A-2 Hot Springs Tank Inventory Current SPCC Plan.pdf

HOT SPRINGS VA HEALTH CARE SYSTEM

HOT SPRINGS, SOUTH DAKOTA

Hot Springs Update SPCC Plans 2021

(100%) Report Submission

CO NTRA CT NO.: 36C26321C0041

PROJECT NO.: 568-20-SL-002

May 28, 2021

U.S. DEPARTMENT OF

V E T E R ANS AF FAI R S

Veterans Health Administration Black Hills VA- Hot Springs Health Care System

Table of Contents

1.0 MANAGEMENT APPROVAL / DESIGNATED PERSON AND RELEASE NOTIFICATION PLAN (40

CFR 112.7)

1.1 Professional Engineer’s Certification (40 CFR 112.3(d))

1.2 Location of SPCC Plan (40 CFR 112.3(e))

1.3 Plan Review/Amendments (40 CFR 112.3 and 112.5)

1.3.1 Changes in Facility

1.3.2 Scheduled Plan Reviews

1.3.3 Record of Plan Reviews

1.3.4 Description of Non-Conformance

1.4 Facilities, Procedures, Methods, or Equipment Not Yet Fully Operational (40 CFR 112.7)

2.0 INTRODUCTION (40 CFR 112.1; 112.4(a))

2.1 Plan Organization and Regulatory References (40 CFR 112.7)

3.0 FACILITY INFORMATION

3.1 Facility Diagram and Location (40 CFR 112.7 (a)(3))

3.2 Facility Description

3.3 Bulk Storage Containers (40 CFR 112.8 (c))

4.0 DISCHARGE POTENTIAL

4.1 Distance to Navigable Waters

4.2 Discharge History

4.3 Potential Discharge Volumes and Rates (40 CFR 112.7 (a)(3)(i & iii); 112.7 (b))

4.4 Containment and Diversionary Structures (40 CFR 112.7 (c))

4.5 Impracticality of Secondary Containment (40 CFR 112.7 (d))

4.6 Inspections, Tests and Records (40 CFR 112.7 (e))

4.7 Personnel Training (40 CFR 112.7(f)(1-3))

4.8 Site Security (40 CFR 112.7 (g))

4.9 Loading/Unloading Operations (40 CFR 112.7(h)(1-3))

4.9.1 Loading/Unloading Procedures (40 CFR 112.7(h)(2) and (3))

4.10 Conformance with Other Applicable Requirements (40 CFR 112.7(j))

4.10.1 State of South Dakota Requirements

4.10.2 Industry Standards

5.0 DISCHARGE PREVENTION

5.1 Facility Drainage (40 CFR 112.8(b)(1-5))

5.2 Container Compatibility with its Contents (40 CFR 112.8(c)(1))

5.3 Secondary Containment (40 CFR 112.8(c)(2))

5.4 Drainage of Diked Areas (40 CFR 112.8(c)(3))

5.5 Corrosion Protection and Leak Testing of Underground Storage Tanks (40 CFR 112.8(c)(4)) . 26

5.6 Partially Buried and Bunkered Storage Tanks (40 CFR 112.8(c)(5))

5.7 Above Ground Tank Inspections and Tests (40 CFR 112.8(c)(6))

5.8 Heating Coils (40 CFR 112.8(c)(7))

5.9 Overfill Prevention Systems (40 CFR 112.8(c)(8))

5.10 Effluent Treatment Facilities (40 CFR 112.8(c)(9))

5.11 Visible Discharges (40 CFR 112.8(c)(10))

5.12 Mobile and Portable Containers (40 CFR 112.8(c)(11))

5.13 Transfer Operations, Pumping, and In-Plant Processes (40 CFR 112.8(d))

6.0 DISCHARGE RESPONSE

6.1 Response to a Minor Discharge

6.2 Response to a Major Discharge

6.3 Notification Procedures

6.4 Reporting (40 CFR 112.4)

6.5 Clean-up Contractors

6.6 Oil Contaminated Materials Disposal

List of Figures

Figure 1. Vicinity Map Figure 2. Site Layout Showing AST Inventory, Flow Paths, and Spill Kit Locations Figure 3. Site Layout Showing Transformer Locations

List of Tables

Table 2.1. Regulatory Requirement and Text Cross-Reference Matrix Table 4.1. Oil Storage Inventory of SPCC ASTs, USTs, and Containers Table 4.2. Inventory of Transformers

Appendices

APPENDIX A - SPCC REVIEW LOGS

APPENDIX B - SUBSTANTIAL HARM DETERMINATION CERTIFICATION FORM

APPENDIX C - EXAMPLE INSPECTION CHECKLISTS

APPENDIX D - RECORD OF ANNUAL DISCHARGE PREVENTION TRAINING

APPENDIX E - EXAMPLE LOADING/UNLOADING PROCEDURE

APPENDIX F – PHOTOGRAPHS

APPENDIX G – SPILL REPORT FORMS

Spill Prevention, Control, and Countermeasure Plan Hot Springs VA Medical Center Page 1 of 62

1.0 MANAGEMENT APPROVAL / DESIGNATED PERSON AND RELEASE

NOTIFICATION PLAN (40 CFR 112.7)

This Spill Prevention, Control, and Countermeasure (SPCC) Plan was prepared in accordance with good engineering practices and has the full approval of management. The Authorized

Facility Representative (AFR) is the designated Person Accountable for Oil Spill Prevention at the facility and has the authority to commit whatever personnel, equipment, and materials are deemed necessary to implement this plan. Management is fully committed to the implementation of the requirements set forth in this SPCC Plan. The priorities of response team members are based upon protection of human life, mitigating environmental harm, and protection of property, respectively.

Authorized Facility Representative (AFR):

Signature: _________________________________________________

John E. Henderson

Chief Facilities Management, VA BHHCS

Date: __________________________________

Release Notification Plan – Hot Springs VA Campus

The Hot Springs VA Medical Center SPILL, PREVENTION, CONTROL AND

COUNTERMEASURE PLAN (SPCC) dated 05/31/2021 serves as the RELEASE NOTIFICATION

PLAN for this facility.

Material Data Safety Sheets for regulated substances are maintained on the VA BHHCS’ electronic SDS database.

