Attachment- 30 SPCC-PIPP Plan VANTHCS_Bonham.pdf

Spill Prevention, Control, and

Countermeasure Plan and

Pollution Incident Prevention Plan

Prepared for:

Department of Veterans Affairs

Sam Rayburn Memorial Veterans

1201 East 9th Street

Bonham, TX 75418

SPCC-PIPP Plan i

Table of Contents

Section Page

Management Approval and Commitment of Resources ............................................................................ iii

SPCC Plan Certification .................................................................................................................................. v

Certification of the Applicability of the Substantial Harm Criteria ............................................................ vii

Introduction

Applicability

Key Facility Information

Roles and Responsibilities

Spill Response

Spill Response Materials and Waste Disposal

Spill Notification Requirements

Non-Reportable Spill Notification Procedures

Reportable Spill Notification Procedures

Imminent Danger Spill Notification Procedures

Written Spill Notification Requirements

DEQ Water Division Chief

USEPA Regional Administrator

Spill Prevention and Controls

Potential Oil Release Sources

General Spill Prevention Measures

Secondary Containment

Impracticability Determination

Oil Transfer Activities

Transfer Procedures

General Secondary Containment in Transfer Areas

Overfill Protection

Inspections and Integrity Testing

Periodic Visual Inspections

Integrity Testing

Personnel Training

Security

Tank Construction Material

Conformance With Applicable State Requirements

Certification Requirements

Records ii

Tables

Table 1. Oil Storage Capacity and Plan Details

Table 2. Spill Classifications

Table 3. Non-Reportable Spill Notification Procedures

Table 4. Reportable Spill Notification Procedures

Table 5. Imminent Danger Spill Notification Procedures

Table 4. Cross-Reference with Spill Contingency Rules

Table 5. Inspection Guidance by Container Type

Table 6. Integrity Testing Guidance by Container Type/Size

Figures

Figure 1. Site Location Map

Figure 2. Facility Site Plan

Attachments

Attachment A Cross-Reference with the SPCC/PIPP Rules

Attachment B Monthly Inspection Checklist

Attachment C Annual Tank Inspection Checklist

Attachment D SPCC Training Record

Attachment E Notice to Petroleum Product Vendors

Attachment F Fuel/Oil Transfer Checklist

Attachment G Annual SPCC Plan Review

Attachment H Spill Incident Report

Attachment I Spill Response Flow Chart

Attachment J Spill Reporting Compliance Documentation Log

Attachment K Oil Spill Disposal Record

Attachment L Secondary Containment Area Storm Water Release Log

Attachment M SPCC Plan Review and Recertification Log

Attachment N SPCC Plan Amendment Certification iii

MANAGEMENT APPROVAL AND COMMITMENT OF RESOURCES

Department of Veterans Affairs is committed to preventing discharges of oil, salts, or other chemicals to navigable waters and the environment through the implementation of this integrated Spill

Prevention, Control, and Countermeasure (SPCC) Plan and Pollution Incident and Prevention Plan

(PIPP). This SPCC-PIPP Plan has the full approval of Department of Veterans Affairs management. By signing this page, Department of Veterans Affairs management commits to provide the personnel, equipment, and materials required to expeditiously control and remove any harmful quantity of oils, salts, or other chemicals discharged.

Jack Jordan

Name Signature

Chief, Safety Service May 5, 2023

Title Date iv v

SPCC PLAN CERTIFICATION

Certification by a Professional Engineer

By means of this certification, I hereby certify and attest that I am familiar with the requirements of the Oil Pollution Act SPCC regulations (Code of Federal Regulations, Title 40, Part 112 [40 CFR

112]), that I or my designated agent has visited and examined the facility, that this SPCC Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of this Part, that procedures for required inspections and testing have been established, and that the plan is adequate for the facility.

This certification in no way relieves the owner or operator of the facility of his/her duty to prepare and fully implement this SPCC Plan in accordance with the requirements of 40 CFR 112. This SPCC

Plan is valid only to the extent that the facility owner or operator maintains, tests, and inspects equipment, containment, and other devices as prescribed in this SPCC Plan.

Printed Name of Registered Professional Engineer

Signature of Registered Professional Engineer

TX

Registration Number State Date vi

[This page left blank intentionally] vii

CERTIFICATION OF THE APPLICABILITY OF THE SUBSTANTIAL HARM

CRITERIA

Facility Name: Sam Rayburn Memorial

Facility Address: 120 East 9th Street

Facility Location: Bonham, TX 75418

1. Does the facility have a maximum storage capacity greater than or equal to 42,000 gallons and do the operations include over water transfers of oil to or from vessels?

2. Does the facility have a maximum storage capacity greater than or equal to 1,000,000 gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground storage tank within the storage area?

3. Does the facility have a maximum storage capacity greater than or equal to 1,000,000 gallons and is the facility located at a distance such that a discharge from the facility could cause injury to an environmentally sensitive area?

4. Does the facility have a maximum storage capacity greater than or equal to 1,000,000 gallons and is the facility located at a distance such that a discharge from the facility would shut down a public drinking water intake?

5. Does the facility have a maximum storage capacity greater than or equal to 1,000,000 gallons and within the past 5 years, has the facility experienced a reportable spill in an amount greater than or equal to 10,000 gallons?

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.

Jack Jordan

Name (please type or print) Signature

Chief, Safety Service May 5, 2023

Note: If an alternative formula is used in questions 3 and 4, documentation of the reliability and analytical soundness of the alternative formula must be attached to this form.

viii

INTRODUCTION

This document is the Spill Prevention, Control, and Countermeasure (SPCC) Plan and Pollution

Incident Prevention Plan (PIPP) for Sam Rayburn Memorial Veterans Center, part of VA North Texas

Health Care System (VANTHCS). The VANTHCS previous hospital complex was constructed in 1948 and consists of the main outpatient building, a boiler plant/maintenance garage, a nursing home and domiciliary, and a few support buildings. Petroleum products, salt storage, and other chemicals applicable to the SPCC and PIPP requirements are primarily stored at the boiler plant/maintenance garage.

