequate to contain more than the potential amount of grease released from the the 300-gallon grease trap1. The basement floor consists of concrete and the walls are constructed of painted concrete. Floor/wall interface areas were observed to be intact, with no visible cracks leading to the building exterior or subsurface.

Building 7 Boiler Plant

The Boiler Plant (Building 7) is located on the southeast portion of the medical center Facility and is accessible via North Wheeler Avenue. The Facility’s two 20,000-gallon diesel USTs are located immediately

1 The sub-basement is assumed to have a minimum floor space of 2,000 square feet and can contain up to 1,200 gallons in discharge assuming a depth of one inch

January 2023 Page 14 west of the Boiler Plant Building and are used as the primary fuel source for the Boiler Plant emergency generator and as a secondary fuel source for the Facility’s three boilers.

The USTs use an automatic tank monitoring system to display tank fuel levels and to detect any potential leaks. Additionally, a tank overfill alarm is in operation at the location of the USTs. Due to the presence of automatic monitoring systems, the likelihood of a catastrophic 40,000-gallon release is remote. The most likely release scenario associated with the 20,000-gallon USTs would occur during a fuel delivery event (see Section 3.8 for tank truck spill prevention procedures). In the event of any malfunction/release, the fuel release would likely flow west toward North Wheeler Avenue. The Facility maintains two spill kits located inside the Boiler Plant Building, both equipped with sorbent socks and pads.

The nearest downgradient body of surface water is an unnamed tributary of the Wood River, located approximately 1.3 miles southeast of the Facility.

Building 8 Facilities Maintenance ASTs

The two 300-gallon ASTs at Building 8 are double-walled tanks with internal fuel level gauges. In the case of a sudden release from either of the ASTs, the largest single release would be the entire volume of one of the ASTs – 300 gallons. However, since the tanks are double-walled, the likelihood of a catastrophic release is remote. Spill response materials are available inside Building 8.

Building 17 AST

The 1,000-gallon diesel AST present east of Building 17 is constructed of double-walled steel, and is vaulted, Underwriters Laboratories (UL) 2085 listed, and pad-mounted. The AST uses an automatic tank monitoring system to display tank fuel levels and to detect any potential leaks. Additionally, a tank overfill alarm is in operation at the location of the AST. Due to the presence of an automatic monitoring system and secondary containment of the double-walled tank construction, the likelihood of a catastrophic 1,000-gallon release is remote. The most likely release scenario associated with the AST would occur during a fuel delivery event (see Section 3.8 for tank truck spill prevention procedures). In the event of any malfunction or other release, the fuel releases would flow west toward the paved driveway and North Wheeler Avenue. The Facility maintains one spill kit located inside the Building 17, equipped with sorbent socks and pads.

Building 17 Emergency Generator

In the case of a sudden release related to the day tank, the largest single release would be the entire volume of the 75-gallon day tank. However, since the day tank is double-walled, the likelihood of a catastrophic release is remote. Day-tank related spills would be contained within Building 17.

The Building 17 floor consists of concrete and the walls are constructed of painted concrete block. The floor/wall interface area was observed to be intact, with no visible cracks leading to the building exterior.

The Facility maintains one spill kit located inside the Building 17, equipped with sorbent socks and pads.

Building 18 Generator

Building 18, located adjacent to the northeast corner of the Boiler Plant, houses the Boiler Plant emergency generator and a double-walled steel, 75-gallon capacity diesel day tank.

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In the case of a sudden release from the day tank, the largest single release would be the entire volume of the 75-gallon day tank. However, since the day tank is double-walled, the likelihood of a catastrophic release to the environment is remote. Day-tank related spills beyond the secondary containment of the double wall would then be contained within Building 18.

The floor of Building 18 consists of concrete and the walls consist of painted concrete block. The floor/wall interface area was observed to be intact, with no visible cracks leading to the building exterior. The Facility maintains two spill kits located inside the Boiler Plant Building, both equipped with sorbent socks and pads.

No floor drains are present in Building 18.

Portable Generator

The Facility maintains a portable generator with an integrated 500-gallon diesel tank which it utilized when needed across the Facility. In the case of a sudden release from the portable generator, the largest single release would be the entire volume of the 500-gallon tank. However, since the tank is double-walled, the likelihood of a catastrophic release to the environment is remote. Generator related spills beyond the secondary containment of the double wall would then be contained within Building 8.

The Facility maintains a total of five pad-mounted, oil-containing electrical transformers, located around the Facility, and which have been assigned a numerical designation (1-5). Each transformer is located within a locked steel cabinet which is only accessible to the Facility’s electrician. See the table below for transformer spill response information.