Signature: ____________________________________________

John E. Henderson

Chief Facilities Management, VA BHHCS

Date: __________________________________

Hot Springs VA Medical Center Page 2 of 62

1.1 Professional Engineer’s Certification (40 CFR 112.3(d))

In accordance with 40 CFR 112.3(a), I hereby certify that I have visited and examined the facility in accordance with 40 CFR 112.3 (d), and, being familiar with the provisions of 40 CFR

112, U.S. Environmental Protection Agency Regulations on Oil Pollution Prevention, attest that the Spill Prevention, Control, and Countermeasure (SPCC) Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of 40 CFR part 112; that procedures for required inspections and testing have been established; and that the SPCC Plan is adequate for the facility. [40 CFR 112.3(d)]

This certification in no way may be construed as a warranty by the Licensed Professional

Engineer that the adequate SPCC Plan will be fully implemented, and in no way relieves the owner or operator of the facility of their duty to prepare and fully implement this SPCC Plan in accordance with the requirements of 40 CFR 112. This Plan is only valid to the extent that the facility owner or operator maintains, tests, and inspects equipment, containment, and other devices as prescribed in this Plan. Furthermore, all information and data related to all tanks, containers, and transformers was provided by the owner and/or operator. This information and data were utilized throughout this SPCC Plan. Construction type of all tanks, containers, and transformers was also provided by the owner and/or operator and was relied upon as the most accurate information available.

____________________________________________ Date: ________________________ Signature

Shane A. Matt, PE

State of South Dakota, PE No. 7899

05/26/2021

05/26/2021

Hot Springs VA Medical Center Page 3 of 62

1.2 Location of SPCC Plan (40 CFR 112.3(e))

In accordance with 40 CFR 112.3(e), a complete copy of this SPCC Plan is maintained at the

Hot Springs VA Medical Center Facilities Management Office and the Hot Springs VA Medical

Center Fire Department. The Fire Department is staffed 24 hours per day 7 days per week.

1.3 Plan Review/Amendments (40 CFR 112.3 and 112.5)

1.3.1 Changes in Facility

In accordance with 40 CFR 112.5(a), this SPCC Plan will be reviewed for changes in the facility design, construction, operation, or maintenance that materially affects the facility’s potential for an oil discharge into or upon the navigable waters of the United States or adjoining shoreline’s or that may impact natural resources belonging to, appertaining to, or under the exclusive management authority of the United States.

Examples of changes that may require amendment of the SPCC Plan include, but are not limited to, any of the following:

• Commissioning or decommissioning containers

• Replacing, reconstructing, or moving containers

• Replacing, reconstructing, or installing piping systems

• Construction or demolition that might alter secondary containment structures

• Changes of product or service

• Revising standard operation or maintenance procedures at a facility o Modification/inspection procedures and use of new or modified industry standards

Amendments to the Plan made to address changes of this nature are referred to as technical amendments and must be certified by a Professional Engineer. Non-technical amendments can be done (and must be documented in this section) by the facility owner and/or operator.

Nontechnical amendments include the following:

• Change in the name or contact information (i.e., telephone numbers) or individuals responsible for the implementation of this Plan; or

• Change in the name or contact information of spill response or cleanup contractors.

Hot Springs VA Medical Center Page 4 of 62

Revisions to the SPCC Plan must be made as soon as possible, but no later than six months after the change occurs. The Plan must be implemented as soon as possible following any technical amendment, but no later than six months from the date of the amendment. The

Authorized Facility Representative or designee is responsible for initiating and coordinating revisions to the SPCC Plan.

1.3.2 Scheduled Plan Reviews

In accordance with 40 CFR 112.5(b), this SPCC Plan will be reviewed at least once every five years. Revisions to the Plan, if needed, are made within six months of the five-year review.

A registered Professional Engineer certifies any technical amendment to the Plan, as described above, in accordance with 40 CFR 112.3(d).

1.3.3 Record of Plan Reviews

Scheduled reviews and Plan amendments are recorded in the SPCC Review Log

(Appendix A). This log must be completed even if no amendment is made to the Plan as a result of the review.

1.3.4 Description of Non-Conformance

There are none so this section is not applicable.

1.4 Facilities, Procedures, Methods, or Equipment Not Yet Fully Operational (40

CFR 112.7)

There are none so this section is not applicable.

Hot Springs VA Medical Center Page 5 of 62

2.0 INTRODUCTION (40 CFR 112.1; 112.4(a))

Spill Prevention, Control, and Countermeasure plans for facilities are prepared and implemented as required by U.S. Environmental Protection Agency (U.S. EPA) regulations contained in Title 40, Code of Federal Regulations, Part 112 (40 CFR 112). A non-transportation related facility is subject to SPCC regulations if: 1) due to its location, the facility could reasonably be expected to discharge oil into or upon the navigable waters of the United

States; 2) the total aboveground storage capacity exceeds 1,320 gallons (calculated total of containers with capacity of 55 gallons or more); or 3) the completely buried storage capacity exceeds 42,000 gallons. Completely buried tanks subject to all the technical requirements of

40 CFR Parts 280 and 281 do not count in the calculation of the 42,000-gallon threshold.

The SPCC plan is not required to be filed with U.S. EPA, but a copy must be available for on-site review by the Regional Administrator during normal working hours if the subject facility is attended at least 4 hours a day. The SPCC plan must be submitted to the U.S. EPA Regional

Administrator and the state agency in charge of oil pollution control along with the other information specified in 40 CFR 112.4 if either of the following occurs:

1. The facility discharges more than 1,000 gallons of oil into or upon navigable water of the United States or adjoining shorelines in a single event; or

2. The facility discharges more than 42 gallons of oil in each of two discharge events within any 12-month period. Discharge information must be reported to U.S. EPA and the state agency within 60 days if either of the above thresholds are reached.

This Plan provides guidance on key actions that must be performed to comply with the SPCC rule:

• Complete monthly and annual site inspections as outlined in the Inspection and Tests section of this Plan (Section 4.6 & 5.7).

• Perform preventive maintenance of equipment, secondary containment systems, and discharge prevention systems described in this Plan as needed to keep them in proper operating conditions.

• Conduct annual employee training as outlined in the Personnel Training of this Plan

(Section 4.7).

Hot Springs VA Medical Center Page 6 of 62

• If either of the following occurs, submit the SPCC Plan to the EPA Region 8 Regional

Administrator (RA) along with other information as detailed in Section 6.4 of this Plan:

o The facility discharges more than 1,000 gallons of oil into or upon the navigable waters of the U.S. or adjoining shorelines in a single spill event; or o The facility discharges more than 42 gallons in each of two discharge events within any 12-month period.