APPLICABILITY

The Clean Water Act Oil Pollution Prevention (SPCC) regulation (Code of Federal Regulations, Title 40, Part 112 [40 CFR 112]), as issued by the U.S. Environmental Protection Agency (USEPA), aims to prevent the discharge of oil into or upon the navigable waters or adjoining shorelines of the United

States. Additionally, Texas Administrative Code (TAC) regulations (R 324.2001 – R 324.2009) aim to provide additional countermeasures to prevent releases to the environment.

A cross-reference checklist identifying how this plan complies with the SPCC and PIPP regulation is provided in Attachment A.

The SPCC regulation applies to all oil products, including, but not limited to:

• Fats, oils, or greases of animal, fish, or marine mammal origin

• Vegetable oils, including oils from seeds, nuts, fruits, or kernels

• Other oils and greases including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil.

The PIPP regulation applies to polluting materials including:

• Oil products as described above

• Salt (solid or brine storage)

• Any material stored above the threshold management quantity (TMQ)

A facility is subject to SPCC regulation if, due to its location, the facility could reasonably be expected to discharge oil in quantities that may be harmful into or upon navigable waters or adjoining shorelines of the United States and the aggregate:

• Aboveground oil storage capacity exceeds 1,320 gallons in containers with volumes of

55 gallons or greater, or

• Underground oil storage capacity of the facility exceeds 42,000 gallons—excluding sources that are currently subject to all technical requirements of 40 CFR 280 or all technical requirements of state programs approved under 40 CFR 281.

A facility is subject to PIPP regulation if it manages polluting materials (described above) more than threshold management quantities:

• Salt in solid form more than 5 tons

• Salt in liquid form more than 1,000 gallons

• Aboveground oil storage capacity exceeding 1,320 gallons or a single storage container exceeding 660 gallons

• Materials listed in Rule 9 stored outdoors more than 440 pounds

• Materials listed in Rule 9 stored indoors more than 2,200 pounds

Because the facility has more than 1,320 gallons of oil (see Table 1 on page 5) in containers with a capacity of 55 gallons or greater (sources) and manages over 5 tons of salt in solid form, this SPCC-

PIPP Plan was prepared and will be implemented consistent with the current version of 40 CFR 112 and MAC R 324.2001 – R 324.2009.

This SPCC-PIPP Plan is used as a:

• Reference for proper oil and other polluting material storage

• Tool for spill or release prevention

• Guide for facility inspections and tank testing

• Resource during emergency response to control, contain, and clean up a release

KEY FACILITY INFORMATION

Name of the Facility: Sam Rayburn Memorial Veterans Center

Facility Owner: Department of Veterans Affairs

Facility/Mailing Address: 120 E. 9th Street

Bonham, Texas 75418 (Fannin County)

Facility Phone Number: 903-583-6692

Latitude/Longitude: 33.58495, -96.16658

Name, Direction, and Distance to the Nearest Body of Water:

Facility Emergency

Coordinator:

Alternate Emergency

Storm sewer on the facility routes toward East 9th Street and toward the Seven Oaks Road (FM 2906) Northeast, east of the State

Veterans Home Area. The local Wastewater Treatment Plan is approximately 500 feet from the VA campus to the North. Pig

Branch is located approximately 1,500 feet west of the facility. Pig

Branch feeds into Bosi d’Arc Creek. The Site Location Map on Figure

1 shows the location of the facility relative to these nearby waterways.

Michael Hoffman, Emergency Manager

Program Manager Work: ( 2 1 4 ) 3 7 2 - 8 8 1 4

Cell: ( 2 1 4 ) 5 6 4 - 5 9 0 6

Associate Chief Engineer

Work: 214-857-1028 Cell: 469-545-8185

Location of SPCC-PIPP Plan: A complete copy of this SPCC-PIPP Plan is maintained in the VA North Texas

Health Care System – Safety Office (Building TT-49) and Boiler Plant

(Building 11), 1201 E. 9th Street, Bonham, TX; and is available for on-site review by the USEPA Regional Administrator. This SPCC- PIPP Plan is not filed with the USEPA.

Next Review Due: October 2027 (or after any release requiring implementation of the plan)

Last Review Completed: September 2022

Facility Oil Sources: See Table 1 on page 5.

Other Oil Sources at Facility

Not Managed Under this

SPCC/PIPP Plan:

None

Facility Salt Storage: No liquid form salt is stored on the facility. No solid salt is stored on the facility more than 5 tons.

Other Polluting Materials at

Facility:

Other materials managed at the facility are below the threshold management quantity.

Spill History: The facility has had no reportable oil spills to date.

Underground Oil Storage

Capacity:

VAMC has approximately 6,500 gallons of underground storage capacity. All underground storage tanks (USTs), aboveground and underground piping, and ancillary equipment at the facility conform to the technical requirements of 40 CFR 280 and are therefore exempt from the requirements of the SPCC program. As required, the location and contents of these tanks are included on the Facility

Site Plan, Figure 2.

Table 1. Oil Storage Capacity and Plan Details

Sam Rayburn Memorial Veterans Center

Bonham, Texas

Storage

Symbol

Oil Source

Volume

(gal)

Location

Container

Construction

Contents

Transfer Activities

Distance and Direction to Nearest Receptor

Spill Prevention and Leak

Detection

Secondary

Containment

Overfill Protection

Spill

Countermeasures and Response

Materials

Security

Inspection and Integrity

Testing Schedule

Underground and Aboveground Storage Tanks

UST1

TCEQ1

4,000 Outdoors, Building 1 Double-Walled

Fiberglass

Reinforced

Plastic (DWFRP)

Diesel Fuel, Red Filled by a tanker truck and transferred to facility vehicles

Northwest approximately 70 ft to site storm drain

Spill Prevention: Level gauge, emergency shutoff switch, and prudent practices of oil transfer

Leak Detection: Routine inspections of tank containment units

(4.5' x 7' x 2.6') 605-gallon HDPE tank containment unit

Visual level gauge Spill kit in Building 2 -

Maintenance

Garage

Located in restricted access area that is fenced with locked gates, facility well lit

Inspections:

Monthly, annually, (see

Attachments B and C).