The Facility maintains spill kits in the vicinity of the transformers equipped with sorbent socks and pads which can be utilized to halt and/or redirect potential spill pathways.

Fuel Delivery Truck Unloading Areas

Tank trucks brought on site to deliver diesel fuel to the USTs and AST could potentially hold up to approximately 9,000 gallons of diesel fuel. Tank truck spill prevention procedures are described in Section

3.8. Site drainage for the area in which tank truck transfer activities occur is included in Figure 2. Spill response equipment is located in Facility loading/unloading areas.

Transformer Number

Facility Location Capacity Oil Type Likely Spill Flow Direction

1 Outside, South of Building 17

453 Mineral Oil East toward driveway

2 Outside, South of Building 17

455 Mineral Oil East toward driveway

3 Outside, West of Building 11 and 4

310 Mineral Oil East toward North Wheeler Avenue

4 Outside, East of Building 18

260 Mineral Oil East toward North Wheeler Avenue

5 Outside, Southeast of Building 7

423 Mineral Oil East toward North Wheeler Avenue

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5.0 SPILL REPORTING PROCEDURE

Pursuant to 40 CFR 110.6, any person in charge of the Facility must notify the National Response Center (NRC) as soon as the release of oil, as defined under 40 CFR 110.3, is known to have occurred. Discharges of oil defined in 40 CFR 110.3 include discharges which:

• violate applicable water quality standards;

• cause formation of a film or sheen on or discoloration of the water surface or adjoining shorelines;

or

• cause a sludge or emulsion to be deposited beneath the water surface or upon adjoining shorelines.

The following sections describe the initial spill response actions to be implemented at the Facility in the event of a release. Reporting action steps and information required for reporting are summarized in Attachment B.

Internal Reporting Requirements

The employee discovering the spill will notify the area supervisor. The supervisor will determine the source and cause of the spill. Should the area supervisor need additional assistance, the Emergency Coordinator will be notified. The Emergency Coordinator will dispatch personnel to contain the spill in accordance with the Spill Response Procedures provided in Table 1.

The Boiler Plant Operator, VA Police, Maintenance and Operations Supervisor, Chief Engineer, Assistant Chief Engineer, Safety Specialist, Green Environmental Management Systems (GEMS) Program Manager, and Site Manager are designated Emergency Coordinators at the Grand Island Facility. Contact information for the Emergency Coordinators is provided in Table 2.

The employee discovering the spill or release will complete the Spill/Release Incident Report in Attachment B, detailing the following information:

• The address and/or location and phone number of the facility,

• The date and time of the spill or release,

• The type of material discharged,

• An estimate of the total quantity discharged,

• An estimate of the quantity discharged as defined in 40 CFR 112.1(b)2,

• The source of the discharge,

• A description of all affected media,

• The cause of discharge,

• Any damages or injuries caused by the discharge,

• Actions being used to stop, remove, and mitigate the effects of the discharge,

• Whether an evacuation may be needed, and

• Names of individuals and/or organizations who have also been contacted regarding the spill or release.

2 40 CFR 112.1(b) states discharges “in quantities that may be harmful, as described in part 110 of [40 CFR], into or upon the navigable waters of the United States or adjoining shorelines, or into or upon the waters of the contiguous zone, or in connection with activities under the Outer Continental Shelf Lands Act or the Deepwater Port Act of 1974, or that may affect natural resources belonging to, appertaining to, or under the exclusive management authority of the United States (including resources under the Magnuson Fishery Conservation and Management Act)”.

January 2023 Page 17

External Reporting Requirements

In accordance with 40 CFR 110.6, any person in charge of a vessel or of an onshore or offshore facility (i.e., the Emergency Coordinator or his designee) shall, as soon as he or she has knowledge of any discharge of oil from such vessel or facility oil discharge (film/sheen/discoloration) to water surface, or shoreline, or violation of water quality standards, notify the NRC, USEPA and/or the Coast Guard as required (see Attachment A).

Notifications of spill events to applicable governmental agencies are to be made only by Veterans Affairs Nebraska-Western Iowa Health Care System management staff or their designee (e.g., Emergency Coordinators/Facility Response Team) and only after the emergency response to the release has been implemented. This restriction is necessary to prevent misinformation, to assure the notifications are conducted properly, and to allow for immediate mitigation of the spill event.