• Review the SPCC Plan at least once every five (5) years and amend it to include more effective prevention and control technology if such technology will significantly reduce the likelihood of a discharge event and has been proven effective in the field at the time of the review. Plan amendments, other than administrative changes discussed above, must be recertified by a Professional Engineer on the certification page in

Section 1.1 of this Plan.

The SPCC plan shall be amended within 6 months whenever there is a change in facility design, construction, operation, or maintenance that materially affects the facility’s discharge potential. The plan must be reviewed once every 5 years and amended to include more effective prevention and control technology if such technology will significantly reduce the likelihood of a discharge event and has been proven in the field. All technical amendments must be certified by a registered professional engineer.

The Hot Springs VA Medical Center facility does not pose a risk of substantial harm under 40

CFR part 112, as recorded in the “Substantial Harm Determination” included in Appendix B.

2.1 Plan Organization and Regulatory References (40 CFR 112.7)

In general, this SPCC Plan follows the sequence of the regulatory requirements outlined in 40

CFR 112.7 and 112.8 and discusses the facility’s conformance to those applicable regulatory requirements. For sections with regulatory references, the federal SPCC regulatory requirements are summarized in Table 2.1, they are also noted at the end of each title to the section pertaining to the regulatory requirements.

Hot Springs VA Medical Center Page 7 of 62

Table 2.1. Regulatory Requirement and Text Cross-Reference Matrix.

Regulatory Requirement and Text Cross-Reference Matrix

Topic

CFR Citation

Spill Prevention, Control, and Countermeasure Section

Requirement for an SPCC Plan 40 CFR 112.1 2.0

Professional Engineer Certification 40 CFR 112.3(d) 1.1

Plan Available On-site 40 CFR 112.3(e) 1.2

Reportable Discharges 40 CFR 112.4(a) 2.0 & 6.0

Amendment of SPCC Plan by Regional Administrator 40 CFR 112.4 6.4

Plan Amendment — Change Affecting Potential for Discharge

40 CFR 112.5(a) 1.3.1

Plan Amendment — 5-Year Plan Review and Amendment

40 CFR 112.5(b) 1.3.2

Professional Engineer Certification of Technical Amendments

40 CFR 112.5(c)

1.3.1 & 1.3.2

Summary of Deficiencies from Rule Requirements 40 CFR 112.7(a)(2) 1.3.4

Facility Diagram 40 CFR 112.7(a)(3) 3.1

Oil Storage 40 CFR 112.7(a)(3)(i) 4.3

Discharge Prevention and Routine Handling 40 CFR 112.7(a)(3)(ii) 4.0 & 5.0

Discharge or Drainage Controls 40 CFR 112.7(a)(3)(iii) Table 4.1 & 5.0

Countermeasures for Discharge Discovery, Response, and Cleanup

40 CFR 112.7(a)(3)(iv)

5.0 & 6.0

Methods of Disposal of Recovered Materials 40 CFR 112.7(a)(3)(v) 6.0

Contact List and Telephone Numbers 40 CFR 112.7(a)(3)(vi) 6.3 & Appendix G

Discharge Reporting Procedures 40 CFR 112.7(a)(4) 2.0, 6.4, Appendix G

Discharge Emergency Response Procedures 40 CFR 112.7(a)(5) 6.0 & Appendix G

Potential Spill Predictions, Volumes, Rates, and Control

40 CFR 112.7(b)

4.3 & Table 4.1

Drainage Prevention Diversionary Structures and Containment

40 CFR 112.7(c) 4.4

Impracticality of Secondary Containment 40 CFR 112.7(d) 4.5

Inspection/Record Keeping 40 CFR 112.7(e) 4.6

Personnel Training and Spill Prevention Procedures 40 CFR 112.7(f)(1-3) 4.7 & Appendix D