Integrity Testing: No required integrity testing.

UST8

TCEQ8

2,000 Outdoors, Building 24 Double-Walled

Fiberglass

Reinforced

Plastic (DWFRP)

Diesel Fuel, Red Filled by a tanker truck and transferred to facility vehicles

Northwest approximately 80 ft to site storm drain

Spill Prevention: Level gauge, emergency shutoff switch, and prudent inspections of tank containment units

(4.5' x 7' x 2.6') 605-gallon HDPE tank containment unit

Visual level gauge Spill kit in Building 2 -

Maintenance

Garage

Located in restricted access area that is fenced with locked gates, facility well lit

Inspections:

UST9

TCEQ9

500 Outdoors, Building 29 Double-Walled

Fiberglass

Reinforced

Plastic (DWFRP)

Diesel

Fuel, Red

Filled by a tanker truck and transferred to facility vehicles

Northwest approximately 90 ft to site storm drain

Spill Prevention: Level gauge, emergency shutoff switch, fuel shutoff valve, and prudent practices of oil transfer

Double-walled tank Visual level gauge, fuel shutoff valve

Spill kit in Building 2 -

Maintenance

Garage

Located in restricted access area that is fenced with locked gates, facility well lit

Inspections:

Leak Detection: Interstitial monitoring, routine inspections, and located on a concrete pad

AST1

TCEQ

FS-1

2,000 Outdoors, Fuel Station Double-Walled

Steel (DWS)

Gasoline Filled by a tanker truck, fuel for

Emergency

Generators

South then east approximately 250 ft total to site storm drain

Spill Prevention: Level gauge, overfill box, and prudent practices of oil transfer

Leak Detection: Interstitial monitoring (with alarm), routine inspections, and located above a concrete pad

Tank construction

(Concrete enclosing

HDPE membrane enclosing steel tank)

Level gauge, overfill box on fill port, overfill alarm (high fuel alarm)

Spill kit in Building 2

Generator Room

Located in restricted access area that is fenced with locked gates, facility well lit

Inspections:

Bonham, Texas

Oil

Source

Countermeasures

AST2

TCEQ

FS-2

10,000 Outdoors, Fuel Station Double-Walled

Steel (DWS)

Ethanol Filled by a tanker truck, fuel for

Emergency

Generators

South then east approximately 250 ft total to site storm drain

Spill Prevention: Level gauge, overfill box, and routine inspections, and located above a concrete pad

Tank construction

(Concrete enclosing

HDPE membrane enclosing steel tank)

Level gauge, overfill box on fill port, overfill alarm (high fuel alarm)

Spill kit in Building 2

Generator Room

Located in restricted access area that is fenced with locked gates, facility well lit

Inspections:

Attachments B, and C).

Integrity Testing: Formal external inspection by certified inspector every

20 years. Tank installed

July 2012.

AST3

TCEQ

FS-3

2,000 Outdoors, Fuel Station Double-Walled

Steel (DWS)

Diesel fuel Filled by an tanker truck, fuel for

Emergency

Generators

South then east approximately 250 ft total to site storm drain

Spill Prevention: Level gauge, overfill box, and routine inspections, and located above a concrete pad

Tank construction

(Concrete enclosing

HDPE membrane enclosing steel tank)

Level gauge, overfill box on fill port, overfill alarm (high fuel alarm)

Spill kit in Building 2

Generator Room

Located in restricted access area that is fenced with locked gates, facility well lit

Inspections:

external inspection by certified inspector every 20 years. Tank installed July

2012.

AST6

TCEQ3

3,000 Outdoors, Building 2 Double-Walled

Steel (DWS)

Diesel fuel, Red Day tanks for generators, automatic recirculation system between

AST4 and AST5

Self-Contained Room Spill Prevention: Level gauge and prudent inspections and located on concrete floor

(5' x 3' x 4') 450-gallon steel secondary containment structure

Level alarm (high fuel alarm), emergency shutoff switch

Spill kit in Building 2

Generator Room

Inside locked building

Inspections:

AST5

TCEQ4

2,000 Outdoors, Building 11 Double-Walled

Steel (DWS)

Diesel fuel, Red Day tanks for generators, automatic recirculation system between

AST4 and AST5

Self-Contained Room Spill Prevention: Level gauge, and prudent on concrete floor

(5' x 3' x 4') 450-gallon steel secondary containment structure

Level alarm (high fuel alarm), emergency shutoff switch

Spill kit in Building 2

Generator Room

Inside locked building

Inspections:

AST4

TCEQ5

25,000 Outdoors, Building 11 Double-Walled

Steel (DWS)

Diesel fuel, Red Day tanks for generators, automatic recirculation system between

AST4 and AST5

Self-Contained Room Spill Prevention: Level gauge, and prudent on concrete floor

(5’ x 3’ x 4’) 450-gallon steel secondary containment structure

Level alarm (high fuel alarm), emergency shutoff switch

Spill kit in Building 2

Generator Room

Inside locked building

Inspections:

AST7

TCEQ6

10,000 Outdoors, Fuel

Station

Double-Walled

Steel (DWS)

Ethanol

Bonham, Texas

100 Outdoors, Building 3 Single-walled steel

Generator

60 Outdoors, Building 24 Single-walled steel

Generator

50 Outdoors, Building 29 Single-walled steel

Generator

50 Outdoors, Building 1 Single-walled steel

Generator

50 Outdoors, Building 11 Single-walled steel

Generator

2 Each

(xxx gals)

Outdoors, Building 20 Single-walled steel

Transformer

Bonham, Texas

Oil Source

Countermeasures

Used Cooking Oil and Grease Containers

275 Outdoors, Building 3 Double-walled steel

Waste cooking oil and grease

Filled by hand and emptied by a third-party vendor

South approximately

30 feet to storm drain inlet

Spill Prevention: Prudent on concrete

See Section 4.3 in

Report Text

Procedure to follow:

1.) Verify container has sufficient free capacity for the transfer; 2.)