In accordance with 40 CFR 112.4 (a), when a discharge of more than 1,000 U.S. gallons of oil into navigable waters in a single event, or two discharges or more of 42 gallons or more in a 12-month period of time occurs, the Emergency Coordinator or his designee will notify the NRC, USEPA and/or the Coast Guard as required (see Attachment A). Subsequent to federal reporting, the Emergency Coordinator or his designee will notify the state agency in charge of oil pollution control activities and the other appropriate agencies listed in Table 2. External reports will be initially by telephone.

A written report must be filed whenever a discharge occurs of more than 1,000 gallons of oil into navigable waters in a single event, or two discharges of more than 42 gallons in a 12-month period of time. When the threshold criteria are exceeded, the Emergency Coordinator will submit the following information within 60 days of the spill event to the USEPA Regional Administrator and, at the same time, to the appropriate agencies listed in Table 2:

• Name of the facility,

• Responder’s name,

• Location of the facility,

• Maximum storage or handling capacity of the facility and normal daily throughput,

• Corrective action and countermeasures taken, including a description of equipment repairs and replacements,

• A description of the facility, including maps, flow diagrams, and topographic maps, as necessary,

• The cause of such discharge as described in 40 CFR 112.1(b), including a failure analysis of the system or subsystem in which the failure occurred,

• Additional preventive measures taken or contemplated to minimize the possibility of recurrence, and

• Such other information as the Regional administrator may reasonably require pertinent to the Plan or discharge.

Additionally, in accordance with Nebraska Administrative Code (NAC) Title 126 Chapter 183 notification within 24 hours to the Nebraska Department of Environmental Quality (NDEQ) is required:

3 http://www.sos.ne.gov/rules-and-regs/regsearch/Rules/Environmental_Quality_Dept_of/Title-126/Chapter-18.pdf http://www.sos.ne.gov/rules-and-regs/regsearch/Rules/Environmental_Quality_Dept_of/Title-126/Chapter-18.pdf

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1) Regardless of the quantity of an oil release which occurs beneath the surface of land or impacts or threatens waters of the state or threatens the public health and welfare, or

2) Upon an oil release to land that exceeds 25 gallons.

However, NDEQ notification is not required if the release is confined and expected to stay confined within a building or otherwise wholly enclosed structure in which the floors and walls are constructed of non-earthen, adequately impervious materials and the spill is cleaned up within 24 hours of its discovery. The NDEQ may require a written final release report for a spill event, to be submitted to the Department within 15 days after the completion of remedial action, or if no remedial action is required, 15 days after the spill event. The final report should contain, at a minimum, the following information:

• Date, time, and duration of the release,

• Location of the release,

• Person or persons causing and responsible for the release,

• Type and amount of oil released,

• Cause of the release,

• Environmental damage caused by the release,

• Actions taken to respond, contain, and clean up the release,

• Location and method of ultimate disposal of the oil and other contaminated materials,

• Actions being taken to prevent a reoccurrence of the release,

• Any known or anticipated acute or chronic health risks associated with the release, and

• When appropriate, advice regarding medical attention necessary for exposed individuals.

See the Emergency Response Notification List, provided herein as Table 2, for agency emergency contact information.

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6.0 CERTIFICATION OF THE APPLICABILITY OF SUBSTANTIAL HARM CRITERIA

Facility Response Plan (FRP) applicability and requirements were established under 40 CFR 112.20 and 112.21 of the Clean Water Act, as amended by the Oil Pollution Act (OPA). According to the OPA, the “owner or operator of any non-transportation-related onshore Facility that, because of its location, could reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines” must prepare and submit an FRP to the appropriate USEPA Regional Administrator (RA). A Facility may be classified as a “substantial harm” Facility if it meets one of the following criteria:

• The Facility has a total oil storage capacity greater than or equal to 42,000 gallons and transfers oil over water to/from vessels, or

• The Facility has a total oil storage capacity greater than or equal to one million gallons, and o The Facility lacks secondary containment large enough to hold the capacity of the largest AST within each storage area plus sufficient freeboard to allow for precipitation, or o A discharge from the Facility could cause injury to fish and wildlife and sensitive environments, or o A discharge from the Facility could affect public drinking water intakes, or o The Facility has had a reportable discharge in an amount greater than or equal to 10,000 gallons with the past five years, or

• A USEPA RA has determined that the Facility poses “substantial harm” to the environment.

The Grand Island Facility does not meet the FRP preparation criteria. However, according to 40 CFR 112.20(e) and Appendix C, paragraph 3.0 of part 112, if an FRP is not required, then a Certification of the Applicability of the Substantial Harm Criteria from must be completed and maintained at the Facility with the SPCC Plan.