Site Security 40 CFR 112.7(g) 4.8

Loading/Unloading Operations 40 CFR 112.7(h)(1-3) 4.9 & Appendix E

Adequate Secondary Containment for Loading/Unloading Racks

40 CFR 112.7(h)(1) 4.9

Warning or Barrier System for Vehicles 40 CFR 112.7(h)(2) N/A

Vehicles Examined for Lowermost Drainage Outlets before Leaving

40 CFR 112.7(h)(3) N/A

Brittle Fracture or Other Catastrophe of Field- Constructed Tanks

40 CFR 112.7(i) N/A

Conformance with Other Applicable Requirements 40 CFR 112.7(j) 4.10

Hot Springs VA Medical Center Page 8 of 62

Drainage Control 40 CFR 112.8(b)(1-5) 5.1

Drainage from Diked Storage Areas 40 CFR 112.8(b)(1) 5.1 & 5.4

Valves Used on Diked Storage Areas 40 CFR 112.8(b)(2) 5.1 & 5.4

Plant Drainage Systems from Undiked Areas 40 CFR 112.8(b)(3) 5.1

Final Discharge of Drainage 40 CFR 112.8(b)(4) 5.1

Facility Drainage Systems and Equipment 40 CFR 112.8(b)(5) 5.1

Bulk Storage Tanks/Secondary Containment 40 CFR 112.8(c)(1-11) 5.3

Container Compatibility with Its Contents 40 CFR 112.8(c)(1) 5.2

Diked Area Construction and Containment Volume for Storage Containers

40 CFR 112.8(c)(2) 5.3

Diked Area, Inspection, and Drainage of Rainwater 40 CFR 112.8(c)(3) 5.4

Corrosion Protection of Buried Metallic Storage Tanks

40 CFR 112.8(c)(4) 5.5

Corrosion Protection of Partially Buried Metallic Tanks

40 CFR 112.8(c)(5) 5.6

Aboveground Tank Periodic Integrity Assessment 40 CFR 112.8(c)(6) 5.7

Control of Leakage through Internal Heating Coils 40 CFR 112.8(c)(7) 5.8

Liquid-Level Sensing Devices 40 CFR 112.8(c)(8) 5.9

Observation of Disposal Facilities for Effluent Discharge

40 CFR 112.8(c)(9) 5.10

Visible Oil Leak Corrections from Tank Seams and Gaskets

40 CFR 112.8(c)(10) 5.11

Appropriate Position of Mobile or Portable Oil Storage Containers

40 CFR 112.8(c)(11) 5.12

Facility Transfer Operations 40 CFR 112.8(d)(1-5) 5.13

Buried Piping Installation Protection and Examination 40 CFR 112.8(d)(1) N/A

Not-In-Service and Standby Service Terminal Connections

40 CFR 112.8(d)(2) N/A

Pipe Supports Design 40 CFR 112.8(d)(3-5) 5.2

Hot Springs VA Medical Center Page 9 of 62

3.0 FACILITY INFORMATION

Facility Name: Hot Springs VA Medical Center

Address: 500 North 5th Street

Hot Springs, SD 57747

Telephone: (605) – 745 - 2000

Owner: United States of America

Department of Veterans Affairs

801 Vermont Avenue, NW

Washington, DC 20420

3.1 Facility Diagram and Location (40 CFR 112.7 (a)(3))

The facility is in Fall River County near the center of Hot Springs, South Dakota. The Center is accessed from the south via Fifth Street and from the west via Highway 385. The facility coordinates are 44.43722° north latitude and 103.47808° west longitude. The nearest perennial surface water body, Fall River, is located approximately 0.1 miles northwest of the main building. Figure 1 shows the general location of the facility.

NOT TO SCALE

FIGURE 1

VICINITY MAP

JOB NUMBER: 21-105

DATE: 5/19/2021

DRAWING: 105-HSFIG01.dwg

SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN (SPCC)

HOT SPRINGS VA MEDICAL CENTER, HOT SPRINGS SOUTH DAKOTA

HOT SPRINGS VA MEDICAL CENTER

Hot Springs VA Medical Center Page 11 of 62

3.2 Facility Description

Veterans Affairs Hospital with aboveground petroleum storage tanks for emergency generators, boiler fuel, vehicles, and hydraulic elevators/hoist. The Hospital also collects used oil and used food grease.

3.3 Bulk Storage Containers (40 CFR 112.8 (c))

Table 4.1 (section 4.3) lists the petroleum storage tanks that are located at the Hot Springs VA

Medical Center. Table 4.2 (section 4.3) lists the transformers located at the Hot Springs VA

Medical Center. Figure 2 shows the location of all tanks/containers and spill kits at the facility and Figure 3 shows the location of the transformers at the facility. Appendix F shows photos of the complete inventory of all AST tanks, containers, food grease (FG) containers, transformers

(TR), and spill kits. See the summary below for total volumes.

• TOTAL AST STORAGE: 126,255 GALLONS

• TOTAL FG STORAGE: 220 GALLONS

• TOTAL TR STORAGE: 2,328 GALLONS

• TOTAL STORAGE: 128,803 GALLONS

X X X X X X X X X

XX X X X X X X

X X X

X X X X

X

X

X

X

X

X

X

X

XXXX

RI

VE

R

ST

RE

ET

E

NT

RA

NC

E

TO NATIONAL CEMETERY

B

C

TELE.

MEDICAL

WASTE

BUILDING

FUEL

STORAGE

TANKS

EMPLOYEE

LOT

D.V.A.M.C.

GRAND

STAIRCASE

C O

U R

T

C O

U R

T

PA

TI

O

To: #39

CARWASH PAD

DOMICILIARY PARKING LOT

MAIN PARKING LOT

HOSPITAL

BUILDING

DOWN

BLOW

DEAERATOR

ARTESIAN

PLANT

BOILER

HAZARDOUS

WASTE

BUILDING

FIFTH

STREET

Stm Inlet

Stm Inlet

Stm Inlet

Oil Leak Sump

Sump Area in Grass

Stm Inlet

A-1, A-2, A-3

39,590 GAL

#2 DIESEL

A-14 (2) 55 GAL CYLINDER OIL

A-15 (2) 55 GAL COMPRESSOR OIL

A-13

500 GAL

#2 DIESEL

A-18

75 GAL

#2 DIESEL

P-1

100 GAL

PROPANE

P-2

250 GAL

PROPANE

A-22

55 GAL

TRANSFORMER

OIL

A-4

2,000 GAL

#2 DIESEL

A-8

75 GAL

#2 DIESEL

A-6

500 GAL

#2 DIESEL

A-7

500 GAL

GASOLINE

A-11 (ELEVATOR 2)

70 GAL

HYDRAULIC OIL

A-17 (ELEVATOR P9)

70 GAL

HYDRAULIC OIL

A-5

2,000 GAL

#2 DIESEL

A-10 (ELEVATOR 8)

40 GAL

HYDRAULIC OIL

A-12 (ELEVATOR 4)

40 GAL

HYDRAULIC OIL

A-19

75 GAL

#2 DIESEL

WATER/OIL SEPARATOR & WASH BAY

A-1, A-2 AND A-3

FILL PORT

A-20

(2) 55 GAL

NEW OIL

A-21

(2) 15 GAL

USED OIL

A-19

115 GAL

#2 DIESEL

FG-1

(2) 55 GAL

FOOD GREASE

A-16

1,010 GAL

#2 DIESEL

FG-2

(2) 55 GAL

FOOD GREASE

FALL RIVER

TO WATER

TANKS

WT2

500,000 GAL

TREATED WATER TANK

WT1

500,000 GAL

TREATED WATER TANK

TO VACAMPUS

LEGEND

ABOVE GROUND TANKS

STORAGE DRUMS

SPILL KITS

PORTABLE TANK

PROPANE TANK

WATER TOWER

FLOW ARROW

00 100' 200'

HORIZ. SCALE: 1"=200'

FIGURE 2

SITE INVENTORY OF PETROLEUM STORAGE

JOB NUMBER: 21-105

DATE: 5/26/2021

DRAWING:105-HSFIG02.dwg

SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN (SPCC)

HOT SPRINGS VA MEDICAL CENTER, HOT SPRINGS SOUTH DAKOTA

STORM

INLET

STORM

INLET

LOW POINT

IN GRASS

X X X X X X X X X

XX X X X X X X

X X X X X X X

X

X

X

X

X

X

X

X

XXXX

RI

VE

R

ST

RE

ET

E

NT

RA

NC

E

TO NATIONAL CEMETERY

OXYGEN TANK

31 14

A

B

C

TELE.