Visually monitor the product level throughout the transfer operation

No Room Locked tank Inspections:

external inspections every

10 years by a certified inspector, and leak testing every 10 years.

Miscellaneous Drum Storage

D1 55 total Indoors, Building 2 -

Maintenance

Garage, North Area

One 55-gallon steel drum

Used Oil Transferred manually

Northwest approximately 15 ft to floor drain (to oil water separator)

Leak Detection: Concrete floor and routine inspections

Stored on secondary containment pallets

Procedure to follow:

1.) Verify container has sufficient free capacity for the transfer; 2.)

Visually monitor the product level throughout the transfer operation

No Garage Inside locked building

Inspections: Monthly (see

Attachment D) required integrity testing

Hydraulic Elevator Reservoirs/Oil Filled Equipment

EQ1 <55 Building 1 - Main

Hospital Building, Loading Dock Area

Compactor

Reservoir

Hydraulic Oil Filled manually South approximately feet to storm drain inlet

Leak Detection: Concrete pad and routine inspections

Not applicable (oil-filled equipment)

Not applicable (oil-filled equipment) No spill kit Routine security inspections, in a well-light area

Inspections: Routine inspections by a third-party refuse contractor

TOTAL ABOVEGROUND OIL STORAGE (SPCC REGULATED): 48,810 GALLONS

ROLES AND RESPONSIBILITIES

Facility Emergency Coordinator / Alternate Facility Emergency

Coordinator

For purposes of implementing this plan, the IH/GEMS Program Manager) and Alternate are responsible for the following items:

General Implementation:

• Obtain all applicable signatures for the SPCC/PIPP Plan

• Distribute, post, and collect (upon completion) the applicable forms from the SPCC/PIPP

Plan (e.g., Monthly, and Annual Inspection Checklists, Notice to Petroleum Product

Vendors, and the Fuel Transfer Checklist)

• Execute or coordinate the routine daily, monthly, and annual inspections on the respective oil storage containers

• Coordinate or provide loading/unloading oil transfer oversight for transfers completed by outside tank vendors

• Maintain SPCC/PIPP records for a minimum of 5 years

• Coordinate and conduct annual SPCC/PIPP training

• Coordinate SPCC/PIPP amendments or required 3-year reviews for the SPCC/PIPP Plan

Spill Response:

• Implement the appropriate spill response operations and ensure the use of appropriate personal protective equipment

• Lead/coordinate emergency oil/fuel spill response team efforts

• Perform spill reporting, as necessary, following the procedures provided in this

SPCC/PIPP Plan

• Ensure the proper disposal of contaminated material

Polluting Material Handling Employees

Polluting material handling employees at the facility are responsible for operating and maintaining the oil and other storage containers at the facility. In relation to the SPCC and PIPP regulations, these responsibilities are as follows:

• Attend annual SPCC-PIPP training (all polluting material handling employees)

• Execute routine daily, monthly, and annual inspections (as assigned)

• Notify the Facility Emergency Coordinator of observed spills to start the emergency spill response procedure

• Place initial spill countermeasure materials (from facility spill kit(s))

SPILL RESPONSE

This portion of the SPCC-PIPP Plan covers this facility’s countermeasures to a potential spill and includes actions such as spill notification requirements, spill contents recovery, response, and cleanup.

All pollutant material spills, regardless of size, must be contained and cleaned up in a safe and effective manner. In general, the following steps should be taken to address a discharge, if possible and safe to do so:

1. Contact the FEC or the Alternate FEC.

2. Secure the site and eliminate potential spark sources.

3. Identify and stop the source of the discharge.

4. Contain the discharge with sorbent materials, berms, boom, or other materials.

5. Collect and dispose of recovered products according to regulation.

6. Complete reporting process according to regulations.

To determine the proper response procedures, this plan classifies spills as “Non-Reportable,”

”Reportable,” or “Imminent Danger,” depending on the following characteristics:

Table 2. Spill Classifications

Non-Reportable Spills Reportable Spills Imminent Danger Spills

• The spill is:

▪ <~6 gallons of oil product

(~50 pounds),

▪ <50 pounds of solid salt, or

▪ <50 gallons of liquid salt

OR

• The spill can be easily contained and cleaned up within 24 hours by facility personnel.

AND

• The spill did not reach the surface waters or groundwater of the state or public sanitary/sewer system

• The spill is:

▪ >~6 gallons of oil product

(~50 pounds),

▪ >50 pounds of solid salt, or

▪ >50 gallons of liquid salt

OR

• The spill reaches the surface waters or groundwater of the state or public sanitary/sewer system

• The spill poses an immediate hazard to human health or the environment.

OR

• There is danger of fire or explosion.

Response by facility personnel possible

Requires coordination with

Emergency

Management (EM) or

Alternate EM

Requires coordination with the Bonham Fire

Department – Call 911

See the flowchart in Attachment I for spill response steps to respond to each spill most appropriately.

SPILL RESPONSE MATERIALS AND WASTE DISPOSAL

Spill Response Materials

Location: Spill kit storage locations for the facility are listed in Table 1 and shown on Figure 2.

Approach: Place at locations central to the oil storage containers and near oil/fuel transfer areas.

Use: Control, contain, and clean up an oil spill.

Response Materials Needed: Materials to contain and absorb incidental spills (up to

20 gallons of oil).

Maintaining Response Materials: Inspect the spill response kits at least monthly to ensure sufficient supply.

