Omaha_SPCC Plan_Jan 2023__.pdf

Spill Prevention, Control, and Countermeasure Plan

Veterans A�airs Medical Center Omaha, 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 - Omaha 4101 Woolworth Avenue

Omaha, Nebraska

Prepared for:

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

Prepared by:

Scout Environmental, Inc.

Encinitas, CA

January 2023

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

January 2023 Page i

FOREWORD

This document comprises the Veterans Affairs Medical Center (VAMC) – Omaha, 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

– Omaha. This document applies to all organizations and contractors at the Omaha 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 Veterans Affairs Emergency line at x3333 from an internal phone line and at (402) 995-3333 from a cell phone or outside phone line.

Specific roles, responsibilities, and procedures are included in the body of this document, including the VAMC – Omaha 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) – Omaha, 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 - Omaha, 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 J. Hailey, AIA

21 FEB 2023

Chief of Engineering Services

January 2023 Page iv

CERTIFICATION OF THE APPLICABILITY OF THE SUBSTANTIAL HARM CRITERIA

Facility Name: Veterans Affairs Medical Center - Omaha Facility Address: 4101 Woolworth Avenue, Omaha, 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 J. Hailey, AIA

21 FEB 2023

Chief of Engineering Services

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 Boiler Plant

2.1.2 Refueling AST

2.1.3 Building 25 Emergency Generators

2.1.4 Research Building Generator

2.1.5 Emergency Generator (North of Building 6)

2.1.6 Ambulatory Care Center Generator

2.1.7 Used Grease Tank

2.1.8 Dialysis Building / Service Garage

2.1.9 Hydraulic Elevator

2.1.10 Transformers

2.1.11 Fuel Delivery Truck Unloading Areas

3.0 SPILL PREVENTION MEASURES AND SYSTEMS

Boiler Plant Refueling AST Building 25 Emergency Generators Research Building Generator Emergency Generator (North of Building 6) Ambulatory Care Center Generator Used Grease Tank Dialysis Building / Service Garage Hydraulic Elevator Transformers Fuel Delivery Truck Unloading Areas

4.0 SPILL RESPONSE

Boiler Plant Refueling AST Building 25 Emergency Generators Research Building Generator Emergency Generator (North of Building 6) Ambulatory Care Center Generator Used Grease Tank Dialysis Building / Service Garage Hydraulic Elevator Transformers Fuel Delivery Truck Unloading Areas

January 2023 Page vi

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 Hydraulic Elevator Transformers Spill Response Equipment 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 Boiler Plant Day Tank

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) - Omaha located at 4101 Woolworth, Omaha, 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 26

§112.5(b) Review of Plan at least every 5 years with documentation (i.e., a log) 26

§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 10-13

§112.7(a)(3)(iii) Discharge drainage controls 10-13

§112.7(a)(3)(iv) Countermeasures for discharge discovery, response and cleanup 14-17

§112.7(a)(3)(v) Methods of disposal of recovered materials in accordance with legal requirements

14, Att. D

January 2023 Page 2

Regulation Description Page #

§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 18-20

§112.7(a)(5) Discharge procedures 13-16

§112.7(b) Failure prediction (sources, quantities, rates, and directions) 14-17

§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, 10-13

§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 22-24, 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 25

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

§112.7(f)(3) Discharge prevention briefings scheduled and conducted annually 25

§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 19-20

§112.7(k)(2)(i) Inspection procedures or monitoring program 22-24, Att. E

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

January 2023 Page 3

§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 1-27

§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

22-24

§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), §112.12(c)(8)(v)

Liquid level sensing devices tested to ensure proper operation 22-24, Att. E

§112.8(c)(9), Observe effluent treatment facilities to detect system upsets NA

January 2023 Page 4

§112.12(c)(9)

§112.8(c)(10), §112.12(c)(10)

Correct visible leaks and remove accumulations of oil 22-24, 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 – Omaha (Facility) is situated on an approximately 35-acre property. The Facility consists of a central 14-story main hospital building (Building 1), with an outpatient care center addition to the north (Building 25). In addition, a group of small VA staff office buildings and a Dental Clinic Building are located near the northwest corner of the Facility, and the Boiler Plant Building, Dialysis Building (Building 9), AC Plant (Building 17 Basement), a parking lot (with a drum shed and grease tank), and a Recovery Center Building (Building 8) are located near the southeast corner of the Facility. A new Ambulatory Care Center has been constructed near the center of the property and a new parking structure has been constructed in the north portion of the property.