FUEL

STORAGE

TANKS

LOT

GRAND

STAIRCASE

C O

U R

T

C O

U R

T

PA

TI

O

CARWASH PAD

DOMICILIARY PARKING LOT

5 SPACES - EMP.

MAIN PARKING LOT

HOSPITAL

10 SPACES

PATIENT/VISITOR

BUILDING

DOWN

BLOW

DEAERATOR

PLANT

BOILER

FIFTH

STREET

PARKING

AMB. CARE

D

TR-17

115 GAL

MINERAL OIL (NON-PCB)

TR-18

184 GAL

MINERAL OIL (NON-PCB)

TR-43

140 GAL

MINERAL OIL (NON-PCB)

TR-10A

200 GAL

MINERAL OIL (NON-PCB)

TR-10B

200 GAL

MINERAL OIL (NON-PCB)

TR-23

140 GAL

MINERAL OIL (NON-PCB)

TR-24

140 GAL

MINERAL OIL (CONTAINS PCB)

TR-27

140 GAL

MINERAL OIL (CONTAINS PCB)

TR-64

140 GAL

MINERAL OIL (CONTAINS PCB)

TR-20

140 GAL

MINERAL OIL (NON-PCB)

TR-65

125 GAL

MINERAL OIL (NON-PCB)

TR-12XR

200 GAL

MINERAL OIL (NON-PCB)

TR-12A

200 GAL

MINERAL OIL (NON-PCB)

TR-12B

200 GAL

MINERAL OIL (NON-PCB)

TR-53

270 GAL

MINERAL OIL (NON-PCB)

TR-66

230 GAL

MINERAL OIL (NON-PCB)

STORM

INLET

FALL RIVER

TR-24

TR-23

TR-27

TR-64

TR-20

TR-65

TR-12XR

TR-12A

TR-12B

TR-53

TR-18

TR-17

TR-43

TR-10A

TR-10B

TR-66

LEGEND

TRANSFORMER

FLOW ARROW

00 100' 200'

HORIZ. SCALE: 1"=200'

FIGURE 3

SITE INVENTORY OF TRANSFORMERS

SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN (SPCC)

HOT SPRINGS VA MEDICAL CENTER, HOT SPRINGS SOUTH DAKOTA

JOB NUMBER: 21-105

DATE: 5/26/2021

DRAWING:105-HSFIG03.dwg

Hot Springs VA Medical Center Page 14 of 62

4.0 DISCHARGE POTENTIAL

4.1 Distance to Navigable Waters

The nearest navigable water is Fall River located approximately 0.1 miles northwest from the center of the facility. Projected spill pathways are shown on the site maps (Figure 1 , 2, & 3).

4.2 Discharge History

The facility has one recorded release that occurred on December 8, 1998. A release of 700 gallons of diesel fuel to the secondary containment occurred from the overfilling of a tank. The contained release was mitigated by recovering the fuel by pumping and the use of sorbent pads and clay.

4.3 Potential Discharge Volumes and Rates (40 CFR 112.7 (a)(3)(i & iii); 112.7 (b))

Table 4.1 and Table 4.2 show the facility’s oil storage inventory and summarizes the potential discharge volumes, rate, and projected flow directions in the event of vessel or equipment failure.

TANK ID

TANK

LOCATION

TANK TYPE

(AST/UST)

TANK

CONTENTS

TANK SIZE

(GAL.)

USE OF TANK

CONTENTS

TANK

CONSTRUCTION

DATE OF TANK

INSTALLATION/

LAST UPGRADE

TYPE OF SECONDARY

CONTAINMENT

DATE OF MOST

RECENT TANK

INTEGRITY

TESTING

LOCATION OF TANK

INTEGRITY TESTING

AND INSPECTION

REPORTS

TYPE OF TANK

MONITORING

1POTENTIAL FAILURE

EVENT(S)

DISCHARGE

DIRECTION

VOLUME

RELEASED (GAL.)

DISCHARGE RATE

(GPM)

A-1 Bldg. 18 AST #2 Diesel 39,590 Heating Steel 1993 Double-Walled Steel Tank w/Concrete Berm 08/31/10

Building 14, Engineering

Office

OMNTEC Monitoring

Equipment on the Tank

A-2 Bldg. 18 AST #2 Diesel 39,590 Heating Steel 1993 Double-Walled Steel Tank w/Concrete Berm 08/31/10

Building 14, Engineering

Office

OMNTEC Monitoring

Equipment on the Tank

A-3 Bldg. 18 AST #2 Diesel 39,590 Heating Steel 1993 Double-Walled Steel Tank w/Concrete Berm 08/31/10

Building 14, Engineering

Office

OMNTEC Monitoring

Equipment on the Tank

A-4 Bldg. 10 AST #2 Diesel 2,000 Generator Steel 1993 Double-Walled Steel Tank w/Concrete Berm 08/31/10

Building 14, Engineering

Office Visual Monitoring

~Complete (Full Tank)

~Partial (Full Tank)

~Pipe (Full Tank)

~Tank Loading

~Northwest

~Secondary Containment

~Southeast

~Southeast

~2,000

~0

~up to 2,000

~up to 4,000

~Instantaneous

~Seep to Instantaneous

~up to 5

~up to 400

A-5 Bldg. 12 AST #2 Diesel 2,000 Generator Steel 1997 Double-Walled Steel Tank 08/31/10 Building 14, Engineering

Office Visual Monitoring

~Complete (Full Tank)

~Partial (Full Tank)

~Pipe (Full Tank)

~Tank Loading

~Southeast

~Secondary Containment

~Southeast

~Southeast

~2,000

~0

~up to 2,000

~up to 4,000

~Instantaneous

~Seep to Instantaneous

~up to 5

~up to 400

A-6 Bldg. 30 AST #2 Diesel 500 Vehicles Steel 1997 Double-Walled Steel Tank 08/31/10 Building 14, Engineering

Office Visual Monitoring

A-7 Bldg. 30 AST Gasoline 500 Vehicles Steel 1997 Double-Walled Steel Tank 08/31/10 Building 14, Engineering

Office Visual Monitoring

A-8 Bldg. 10 AST (Day Tank) #2 Diesel 75 Generator Steel 1998 Inside Building 08/31/10 Building 14, Engineering

Office Visual Monitoring

A-9 Bldg. 12 AST (Day Tank) #2 Diesel 75 Generator Steel 2001 Inside Building 08/31/10 Building 14, Engineering