Disposal of Used Sorbents and Contaminated Soil

• Record used sorbents and contaminated soil reclaimed after a spill in the Oil Spill

Disposal Record (Attachment K).

• Dispose used sorbents and contaminated soil in a manner consistent with local, state, and federal regulations, as well as VAMC policy.

• Contain absorbent materials separately from contaminated soil/granular clay (Oil-Dri) in drums or non-leaking containers.

• Work with your regulated waste vendor to determine if the spilled product may be considered a hazardous waste.

Note: Oil absorbents that are not hazardous waste may be placed in the trash if there is no free-flowing oil remaining in the absorbents. A licensed waste disposal company can help with removal and treatment of hazardous wastes and absorbents with free-flowing oil.

Safety Data Sheets

Safety data sheets for all potentially polluting materials are stored online at http://vaww.hefp.va.gov/ and accessed by qualified users.

http://vaww.hefp.va.gov/

SPILL NOTIFICATION REQUIREMENTS

Depending on the nature and quantity of the product released, several individuals and organizations must be contacted in the event of a spill. When there is a release, determining if, when, and to whom it should be reported can be a daunting task, even if you are familiar with the reporting requirements. There is NO PENALTY for over-reporting.

Non-Reportable Spill Notification Procedures

In the event of a non-Reportable spill as described in Section 3.0, facility personnel will contact the

FEC or Alternate FEC. After response and containment of the spill are complete, the FEC or designee will fill out the Spill or Release Report form provided in Attachments H and K. The FEC or Alternate

FEC, will not need to notify or submit the documentation to local, state, or federal agencies.

Table 3. Non-Reportable Spill Notification Procedures

Non-Reportable Spills Agency/

Organization

Contact #

When to Notify

▪ <6 gallons of oil product

(~50 pounds),

▪ <50 pounds of solid salt, or

▪ <50 gallons of liquid salt

OR

• The spill can be easily contained and cleaned up within 24 hours by facility personnel.

AND

• The spill did not reach the surface waters or groundwater of the state or public sanitary/sewer system

Site Contacts

Facility Emergency

Mike Hoffman

1-214-564-5906

Immediately

(verbal)

Alternate Facility

Emergency

Dennis Pollard

1-214-392-2728

Local Agencies ➔ Notification is Not Required

State Agencies ➔ Notification is Not Required

Federal Agencies ➔ Notification is Not Required

Reportable Spill Notification Procedures

In the event of a Reportable spill as described in Section 3.0, facility personnel will contact the FEC or

Alternate FEC. After response and containment of the spill are complete, the FEC or designee will fill out the Spill or Release Report form provided in Attachments H, J, and K. The FEC or Alternate FEC, will need to notify/submit the documentation to local, state, or federal agencies. See Section 3.2.

Table 4. Reportable Spill Notification Procedures

Reportable Spills Agency/ Organization Contact # When to Notify

▪ >~6 gallons of oil product (~50 pounds)

▪ >50 pounds of solid salt, or

▪ >50 gallons of liquid salt

OR

• The spill reaches the surface waters of the state or public sanitary/sewer system

Local Agencies

Bonham Water Treatment

Plant

1-972-442-5405 Immediately

(verbal) – for spills reaching public sanitary sewer system

Bonham Fire Department 1-903-640-0408

(non-emergency)

Immediately

(verbal) – for spills reaching public storm sewer system

Fannin County Emergency

Management

1-903-640-8484 Immediately (verbal)

State Agencies

First Contact:

Texas Commission on

Environment Quality

1-817-588-5800

(Emergency)

Immediately (verbal)

VISN 17: VA Heart of Texas

Health Care Network

1-817-385-1111

(Business Hours)

Immediately (verbal)

Texas Commission on

Environment Quality

Use their online form.

Call them at (888)

777-3186 (24 hours).

Written notification within 10 days

(See Section 3.2.1)

Federal Agencies

National Response Center

(NRC)

1-800-424-8802 www.nrc.uscg.mil

Immediately (verbal)

EPA Region 6 (hotline) 1-800-887-6063 Immediately (verbal)

EPA Region 6 Regional

Administrator

US EPA Region 6

1201 Elm Street, Suite 500

Dallas, TX 75270

Written notification within 60 days (see

Section 3.2.2)

Imminent Danger Spill Notification Procedures

In the event of an Imminent Danger spill as described in Section 3.0, facility personnel will contact

911 and the FEC or Alternate FEC. After evaluation, the FEC or Alternate FEC will determine the appropriate level of response and containment of the spill as either a Non-Reportable Spill or a

Reportable Spill as previously described.

http://www.nrc.uscg.mil/

Table 5. Imminent Danger Spill Notification Procedures

Imminent Danger Spills Agency/

Organization

Contact #

When to Notify

• The spill poses an immediate hazard to human health or the environment.

OR

• There is danger of fire or explosion.

Site Contacts

Facility Emergency

Mike Hoffman

1-214-857-5906

Alternate Facility

Emergency

Dennis Pollard

1-214-392-2728

Local Agencies

First Contact:

Bonham

Fire/Police

Department

911 Immediately

WRITTEN SPILL NOTIFICATION REQUIREMENTS

TCEQ Water Division Chief

A written notification to the TCEQ Water Division Chief is required after a reportable polluting material release. This report must be made within 10 days of the release and must include the following information:

1. Cause of the release.

2. Discovery of the release.

3. Response measures taken and/or schedule for completion of measures to be taken.

4. Measures to prevent recurrence of similar releases.

The Spill or Release Report (DEQ EQP3465 “Spill or Release Report”) form can be used for this written notification requirement and is provided in Attachment H.

USEPA Regional Administrator

A written notification to the TCEQ to a navigable waterway or adjoining shoreline waterway, for any discharge greater than 1,000 gallons, or for two discharges of 42 gallons or more of oil to navigable waters in any 12-month period. This report must be made within 60 days of the discharge and must include the following information:

1. Name of the facility.

2. Name of the individual submitting the information.

3. Location of the facility.

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

5. The corrective actions and/or countermeasures taken, including adequate description of equipment repairs and/or replacements.