On-site operations consist of inpatient and outpatient medical care for United States veterans. The VAMC

- Omaha Facility also operates a medical research unit, which is located in the southern wing of the main hospital building (Building 15).

The Facility also includes asphalt parking lots, asphalt 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. There are currently no instances of non-conformance with the plan and no deviations from plan requirements.

Oil Use and Storage

Certain on-site operations require the storage and use of oils and other petroleum-based products.

Specifically, in the event of an emergency power outage, the Facility operates several emergency generators which use diesel fuel as a primary fuel source. These emergency generators and reservoir tanks are described in more detail in the following subsections. A complete listing of the Facility’s oil and petroleum-based storage and storage tank details are provided as Table 4 and Table 5, respectively. The following subsections describe material use and storage areas for the Facility.

2.1.1 Boiler Plant

The Boiler Plant, located on the east side of the Facility, houses the Facility’s boilers and an emergency generator. The Facility’s four 10,000-gallon diesel ASTs, installed in 1998, are located immediately north of the Boiler Plant Building and are used as the primary fuel source for the emergency generator. The four 10,000-gallon ASTs are constructed of fabricated steel, lined with a polyethylene secondary containment layer, and encased in a six-inch layer of reinforced concrete. The ASTs are maintained at capacity at all times. Steel piping routes diesel fuel from the ASTs to a 50-gallon, single-walled steel day tank (tank with sufficient capacity for 24-hour operation) located near the emergency generator in the Boiler Plant Building.

According to Boiler Plant operations staff, the day tank is maintained at capacity with diesel fuel at all times to provide an immediate fuel source for the emergency generator.

Figure 1 Site Location and Overview

Department of Veterans Affairs Omaha VA Health Care Facility

Source: Google Satellite, 2020 Prepared by: JAW 2/20/2020, rev. 4/28/2021

F

Woolworth Avenue T

T-1

C

Golf Course

P P

12 T-2

10,000-gallon ASTs (Diesel) (4 Total Tanks)

Emergency

T T 24

Generator

22,053-gallon Tank (Diesel)

6 T-3 25

T-10

T-11

13 14

5,000-gallon

AST (Gasoline) D

Emergency Generator Room (Two 100-gallon Day Tanks)

(Diesel) P

6,000-gallon UST (Diesel) (Exempt)

Emergency Generator

500-gallon Tank (Diesel)

T-9

T-8

T-7

T-13

T-4

T-12

125-gallon Aboveground 16 Grease 21 Tank

T-5

T-6

Hydraulic Elevator

243-gallon AST (Diesel)

243-gallon AST (Gasoline)

Center Stree t

0 250 500 1,000

Approximate Scale in Feet (1 inch = 250 feet)

Figure 2 Site Plan

Updated: October 2022

Department of Veteran Affairs Omaha VA Health Care Facility

Sources: Site reconnaissance performed by Jason Strayer and Dean Bender on October 9, 2019, plot plan provided by Department of Veterans Affairs.

Prepared by / Date: JAW 2/24/2020

Building Numbers

1 - Main Hospital Building 16 - Cooling Tower 2 - Boiler Plant 17 - Air Conditioning Building 6 - Dental 18 - Cooling Tower ICU 7 - Flagpole 19 - Welding Shop 8 - Day Hospital Care 21 - Oxygen Storage Pad 9 - Dialysis Building 22 - T Building 10 - Diesel Storage Tanks 24 - High Voltage Switching Station 13 - Underground Tunnel 25 - Outpatient Clinic 14 - Equipment Storage 15 - Research Building A - Ambulatory Care

D - OIF / OEF Clinic F - Fisher House

LEGEND

- Subject Property Boundary

- Flow Direction

- Connecting Pipes

P Parking Lot

T-11 Transformer

- Fuel Delivery Truck Unloading Area

- Storm Drain

- Spill Kit

Portable Generator 500-gallon Tank (Diesel)

ACC Generator (268 Gallons Diesel)

A

T

Elevator Reservoir 500-gal, hydraulic oil

T

P nd

S tr ee t

Parking Garage

Elevator Reservoir 1,000-gal, hydraulic oil

Elevator Reservoir 1,500-gal, hydraulic oil

Elevator Reservoir 1,500-gal, hydraulic oil

January 2023 Page 8

2.1.2 Refueling AST

The Facility operates a 5,000-gallon E-85 gasoline AST located north of Building 9. The tank is used to fuel VA fleet vehicles. The AST is double-walled, was installed in 2017, and is used to refuel equipment onsite.