Office Visual Monitoring

A-10 Bldg. 11, Room

AST Hydraulic Oil 40 Elevator 8 Steel 1995 Inside Building 08/31/10

Building 14, Engineering

Office Visual Monitoring

A-11 *Bldg. 2, Room

SB-1

AST Hydraulic Oil 70 Elevator 2 Steel 2005 Inside Building 08/31/10

Building 14, Engineering

Office Visual Monitoring

A-12 Bldg. 12, Room

DB19

AST Hydraulic Oil 40 Elevator 4 Steel 2004 Inside Building 08/31/10

Building 14, Engineering

Office Visual Monitoring

A-13 *Bldg. 18 AST #2 Diesel 500 Heating Steel 1993 Double-Walled Steel Tank;

Inside Building 08/31/10

Building 14, Engineering

Office Visual Monitoring

~Complete (Full Tank)

~Partial (Full Tank)

~Inside Building

~Inside Building

~500

~2 to 500

~Instantaneous

~Seep to Instantaneous

A-14 *Bldg. 18 AST Drum (2) Cylinder Oil 55 (110) Steam Pump Oil Steel N/A Poly Dolly or Spill Deck; Inside

Building

Building 14, Engineering

Office Visual Monitoring

A-15 *Bldg. 18 AST Drum (2) Compressor Oil 55 (110) Air Compressor Oil Steel N/A Poly Dolly or Spill Deck; Inside

Building

Building 14, Engineering

Office Visual Monitoring

A-16 Bldg. 66 AST #2 Diesel 1,010 Heating Steel 2015 Double-Walled Steel Tank Building 14, Engineering

Office Visual Monitoring

~Complete (Full Tank)

~Partial (Full Tank)

~Pipe (Full Tank)

~Tank Loading

~Southwest

~Secondary Containment

~Southwest

~Southwest

~1,010

~0

~up to 1,010

~up to 4,000

~Instantaneous

~Seep to Instantaneous

~up to 5

~up to 400

A-17 Bldg. 4, Room

1-1 AST Hydraulic Oil 70 Elevator P9 Steel Inside Building

Building 14, Engineering

Office Visual Monitoring

~Complete (Full Tank)

~Partial (Full Tank)

~Inside Building

~Inside Building

~70

~1 to 70

~Instantaneous

~Seep to Instantaneous

A-18 Bldg. 18 AST (Day Tank) #2 Diesel 75 Generator Steel Inside Building Building 14, Engineering

Office Visual Monitoring

~Complete (Full Tank)

~Partial (Full Tank)

~Inside Building

~Inside Building

~75

~1 to 75

~Instantaneous

~Seep to Instantaneous

A-19 Bldg. 17 AST (Portable

Tank) #2 Diesel 115 Vehicles Steel 2010 Double-Walled Steel Tank

Building 14, Engineering

Office Visual Monitoring

~Complete (Full Tank)

~Partial (Full Tank)

~Depends on where truck is parked

~115

~1 to 115

~Instantaneous

~Seep to Instantaneous

A-20 *Bldg. 172 AST Drum (2) Diesel Oil and

Gas Oil 55 (110) Vehicles Steel N/A Spill Deck Inside Building

Building 14, Engineering

Office Visual Monitoring

~Complete (Full Drum)

~Partial (Full Drum)

~Secondary Containment

~Secondary Containment

~110

~1 to 110

~Instantaneous

~Seep to Instantaneous

A-21 *Bldg. 172 AST Drum Used Oil 15(30) Oil Recycling Steel N/A Spill Deck Inside Building Building 14, Engineering

Office Visual Monitoring

~Complete (Full Drum)

~Partial (Full Drum)

~Secondary Containment

~Secondary Containment

~15

~1 to 15

~Instantaneous

~Seep to Instantaneous

A-22 Bldg. 35 AST Drum Transformer Oil 55 New Transformer Oil Steel N/A Spill Deck Inside Building Building 14, Engineering

Office Visual Monitoring

~Complete (Full Drum)

~Partial (Full Drum)

~Secondary Containment

~Secondary Containment

~55

~1 to 55

~Instantaneous

~Seep to Instantaneous

P-1 Bldg. 18 AST Propane 100 Ignitor Steel 1975 None 11/13/09 Building 14, Engineering

Office Visual Monitoring N/A N/A N/A N/A

P-2 Bldg. 12 AST Propane 250 Bunsen Burner

(Dental) Steel 1989/2009 None 11/13/09

Building 14, Engineering

Office Visual Monitoring N/A N/A N/A N/A

WT-1 Water Towers AST Water 500,000 Drinking Steel 2009 None 10/21/19 Building 14, Engineering

Office Visual Monitoring N/A N/A N/A N/A

WT-2 Water Towers AST Water 460,000 Drinking Steel 1957 None 10/21/19 Building 14, Engineering

Office Visual Monitoring N/A N/A N/A N/A

FG-1 Bldg. 53 Drums (2) Used Food

Grease 55 (110) Used Food Grease Steel N/A

Roll-top Containment Unit w/Spill Deck N/A

Building 14, Engineering

Office Visual Monitoring

~Complete (Full Drum)

~Partial (Full Drum)

~Secondary Containment

~Secondary Containment

~55 to 110

~1 to 110

~Instantaneous

~Seep to Instantaneous

FG-2 *Bldg. 2 Drums (2) Used Food

Grease 55 (110) Used Food Grease Steel N/A

Roll-top Containment Unit w/Spill Deck N/A

Building 14, Engineering

Office Visual Monitoring

~Complete (Full Drum)

~Partial (Full Drum)

~Secondary Containment

~Secondary Containment

~55 to 110

~1 to 110

~Instantaneous

~Seep to Instantaneous

* - Buildings with SPILL CLEAN-UP KITS

1 - Complete failure is the result of a catastrophic event that cause the entire tank and any secondary containment to be compromised. A partial failure is the result of only the tank being compromised and contained in the secondary containment.