6. An adequate description of the facility, including maps, flow diagrams, and topographical maps.

7. A complete copy of the SPCC Plan with any amendments.

8. The cause(s) of such discharge(s), including a failure analysis of the system or subsystem in which the failure(s) occurred.

9. Additional preventative measures taken or contemplated to minimize the possibility of recurrence.

SPILL PREVENTION AND CONTROLS

This section of the SPCC/PIPP Plan covers this facility’s prevention and control measures in place to help this facility limit its potential for spills.

POTENTIAL OIL RELEASE SOURCES

The oil sources at this facility, specific discharge volumes, direction of flow, and potential spill receptors for individual tanks and containers are listed in Table 1. An oil release could occur due to any of the following situations:

• During loading/unloading activities, such as:

– Overflow or spillage during tank or container filling:

▪ Potential rate of flow is dependent on fill rate of mobile tanker truck (typically ranges between 60 gallons per minute (gpm) and 300 gpm).

▪ Total volume released is dependent on how quickly the filling technician or facility representative (If observing transfer process) is able to press the emergency shutoff button on the truck and size/remaining product in the mobile tanker truck

(typically ranges from nil to hundreds of gallons).

– Spillage during tank or container emptying:

▪ Potential rate of flow is dependent on the empty rate of the pump (typically ranges from 5 to 10 gpm).

▪ Total volume released is dependent on how quickly the filling technician or facility representative (If observing transfer process) is able turn off/unplug the pump or press the emergency shutoff button on the truck and size/remaining product in the mobile tanker truck (typically ranges from nil to hundreds of gallons).

• Due to equipment failure, such as:

– Tank rupture because of nature, human error, or vandalism:

▪ Potential release rate is instantaneous (entire container contents released immediately) and total volume released is equal to the volume of the container

(see Table 1).

– Leaks due to corrosion or partial failure of tank or container seams, pipes, valves, or connections:

▪ Potential release rate is nil to 10 gpm and total volume released is equal to the volume of the container (see Table 1).

GENERAL SPILL PREVENTION MEASURES

Implement the following measures to prevent an oil spill during the handling, use, or transfer of oil products at the facility:

• Verify that tanks and containers are constructed of material compatible with the oil being stored (Section 4.8).

• Provide a functioning liquid level sensing device for bulk storage containers, such as a visual gauge, an electronic high-level alarm, or automatic pump cutoff (Section 4.4.3).

• Practice good housekeeping to ensure that oil storage areas are kept clear of debris.

• Promptly correct all visible spills (Section 3.0).

• Provide appropriate secondary containment (Section 4.3).

• Practice proper unloading/loading procedures during oil transfer activities

(Section 4.4/Attachment E).

• Conduct as-used, daily, monthly, and annual inspections on all SPCC/PIPP applicable tanks and containers (Section 4.5.1).

• Conduct integrity testing, or a practice that is environmentally equivalent, on tanks and containers as required (Section 4.5.2).

• Store sufficient spill response materials near oil sources (Section 3.3).

• Train personnel at least annually in proper oil-handling procedures (Section 4.2).

• Provide adequate security measures on and around all oil sources (Section 4.7).

• Maintain inspection and maintenance records for 3 years (Section 4.5.1/Section 7.0).

SECONDARY CONTAINMENT

All oil source areas listed in Table 1 at this facility are required to be designed with appropriate containment and/or diversionary structures. Common examples of secondary containment include double-wall tank construction, concrete containment berms, spill pallets for portable drums, nearby sorbent materials, oil/water separators, and self-contained concrete-floored rooms. Specific information regarding secondary containment measures provided for each tank and container is included in Table 1.

Oil storage containers at the facility generally have sufficient secondary containment with being double walled, inside steel or HDPES containment structure, in a self-contained room, or stored on secondary containment pallets. Bulk storage containers (tanks, drums) meet the requirements for sized containment in 40 CFR 112.8(c)(2). Elevator reservoirs and oil-filled equipment meet the general secondary containment requirements in 40 CFR 112.7(c).

Impracticability Determination

These oil sources are covered under this SPCC-PIPP Plan’s inspection and monitoring program

(Section 4.5.1 and Attachment B) and the SPCC-PIPP Plan’s written commitment of resources (page iii). Requirements for an oil spill contingency plan are satisfied by this SPCC-PIPP Plan as demonstrated in the following table:

Table 4. Cross-Reference with Spill Contingency Rules

Provision Rule Coverage Plan Section

109.5(a) Definition of the authorities, responsibilities, and duties of all persons Sections 1.2 and 2.0

109.5(b) Establishment of notification procedures Section 3.1

109.5(b)(1) Identification of critical water use areas Section 1.2

109.5(b)(2) Current list of names, telephone numbers, and addresses Sections 1.2 and 3.1

109.5(b)(3) Provisions for access to a reliable communications system Sections 1.2 and 3.1

109.5(b)(4) An established, prearranged procedure for requesting assistance Section 3.1

109.5(c) (1-

3)

Provisions to assure that full resource capability is known Section 3.1

109.5(d) (1-

5)

Provisions for well-defined and specific actions to be taken Section 3.0

OIL TRANSFER ACTIVITIES

Transfer Procedures

Oil transfer at the facility may include the filling and emptying of tanks by a tanker truck, the dispensing of oil from tanks into smaller containers or vehicles, or the transfer of used oil into tanks or containers. Specific oil transfer activities related to individual oil sources for this facility are included in Table 1. All petroleum product vendors and VAMC employees who deliver, load, unload, or pick up petroleum products must review and comply with the requirements set forth in

Attachment E, the Notice to Petroleum Product Vendors. During oil transfer activities, follow these measures to prevent a spill:

• Temporarily cover or block nearby storm or sanitary sewer drains.