2.1.3 Building 25 Emergency Generators

The Facility operates two emergency generators, each provided with a double-walled steel, 100-gallon day tank in a small generator room present on the south end of Building 25. A 6,000-gallon diesel UST (exempt from the SPCC Rule requirements), installed on the exterior area south of the Building 25 generator room, functions as the generators’ primary fuel source. The UST is constructed of fiberglass reinforced plastic and was installed in 1986. While the UST is exempt from the SPCC Rule requirements, VA management has elected to include the UST as part of their SPCC Plan inspection program as a “best management practice.”

2.1.4 Research Building Generator

An emergency generator is located on the exterior, north side of the Research Building (Building 15). This generator unit, also referred to as the Microbiology Generator, is pad-mounted and contains an integral (i.e., belly tank) 500-gallon diesel tank.

2.1.5 Emergency Generator (North of Building 6)

An emergency generator is located north of Building 6. This generator was installed in 2020, is pad-mounted, and contains an integral (i.e., belly tank) 22,053-gallon diesel tank.

2.1.6 Ambulatory Care Center Generator

An emergency generator is located off the southeast corner of the Ambulatory Care Center. This generator unit is pad-mounted and contains an integral (i.e., belly tank) 268-gallon diesel tank.

2.1.7 Used Grease Tank

The Facility’s 125-gallon steel used grease tank is located in the loading dock area on the northeast side of Parking Lot 6 near the Drum Shed. Spent cooking grease is collected from Facility food preparation areas and manually poured into an access hatch on the top of the grease tank.

2.1.8 Dialysis Building / Service Garage

The Dialysis Building, also known as Building 9, contains an upper level where patient dialysis procedures are performed and a lower-level service garage occupied by Facility maintenance staff. The service garage contains an interior room which serves as storage for small (less than 55-gallon) containers of lubricant and motor oil. The service garage area also includes two 243-gallon ASTs (one diesel and one gasoline). The ASTs are double-walled, secure, and located outside, off the southeast corner of the building.

2.1.9 Hydraulic Elevators

There are five hydraulic elevators on the Omaha campus. Their location and volume are listed in the table below. The elevators are serviced by a contractor.

January 2023 Page 9

Location Oil Capacity

(gallons)

Dialysis Building 55 Fisher House 500 Parking Garage 1,000 ACC Front House 1,500 ACC Back House 1,000

2.1.10 Transformers

The Facility operates a total of 14 oil-containing transformers throughout the Facility. See the table below for a description of each transformer and their respective numerical designation.

Transformer Number Location Transformer

Type Oil Capacity

(gallons) Oil Type

1 Outside Building 3 Pad mounted 281 Mineral oil 2 Outside (adjacent to former location of

Building 5) Pad mounted 281 Mineral oil

3 Outside Building 6 Pad mounted 281 Mineral oil 4 Outside Building 17 Pad mounted 396 Mineral oil 5 Outside Building 9 Pad mounted 136 Mineral oil 6 Outside Building 9 Pad mounted 157 Mineral oil 7 Building 17 Room A104 Substation 145 Mineral oil 8 Building 17 Room A104 Substation 165 Mineral oil 9 Building 17 Room A104 Substation 165 Mineral oil

10 Building 1 Room 1269 Substation 138 Mineral oil 11 Building 1 Room 1269 Substation 139 Mineral oil 12 Outside Building 17 Substation 487 Mineral Oil 13 Outside Building 17 Substation 227 Mineral Oil

Note: In addition to the transformers listed above, there are numerous transformers owned and operated by Omaha Public Power District on the VA property. Those transformers are excluded from this plan as the VA has no responsibility for these pieces of equipment.