2 - Building that houses the on-site wash bay with an oil/water separator (Building 17)

~Complete (Full Tank)

~Partial (Full Tank)

~Inside Building

~Inside Building

~40 to 70

~1 to 40 or 70

~Instantaneous

~Seep to Instantaneous

~Complete (Full Drum)

~Partial (Full Drums)

~Inside Building

~Inside Building

~55 to 440

~1 to 55

~Instantaneous

~Seep to Instantaneous

TABLE 4.1 OIL STORAGE INVENTORY OF SPCC ASTs & CONTAINERS (HOT SPRINGS)

~Complete (Full Tank)

~Partial (Full Tank)

~Pipe (Full Tank)

~Tank Loading

~Northwest

~Secondary Containment

~Underground

~Northwest

~39,590

~0

~up to 39,590

~up to 8,000

~Instantaneous

~Seep to Instantaneous

~up to 5

~up to 400

~Complete (Full Tank)

~Partial (Full Tank)

~Tank Loading

~Northeast

~Northeast

~Northeast

~500

~1 to 500

~up to 4,000

~Instantaneous

~Seep to Instantaneous

~up to 400

~Complete (Full Tank)

~Partial (Full Tank)

~Inside Building

~Inside Building

~75

~1 to 75

~Instantaneous

~Seep to Instantaneous

TABLE 4.1 OIL STORAGE INVENTORY OF SPCC ASTs CONTAINERS

1 TR-10A 500 N OF BLDG 10 216

MINERAL OIL

(NON-PCB)

Complete

Radial - Surrounding

Ground

216 STEEL

INSTALLED IN

2 TR-10B 500 N OF BLDG 10 216

MINERAL OIL

(NON-PCB)

Complete

Radial - Surrounding

Ground

216 STEEL

INSTALLED IN

3 TR-12A 500 S OF BLDG 12 216

MINERAL OIL

(NON-PCB)

Complete

Radial - Surrounding

Ground

216 STEEL

INSTALLED IN

4 TR-12B 500 S OF BLDG 12 216

MINERAL OIL

(NON-PCB)

Complete

Radial - Surrounding

Ground

216 STEEL

INSTALLED IN

5 TR-12XR 500 S OF BLDG 12 174

MINERAL OIL

(NON-PCB)

Complete

Radial - Surrounding

Ground

174 STEEL

INSTALLED IN

6 TR-17 75 NW OF BLDG 17 125

MINERAL OIL

(NON-PCB)

Complete

Radial - Surrounding

Ground

125 STEEL

INSTALLED IN

7 TR-18 225 SE SIDE OF BLDG 18 140

MINERAL OIL

(NON-PCB)

Complete

Radial - Surrounding

Ground

140 STEEL

INSTALLED IN

8 TR-20 75 NW OF BLDG 20 50

MINERAL OIL

(NON-PCB)

Complete

Radial - Surrounding

Ground

50 STEEL

INSTALLED IN

9 TR-23 37.5 SW OF BLDG 23 50

MINERAL OIL

(NON-PCB)

Complete

Radial - Surrounding

Ground

50 STEEL

INSTALLED IN

10 TR-24 50 BETWEEN BLDGS 42 & 44 100

MINERAL OIL

(CONTAINS PCBS)

Complete

Radial - Surrounding

Ground

100 STEEL

INSTALLED IN

11 TR-27 37.5 NW CORNER OF BLDG 27 100

MINERAL OIL

(CONTAINS PCBS)

Complete

Radial - Surrounding

Ground

100 STEEL

INSTALLED IN

12 TR-43 150 N OF BLDG 43 113

MINERAL OIL

(NON-PCB)

Complete

Radial - Surrounding

Ground

113 STEEL

INSTALLED IN

13 TR-53 500 N OF BLDG 53 216

MINERAL OIL

(NON-PCB)

Complete

Radial - Surrounding

Ground

216 STEEL

INSTALLED IN

14 TR-64 37.5 NW CORNER OF BLDG 64 50

MINERAL OIL

(CONTAINS PCBS)

Complete

Radial - Surrounding

Ground

50 STEEL

INSTALLED IN

15 TR-65 150 S OF BLDG 65 116

MINERAL OIL

(NON-PCB)

Complete

Radial - Surrounding

Ground

116 STEEL

INSTALLED IN

16 TR-66 225 NE CORNER OF BLDG 66 230

MINERAL OIL

(NON-PCB)

Complete

Radial - Surrounding

Ground

230 STEEL

INSTALLED IN

126,255 Total Volume of SPCC ASTs & Containers (In Gallons): 126,475

220 Total Volume of Transformers (In Gallons): 2,328

126,475 GRAND TOTAL (IN GALLONS): 128,803

TABLE 4.2 INVENTORY OF TRANSFORMERS (HOT SPRINGS)

LOCATION CONTENT* COMMENTS

TOTAL OIL CAPACITY (IN GALLONS):

POTENTIAL FAILURE

EVENT**

VOLUME RELEASED

(GAL.)

TRANSFORMER

NUMBER

ITEM

Rating

(KV)

CAPACITY

(GAL.)

FLOW

DIRECTION ***

CONSTRUCTON

* - If the transformer does not contain the wording "NON-PCB" (or similar language), then it is assumed to contain PCBs.

AST Total Volume (In Gallons):

Food Grease (FG) Total Volume (In Gallons):

TOTAL (IN GALLONS):

*** - For all potential failures the worst case (complete failure) was assumed. This would result in an instantaneous discharge rate. See Figure 3 for overall flow paths.

** - Complete failure is the result of a catostrophic event that cause the entire tank and any secondary containment to be compromised.

Table 4.2 INVENTORY OF TRANSFORMERS

Hot Springs VA Medical Center Page 17 of 62

4.4 Containment and Diversionary Structures (40 CFR 112.7 (c))

• Each aboveground storage tank is contained within a secondary containment structure or within a building that provides secondary containment. The secondary containment areas for Tanks A-1 through A-4 are constructed of concrete. The volume of the containment area for Tanks A-1 through A-3 is approximately 60,000 gallons and the containment volume for Tank A-4 is approximately 2,120 gallons. (It is noted that this concrete secondary containment structure is not adequate to contain 110 percent of the 2,000 gallons stored in tank A-4. This is due to the tank supports recessed into the containment structure. However, it is noted that this tank is double walled as per facility personnel and therefore complies with the secondary containment requirements and the concrete structure provides containment for loading operations discussed in section 4.9.) The secondary containment for Tank A-5 consists of the double-wall tank construction that is equal to the volume of that tank. Secondary containment for the hydraulic reservoir tanks and generator day tanks consists of interior concrete floors and walls. It is highly unlikely that a spill from these tanks would migrate beyond the interior portions of the buildings.

• Surface drainage at the facility provides opportunity to contain surface spills with diking methods (earth berms, weirs, booms, etc.). Prompt emergency action response to all surface spills should contain any release (on-site) before leaving the property and reaching the nearest navigable water.

• The Hot Springs VA Medical Center has a 24 hour per day, 7 days per week staffed fire station. These personnel are first responders for containment and control of a release.

