839CM3028_3030 Fuel Tank Closure Culpeper.pdf

Culpeper National Cemetery Projects 839CM3028 and 839CM3030

Columbarium, Facility Renovation, 100% CDs – April 24, 2020

Improvements and Repairs, and Pre-Placed Crypts

Culpeper National Cemetary

DESIGN NARRATIVE

To: File Date: April 15, 2020

Existing Underground Oil Storage Tank / Aboveground Propane Tank Revision 1

Applicable Codes, Regulations and Policy Guidance

1.0 Primary Design Criteria

• Code of Federal Regulations (CFR)- 40 CFR 280

• Virginia Administrative Code (VAC) - 9 VAC 25-580

• Virginia Construction Code (VCC) – 414.6.2

• Virginia Statewide Fire Prevention Code (SFPC) – 5704.2.13.1.4

2.0 Specific Site Conditions

The following information was compiled from observations made during a site reconnaissance conducted on 2020 February 20. The following is a summary of information for each tank to be assessed at the project site.

Heating Oil Tank – Ex Lodge Building

Tank No: N/A Tank Dimensions: 4’ x 10.5’ (estimated)

Location: Ex Lodge Building Overburden Depth: 2-feet

Capacity: 1,000-gallons (estimated) Overburden Type: Soil / Grass

Contents: Heating Oil Liquid in Tank: 17 inches (325-gallons)

Status: Out of Service Removal / Abandonment: Abandonment

Position:

Grass area south of Lodge entrance between flagstone walkway and drive area.

Fill & Vent Pipe Accessible: Yes

This tank is currently out-of-service and consists of a 1,000-gallon single-walled steel underground storage tank (UST). The UST is approximately 4-foot diameter and 10.5-feet in length. This tank is located in a grass covered area under approximately 2-feet of cover. This tank contains approximately 17-inches of liquid (heating oil), which equates to approximately 325-gallons. The orientation of this tank appears to run north-south, parallel to the walkway.

Historic Gasoline Tank – Location Unknown

Culpeper National Cemetery staff reported the suspected presence of an additional underground storage tank at the facility, which reportedly stored gasoline. The location of this tank was unknown. KCI inspected the facility for visual indications of a UST, such as fill port, vent, dispenser, piping, sumps, etc. -no visual indications were present. KCI reviewed Virginia Department of Environmental Quality (VDEQ) records regarding USTs registered at the subject site. According to VDEQ records there was a 1,000-gallon UST, used to store gasoline, in use at the facility between 1978 and 1988; records indicate that the tank was removed from the ground in April 1988. Based on available information appears that the former gasoline UST has been removed from the property, no indications of an additional tank are present.

3.0 Closure of Existing Underground Storage Tank (UST)

3.1 Tank Removal vs Abandonment

Due to the location of the tank relative to the existing Lodge structure and emergency generator system, as well as the presence of known utilities (storm drain, electrical and telecom lines) running within close proximity to the tank, KCI is currently recommending the Heating Oil tank be disconnected from all piping, fill and vent structures, filled with a concrete slurry, and abandoned in place. This option provides the most secure and cost-effective method closure when considering the need for maintaining structural support for the Lodge, emergency generator and buried utilities.

While abandonment in place is recommended, the alternative would be removal of the tank from the ground. This option is not our recommended course of action due to the possibility of damage to the existing utilities running across the tank field. Additionally, shoring of the excavation area would likely be required to maintain structural support for the Lodge and emergency generator system. Installation of shoring could prove to be problematic given the limited access to the work area. (The decision was made to remove the tank and the specifications reflect removing the tank since this area will be disturbed because new utilities being installed) (comment added April 15, 2020 for clarification and compliment the specifications.) CTD 4-15-20

3.2 Regulatory Requirements – Tank Abandonment

Federal regulations (40 CFR 280) do not apply to underground storage tanks used to store heating oil consumed on-site.

Virginia environmental regulations pertaining to USTs (9 VAC 25-580) excludes underground storage tanks used to store heating oil consumed on-site. Specifically, heating oil tanks are excluded from the definition of a UST and therefore the regulations pertaining to USTs.

While not regulated under Virginia environmental regulations, USTs are still regulated under the Virginia Uniform Statewide Building Code. A review of the Virginia Statewide Fire Prevention Code (SFPC), Chapter 5704, Section 2.13.1.4 provided the requirements for tank abandonment. These are provided below:

5704.2.13.1.4 -Tanks abandoned in place.

Tanks abandoned in place shall be as follows:

1. Flammable and combustible liquids shall be removed from the tank and connected piping.

2. The suction, inlet, gauge, vapor return and vapor lines shall be disconnected.

3. The tank shall be filled completely with an approved inert solid material.

4. Remaining underground piping shall be capped or plugged.

5. A record of tank size, location and date of abandonment shall be retained.

6. All exterior above-grade fill piping shall be permanently removed when tanks are abandoned or removed.

KCI has made several attempts to reach representatives of the Culpeper County Government to determine if the County has any requirements regarding the closure of UST systems. KCI spoke with Mr. Bob Orr, with the Culpeper County Building Department. Mr. Orr stated that as a federal facility the County would defer regulation of the tanks to the federal government.

At this time, KCI recommends adhering to SFPC requirements regarding UST abandonment.

4.0 Closure of Existing Aboveground Propane Tank

The existing aboveground propane tank has a capacity of approximately 500-gallons. Regarding closure of the existing aboveground propane tank, KCI was unable to identify any regulations pertaining the closure of aboveground propane tanks. As such, it is recommended that a licensed propane supplier be used to remove any residual propane from the tank, disconnect all piping from the tank, then load, transport, and dispose of the tank.