2.1.11 Fuel Delivery Truck Unloading Areas

According to Facility operations employees, large fuel deliveries to the Facility are rare, as the diesel fuel stored in the on-site ASTs and UST is only used in case of emergency. Petroleum product transfers occur in the driveway adjacent to the Boiler Plant (in the area of the 10,000-gallon ASTs), near the refueling station, in the driveway south of Building 25 adjacent to the 6,000-gallon UST, in Parking Lot 6., and north of Building 6.

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 Omaha Facility.

Boiler Plant

The Facility’s four 10,000-gallon diesel ASTs, installed in 1998, are located immediately north of the Boiler Plant Building and are used as the primary fuel source for the Boiler Plant emergency generator. The four 10,000-gallon ASTs are constructed of fabricated steel, lined with a polyethylene secondary containment layer, and encased in a six-inch layer of reinforced concrete.

Several spill prevention and security measures are in place related to the operation of the Boiler Plant ASTs, including an automatic tank monitoring system, a locked fill port policy, and nighttime security lighting.

The ASTs are also located within a fenced and locked area. Additionally, VA police officers and Boiler Plant operators are present at the Facility twenty-four hours a day, seven days a week to monitor these tanks.

The Boiler Plant Building is locked at all times and is only accessible to authorized Facility personnel. The Facility maintains one Boiler Plant spill kit, located on the south end of the Boiler Plant Building, equipped with garbage bags, sorbent socks, and sorbent pads.

Refueling AST

The Facility operates a 5,000-gallon E-85 gasoline AST located north of Building 9 which is used to refuel fleet vehicles and other onsite equipment. The AST is pad-mounted, constructed of steel, and is double-walled. Several spill prevention and security measures are in place, including an automatic tank monitoring system, a nearby emergency shutoff station, and a locked fill port policy. The ASTs are also located within a locked, fenced area. Additionally, VA police officers and Boiler Plant operators are present at the Facility twenty-four hours a day, seven days a week and routinely conduct surveillance of this area.

Building 25 Emergency Generators

A 6,000-gallon diesel UST, installed in the exterior area south of the Building 25 generator room, functions as a primary fuel source for two emergency generators. The UST is constructed out of single wall fiberglass reinforced plastic and was installed in 1986. Two 100-gallon, diesel-containing day tanks are also located in this room.

January 2023 Page 11

Spill prevention and security measures are in place related to the 6,000-gallon UST, including an automatic tank monitoring system, a locked fill port policy, and nighttime security lighting. Additionally, VA police officers and Boiler Plant operators are present at the Facility twenty-four hours a day, seven days a week.

The generator room is locked at all times and is only accessible to authorized Facility personnel. The Facility maintains a spill kit inside the generator room, equipped with sorbent socks and pads.

Research Building Generator

This emergency generator consists of an exterior, generator, located on the north side of the Research Building. The generator unit, also referred to as the Microbiology Generator, is cement pad-mounted and contains an integral 500-gallon diesel tank with a 600-gallon secondary containment capacity. VA police officers and Boiler Plant operators are present at the Facility twenty-four hours a day, seven days a week and provide routine surveillance of this area.

Emergency Generator (North of Building 6)

This generator unit was installed in 2020 is pad-mounted and contains an integral 22,053-gallon diesel tank provided with secondary containment. The generator and associated fuel tank are located in a locked, fenced enclosure. VA police officers and Boiler Plant operators are present at the Facility twenty-four hours a day, seven days a week and provide routine surveillance of this area.

Ambulatory Care Center Generator

This generator unit is pad-mounted and contains an integral 268-gallon diesel tank provided with secondary containment. VA police officers and Boiler Plant operators are present at the Facility twenty-four hours a day, seven days a week and provide routine surveillance of this area.

Used Grease Tank

The Facility’s 125-gallon steel grease tank is located in the loading dock area on the southwest side of Parking Lot 6. The grease tank is serviced and emptied by Darling International, Inc., an off-site, contracted company. A spill kit is available nearby in Building 1.