• Know the location of the closest spill kit containing oil absorbent materials in case of a spill.

• Check to make sure the drivers understand the amount of product to be transferred and that they are constantly monitoring for potential oil storage container overfills.

• Ensure drivers are monitoring the transfer of oil full-time while the product is being transferred.

• Use wheel chocks or other similar barriers to prevent premature movement of transfer vehicles.

• Inspect around and below oil transfer vehicles for leaks before and after loading or unloading.

• For transfers not involving filling and emptying of tanks by a tanker truck, use a funnel or pump when adding or removing smaller quantities of oil to tanks, containers, or filling oil-filled electrical equipment reservoirs.

The Fuel/Oil Transfer Checklist (Attachment F) is recommended as a BMP for completion for each oil transfer conducted by a third-party vendor for tanks listed within this SPCC-PIPP Plan. Post the Notice to Petroleum Product Vendors (Attachment E) prominently in key oil transfer areas, to ensure these practices are followed by vendors and VAMC employees.

General Secondary Containment in Transfer Areas

Since other oil/fuel transfers at the facility are conducted on impervious surfaces and have nearby spill kits readily available for use if needed, they meet general secondary containment requirements in 40 CFR 112.7(c).

For the facility’s drum storage (D1), the facility is following the environmentally equivalent procedure below in lieu of the procedure in 40 CFR 112.8 (C)(8).

1. Verify container has sufficient free capacity for the transfer

2. Visually monitor the product level during transfer

INSPECTIONS AND INTEGRITY TESTING

Periodic Visual Inspections

The purpose of visual inspections is to determine if an oil release has occurred; evaluate the general condition of tanks, containers, and piping; and determine the suitability for continued oil storage until the next inspection. The inspection program for the facility includes routine daily observations for leakage from equipment as it is used, as well as documented monthly and annual scheduled inspections. Routine daily inspections are not required to be documented as part of this SPCC-PIPP

Plan.

Checklists used to document the inspections are included as Attachments B and C. Completed inspection forms must be kept for a minimum of 3 years. The visual inspections do not require a

Certified Inspector.

Table 1 lists the required inspection frequency for each oil source. Inspection criteria and schedules outlined in this plan are based on the Steel Tank Institute (STI) SP 001-18 (2018, 6th edition). This standard is applicable to shop-fabricated tanks (less than 30,000 gallons in capacity) and portable containers.

Conduct routine daily inspections by checking:

• Tanks, containers, and associated piping for evidence of leakage or spillage

• Tanks and containers for water or oil in the tank, interstice, or secondary containment

• Pumps and valves are locked or secured

• Manholes and sumps for any petroleum constituent or buildup

Conduct documented monthly inspections using Attachment B by checking:

• Storage areas for signs of debris that may block access

• Storage areas for unlabeled or outdated containers

• Tanks, containers, and associated piping for evidence of leakage or spillage

• Tanks and containers for water or oil in the tank, interstice, or secondary containment

• Pumps and valves are locked or secured

• Outdoor secondary containment structures that may require drainage (Attachment L)

• Manholes, sumps, and oil/water separator for any petroleum constituent or buildup

• Spill response materials for replacement or replenishment of spill response materials

Conduct documented annual inspections using Attachment C by checking:

• Secondary containment structures for evidence of damage

• Tank foundation and support structures for signs of settlement, corrosion, or damage

• Tank or container exterior coatings for needed cleaning or maintenance

• Tank normal and emergency vents for needed cleaning or maintenance

• Tank or container liquid level and overfill prevention sensing devices

Additional inspections and/or additional inspection items may be warranted if the facility incurs damaging severe weather events (e.g., lightning strikes, wind damage, flooding). The inspection frequency for the oil/fuel storage containers at this facility is summarized in the table below.

Table 5. Inspection Guidance by Container Type

Tank or Container Type Guidance Visual Inspection Frequency

Aboveground storage tanks STI SP-001-18 Monthly and annually

Used cooking oil containers STI SP-001-18 Monthly and annually

Portable drums STI SP-001-18 Monthly

The facility personnel performing these inspections are knowledgeable of the facility operations, characteristics of the oil stored, the type of container, and its associated components. The scope of inspections and procedures are covered in the training provided to employees involved in handling oil at the facility. The routine inspections focus specifically on detecting changes in conditions or evidence of oil leakage from the container, piping system, or appurtenances.

If non-conforming items important to the tank or containment integrity are identified, an evaluation by an engineer experienced in AST design, a certified inspector, or a tank manufacturer is required to determine the appropriate corrective action. As an alternative, the facility owner may replace the tank/container with a new tank/container.

Maintain copies of tank permits, licenses, records of inspections, and integrity tests.

Integrity Testing

The purpose of integrity testing is to measure the tank or container’s structural imperviousness and its soundness in containing oil, ensuring its suitability for continued use under current and anticipated operating conditions. Integrity testing may also help a facility determine whether corrosion has reached a point where repairs or replacement of the container is needed, and thus avoid unplanned interruptions in facility operations.

Compliance recommendations for the SPCC rule’s integrity testing requirements are based on the

STI Standard for the Inspection of Aboveground Storage Tanks (SP-001-18). The following table summarizes general integrity testing requirements.

Table 6. Integrity Testing Guidance by Container Type/Size

Tank Type Tank Volume

(gallons)

Secondary Containment

Guidance

Integrity

Testing

Frequency

Shop-built aboveground storage tanks

0 – 1,100

Spill control1 with or without a continuous release detection method2

STI SP-001-18

Not required

0 – 1,100 No Spill control1 STI SP-001-18 E&L (10)3

1,101 – 5,000

Spill control1 with a continuous release detection method2

5,001 – 30,000

Spill control1 with continuous release

E (20)3

Portable

Containers

Drums/Totes

Spill control1 with or without continuous release

1 Spill control is a means of preventing a release of liquid to the environment (e.g., secondary containment berm, dual-walled AST, or other secondary containment system).