Dialysis Building / Service Garage

Two 243-gallon ASTs were installed at this location in 2020. The tanks are located outside, off the southeast corner of the building. One AST contains diesel fuel and one contains unleaded gasoline. The tanks are provided with internal secondary containment and the dispensing nozzles are locked with grounds maintenance staff having key control. Additionally, VA police officers and Boiler Plant operators are present at the Facility twenty-four hours a day, seven days a week and routinely conduct surveillance of this area.

Hydraulic Elevator

The elevator equipment rooms throughout the campus are locked at all times and are only accessible to authorized personnel. Additionally, any major hydraulic elevator maintenance activities, including oil-related maintenance, is performed by contractors. Spill kits are located nearby the equipment rooms.

January 2023 Page 12

Transformers

The Facility maintains a total of 13 oil-containing electrical transformers, which are located in various locations around the Facility. To ensure the security of each transformer, access panel doors are maintained locked and are only accessible to the Facility’s electrician. Also, VA police officers and Boiler Plant operators are present at the Facility twenty-four hours a day, seven days a week and provide routine surveillance of the 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 Omaha Facility are rare, as the diesel fuel stored in the on-site ASTs and UST 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 Omaha Facility typically contracts with private fuel supply and delivery companies. Prior to tank truck fuel deliveries, Omaha 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 Omaha 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.

• 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 Omaha 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

January 2023 Page 13 be required to identify potential leaks from the drain outlet of an unloading vehicle to avoid leaks while in transit. Spill response equipment is located in Facility loading/unloading areas.

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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 Omaha 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.

Boiler Plant

The Boiler Plant Building, located on the east side of the Facility, is accessible via the Facility’s Center Street entrance. The Facility’s four 10,000-gallon diesel ASTs are located immediately north of the Boiler Plant Building. The ASTs utilize an automatic tank monitoring system to display tank fuel levels and to detect potential leaks. Due to the presence of the automatic monitoring system and AST secondary containment, the likelihood of a catastrophic 40,000-gallon release is remote. Any leaks associated with the ASTs would likely flow east toward the vegetated, recessed area near the Facility property line. The nearest downgradient body of surface water is the Missouri River, located approximately three miles east of the Boiler Plant area.

The most likely release scenario associated with the ASTs would occur during a fuel delivery event and would most likely be under 50-gallons due to the unloading procedures in place. Spill response equipment is located in Facility loading/unloading areas. See Section 3.12 for tank truck spill prevention procedures.

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Refueling AST

The Facility operates a 5,000-gallon gasoline AST located north of Building 9 which is used to refuel onsite equipment and fleet vehicles. The AST is double-walled and constructed of heavy gauge steel, making a sudden release of a sudden large volume release unlikely. The AST is also equipped with a nearby emergency shutoff station outside of the fenced area. The most likely release scenario associated with the AST would occur during a fuel delivery event, and would most likely be under 50-gallons due to the unloading procedures in place. Any leaks associated with the AST would likely flow south. The Facility maintains one spill kit, located on the north end of Building 9, equipped with garbage bags, sorbent socks, and sorbent pads.

The most likely release scenario associated with the ASTs would occur during a fuel delivery event and would most likely be under 50-gallons due to the unloading procedures in place. Spill response equipment is located in Facility loading/unloading areas. See Section 3.9 for tank truck spill prevention procedures.

Building 25 Emergency Generators

The Facility operates two emergency generators and two double-walled steel, 100-gallon day tanks in a small generator room present on the south end of Building 25. A 6,000-gallon diesel fiberglass UST, installed in the exterior area south of the Building 25 generator room, functions as the generators’ primary fuel source.

The 6,000-gallon UST uses an automatic tank monitoring system to display tank fuel levels and to detect any potential leaks. Detection of any underground releases may result in soil excavation, tank inspection, and investigation of subsurface media. Due to the presence of an automatic monitoring system, the likelihood of a catastrophic 6,000-gallon release is remote.

The most likely release scenario associated with the UST would occur during a fuel delivery event. See Section 3.9 for tank truck spill prevention procedures. In the event of a spill during a fuel delivery event, a fuel release would likely flow toward the storm drain located in the driveway located approximately 25 feet south of the UST area. The nearest downgradient body of surface water is the Missouri River, located approximately three miles east of the Building 25 area.

The generator room’s floor surface area and walls are large enough to contain a worst-case 200-gallon spill from the day tanks. The generator room contained a concrete floor and concrete block walls. The floor/wall interface area is intact, with no visible cracks leading to the building exterior. A spill kit is available in the generator room.

Research Building Generator

The Research Building generator is located on the exterior of the north side of the building. The generator contains an integral 500-gallon diesel tank provided with secondary containment. The most likely release scenario associated with the generator would occur during a fuel delivery event. See Section 3.9 for tank truck spill prevention procedures. In the event of a spill during a fuel delivery event, a fuel release would likely not flow beyond the grassy area surrounding the generator. Additionally, a spill kit is available in the adjacent Building 25 generator room.

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Emergency Generator (North of Building 6)

Due to the presence of the integral storage tank secondary containment and other controls (the tank is equipped with a direct read fuel gauge a secondary containment tank leak detector float alarm, high level float alarm, and a primary talk overflow connection) the likelihood of a catastrophic 20,000-gallon release is remote. Any leaks associated with the tank would likely flow west toward the vegetated, slope along the Facility property line, then towards 42nd Street. The most likely release scenario associated with the AST would occur during a fuel delivery event and would most likely be under 50-gallons due to the unloading procedures in place. See Section 3.12 for tank truck spill prevention procedures.

Ambulatory Care Center Generator

The Ambulatory Care Center generator is located off the southeast corner of the building. The generator contains an integral 268-gallon diesel tank provided with secondary containment. The most likely release scenario associated with the generator would occur during a fuel delivery event. See Section 3.9 for tank truck spill prevention procedures. In the event of a spill during a fuel delivery event, a fuel release would likely not flow beyond the grassy area surrounding the generator.

Used Grease Tank

The Facility’s 125-gallon steel used grease tank is located in the loading dock area on the north side of Parking Lot 6. The most likely release would occur during a service event. Any spills occurring in Parking Lot 6 would likely flow toward the parking lot’s storm drains, located on the east side. A room in Building 1 located immediately adjacent to the collection tank contains a spill kit equipped with sorbent socks and pads.

Dialysis Building / Service Garage

The Service Garage area includes two 243-gallon ASTs (one diesel and one gasoline). The most likely release would occur during fueling operations or filling the tanks. Any spills occurring in lot where the tanks are located would likely flow toward the storm drain, located north of the tanks. A spill kit is located immediately adjacent to the tanks and is equipped with sorbent socks and pads.

Hydraulic Elevators

The elevator equipment room’s floor and associated walls are sealed and are large enough to contain 55-gallons of oil, should a worst-case spill occur.

The Facility maintains a total of 13 pad-mounted, oil-containing electrical transformers, located around the Facility, and which have been assigned a numerical designation (1-13). Each transformer is located within a locked steel cabinet which is only accessible to the Facility’s electricians. See the table below for transform spill containment and release flow direction.

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Transformer Description

# Location Transformer Type

Oil Capacity (gallons)

Oil Type Release Flow Direction

1 Outside Building 3 Pad mounted 281 Mineral oil West to S 42nd St 2 Outside Building 5 Pad mounted 281 Mineral oil West to S 42nd St 3 Outside Building 6 Pad mounted 281 Mineral oil West to S 42nd St 4 Outside Building 17 Pad mounted 396 Mineral oil South 5 Outside Building 9 Pad mounted 136 Mineral oil East 6 Outside Building 9 Pad mounted 157 Mineral oil East 7 Building 17 Room

A104 Substation 145 Mineral oil Contained in room

8 Building 17 Room A104

Substation 165 Mineral oil Contained in room

9 Building 17 Room A104

Substation 165 Mineral oil Contained in room

10 Building 1 Room 1269 Substation 138 Mineral oil Contained in room

11 Building 1 Room 1269 Substation 139 Mineral oil Contained in room 12 Outside Building 17 Substation 200 Mineral Oil East 13 Outside Building 17 Substation 227 Mineral Oil East

Fuel Delivery Truck Unloading Areas

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

3.12. 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.

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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, immediately contact the Veterans Affairs Emergency line at x3333 from an internal phone line and at (402) 995-3333 from a cell phone or outside phone line. This agency 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, and Green Environmental Management Systems (GEMS) Program Manager are designated Emergency Coordinators at the Omaha 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)1,

• 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

1 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)”.

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

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.