2 Continuous release detection method (CRDM) refers to a means of detecting a release of liquid where releases are visually detectable by facility operators (e.g., dual-walled AST with interstitial monitoring port, elevated AST, AST on a concrete floor).

3 E&L (10) = Formal external inspections every 10 years by a certified inspector, and leak testing every

10 years by owner or owner’s designee.

E (20) = Formal external inspections every 20 years by a certified inspector

Formal integrity testing is not required for the steel drums in the drum storage area (D1), provided the containers have spill control in place, by means of containment pallets or other form of appropriate secondary containment.

Transformers are oil-filled operational equipment and are not considered bulk storage containers.

All transformers located on the facility are utility-owned and are therefore inspected and maintained by the Utility.

PERSONNEL TRAINING

All oil-handling personnel receive at least annual training to properly respond to spills in their work areas. The Facility Emergency Coordinator determines who is trained, and the content and training method (e.g., hands-on, classroom, computer-based). A training documentation form is provided as

Attachment D. Update the form each time the on-site staff receive training. Training needs to cover the following information:

• The contents of the facility SPCC Plan, including the specific locations of oil tanks and containers.

• The frequency and procedures of inspections and record keeping.

• The operation and maintenance of equipment to prevent spills.

• Spill response procedures.

• Applicable oil pollution prevention laws, rules, and regulations.

• General facility operations; and

• Discharge prevention briefings highlighting and describing discharges or failures, malfunctioning components, and any recently developed precautionary measures.

SECURITY

To ensure the safety of the facility personnel and to minimize the potential for releases of oil and other polluting materials, various security measures are in place. Moist polluting material are located within locked buildings or rooms eliminating access to indoor oil storage off-hours. The facility is fully fenced and the outdoor areas around the facility are well-lit to discourage vandalism during non-working hours. Specific security information related to individual tanks and containers is listed in Table 1.

TANK CONSTRUCTION MATERIAL

The facility’s oil-filled containers are compatible with the contents they store and the conditions they are stored in. See Table 1 for specific container construction information.

CONFORMANCE WITH APPLICABLE STATE REQUIREMENTS

This SPCC-PIPP Plan was prepared and is implemented consistent with the current version of 40 CFR

112 and the Texas Commission of Environmental Quality, Surface Water Resources Division

Regulations R 324.2001 – R 324.2009 of the Texas Administrative Code (TAC). Refer to Attachment

A for a summary of how this Plan complies with applicable portions of MAC.

CERTIFICATION REQUIREMENTS

The facility has approximately 48,910 gallons of aboveground oil storage capacity in containers 55 gallons or greater. Since the facility has over 10,000 gallons of aboveground oil storage capacity, a

Professional Engineer must certify the mandatory 5-year SPCC review and future amendments to this

SPCC/PIPP Plan.

RECORDS

Maintain inspection checklists, recertification logs, spill/release reports, fuel delivery notice and storm water release logs, and fuel transfer checklists in Attachments A through N for a minimum of

5 years.

Figures

1 Site Location Map

2 Facility Site Plan

SITE LOCATION

Bonham.zip

BONHAM TOPO SITE

MAP STORAGE TANKS.pdf site locations.pdf

Fuel Tanks.pdf

Attachments

A Cross-Reference with the SPCC Rule

B Monthly Inspection Checklist

C Annual Tank Inspection Checklist

D SPCC Training Record

E Notice to Petroleum Product Vendors

F Fuel/Oil Transfer Checklist

G Annual SPCC Plan Review

H Spill Incident Report

I Spill Response Flow Chart

J Spill Reporting Compliance Documentation Log

K Oil Spill Disposal Record

L Secondary Containment Area Storm Water Release

Log

M SPCC Plan Review and Recertification Log

N SPCC Plan Amendment Certification

Attachment A

Cross Reference with the SPCC Rule

Sam Rayburn Memorial Veterans

Center

40 CFR Part 112 Description SPCC Plan/PIPP Location

Subpart A: Applicability, Definitions, and General Requirements for All Facilities and All Types of

Oils

§ 112.1 General applicability Section 1.1

§ 112.2 Definitions See 40 CFR 112

§ 112.3(d) Professional Engineer Review & Certification Section 1.0, Page v

§ 112.3(e) Plan location and availability Section 1.2

§ 112.4 Regional Administrator Submittal Section 3.3

§ 112.5 Amendment of SPCC Plan by owners or operators

Cover letter, Section 6.0, and Attachments M and N

§ 112.6(a)(1) Qualified Facilities Plan requirements Not applicable

§ 112.6(a)(2) Technical Amendments Attachment N

§ 112.7 General requirements for SPCC Plans

§ 112.7(a)(1) Conformance with applicable parts of § 112.7 Sections 1.0 and 5.0

§ 112.7(a)(2) Compliance with applicable parts of § 112.7 See the other cross-references in this table

§ 112.7(a)(3) Physical layout and facility diagram Figure 2

(a)(3)(i) Oil storage type and capacity Table 1

(a)(3)(ii) Discharge prevention measures Section 4.0 and Table 1

(a)(3)(iii) Discharge or drainage controls Section 4.0 and Table 1

(a)(3)(iv) Countermeasures for discharge discovery, response, and cleanup Section 3.0

(a)(3)(v) Recovered material disposal Section 3.4

(a)(3)(vi) Contact list Section 1.2 and 3.2

§ 112.7(a)(4) Response plan or spill reporting procedures Section 3.0, and

Attachments H and I

§ 112.7(a)(5) Discharge procedures to use in emergency Section 3.0, and

Attachments H and I

§ 112.7(b) Spill direction, rate of flow and total quantity of oil during failures

Section 4.1, Table 1 and Figure 2

§ 112.7(c) General Secondary Containment Section 4.3

§ 112.7(d)(1) Secondary containment impracticability determination Section 4.3.1

§ 112.7(d)(2) Written commitment of manpower, equipment, and materials Page…