4.5 Impracticality of Secondary Containment (40 CFR 112.7 (d))

All areas of the facility where petroleum products are handled or stored are equipped with appropriate containment and/or diversionary structures or equipment and qualified VA personnel to prevent discharged petroleum products from reaching navigable waters, as required by 40 CFR 112.7 (c). Furthermore, in the 2002 rule clarification it is not required that facilities demonstrate impracticality for containment of spills from oil-filled operational

Hot Springs VA Medical Center Page 18 of 62 equipment, including transformers. Instead, the facility must be able to respond to a release of oil from this equipment with spill response equipment and have an adequate operation, maintenance, and inspection program in place to prevent releases. Spill response and absorbent materials will be used as the primary means of containment in these cases.

4.6 Inspections, Tests and Records (40 CFR 112.7 (e))

Although inspections may be performed more often, periodic inspections must be performed on all oil storage containers at the minimum frequencies recommended by industry standards.

The Authorized Facility Representative or designee is responsible for conducting the inspections and completing and signing the appropriate forms. Section 5.7 provides further details regarding integrity assessments of the containers, which will be conducted according to industry standards for the facility’s containers. Example inspection forms are in Appendix C to assist with the inspection requirements. Records of required inspections must be retained for at least 3 years at the facility.

All ASTs, drums, and mobile/portable oil storage containers with capacities less than or equal to 5,000 gallons require periodic (monthly and annually) routine visual inspections by authorized personnel. No periodic non-routine inspections by a Steel Tank Institute (STI) inspector are required for these containers unless the monthly and annual inspections are not adequately documented. Any tank over 5,000 gallons also requires periodic (monthly and annually) routine visual inspections by authorized personnel plus a formal non-routine external inspection by an STI-certified inspector every 20 years. For the three 39,590-gallon diesel

ASTs, this test/inspection is due in 2030.

Monthly and annual routine visual inspections consist of a walkthrough of the petroleum storage sites by facility personnel responsible for the operation and maintenance of the subject equipment. These inspections check for damage or leakage, stained or discolored soils, or elevated fuel odors that could indicate a leak. The monthly example inspection checklists are provided in Appendix C. The monthly inspection records are signed and dated by the inspector and maintained in the Engineering Office for not less than three years.

Hot Springs VA Medical Center Page 19 of 62

Non-routine inspections and integrity testing must be performed by qualified inspectors (e.g., authorized American Petroleum Institute (API) or STI certified inspectors). This testing and inspection must be performed in accordance with acceptable industry standards and/or regulatory requirements. It must also be signed and certified by the authorized inspector and maintained in the Engineering Office for 5 years after the operational life of the storage tank system or lifetime of the equipment.

4.7 Personnel Training (40 CFR 112.7(f)(1-3))

Facility personnel that are responsible for the operation and maintenance of the petroleum storage systems have been instructed in the release response procedures and pollution control laws and regulations. Refresher training will be conducted annually and documented on a training log/record in Appendix D. Periodic briefings are conducted by the Facilities

Management Unit for operating personnel to ensure adequate understanding of the SPCC plan. These briefings discuss any past discharge events or failures and any new release prevention measures or response measures.

4.8 Site Security (40 CFR 112.7 (g))

The Hot Springs VA Medical Center is staffed 7 days per week, 24-hours per day with facility operators and VA Police.

Flow and Drain Valves Secured:

Ensure that the tank and secondary containment drainage valves have adequate security measures in place, so they remain in the closed position when not in use.

Starter Controls and Oil Pumps Secured:

Fuel dispensing at the facility is locked allowing only authorized personnel to dispense fuel.

Pipeline Loading/Unloading Connections Secured:

All piping is in service; however, when facility piping is taken out of service or placed in standby for an extended period of time, the owner/operator will comply with this requirement.

Hot Springs VA Medical Center Page 20 of 62

Lighting Adequate to Detect and Deter Spills:

Lighting within the buildings is adequate to detect a discharge from oil containers. Outside the buildings, security lighting is provided. Lighting at the facility is such that a spill may be observed during hours of darkness, both by operating personnel and non-operating personnel (general public, local police, etc.), and spills are deterred from occurring through acts of vandalism.

4.9 Loading/Unloading Operations (40 CFR 112.7(h)(1-3))

Loading, unloading, and interfacility transfer of oil products occur at this facility. New fuel/oil is delivered to the facility by tanker truck on an as-needed basis. To fill the tanks, the tanker truck is parked and chocked next to the tanks and/or tank fill ports. Before filling the tanks, the truck should be closely inspected by the delivery driver for discharges at the lowermost drain and all outlets of the tanker. After the inspection, the tanker’s discharge hose is attached to the inlet valve of the tank. The valve is normally in a closed position. The Authorized Facility

Representative or designated personnel must be notified and be present to supervise the loading procedure. Other virgin oil products are delivered in 55-gallon drums. Diesel fuels for the emergency generators are delivered on an as-needed basis. Used oil is stored in a 15-gallon drum at building 17.

The facility does not have any “loading/unloading racks” as defined by the U.S. EPA standard and is not subject to the requirements of 40 CFR 112.7(c) and 40 CFR 112.8(b). Rule 40 CFR

112(h) does not apply to transfer of fuel to shop-fabricated end-use containers such as small

ASTs, nor does it apply to fuel transfer into non-AST systems by commercial fuel transporters.

Oil throughput associated with these systems and operations is considered low. For these operations, spill risk potential is managed in accordance with standard operating procedures described throughout this SPCC Plan.

The potential for discharges during tank truck loading and unloading operations is a concern at this facility. The following measures are implemented to prevent oil discharges during tank truck unloading operations.

Hot Springs VA Medical Center Page 21 of 62

4.9.1 Loading/Unloading Procedures (40 CFR 112.7(h)(2) and (3))

All suppliers must meet the minimum requirements and regulations for tank truck loading/unloading established by the U.S. Department of Transportation. Vendors are required to understand the site layout, the protocol for entering the facility and loading or unloading product, and how to contact facility personnel. The Authorized Facility

Representative, or his/her designee, needs to supervise oil deliveries for all new suppliers, and periodically observe deliveries for existing, approved suppliers.

Prior to filling a tank, the available storage capacity is verified. The delivery driver is required to remain at the point of delivery and man the delivery operation the entire time fuel is being transferred to the storage container. A Loading/Unloading Procedure list is provided in

Appendix E and an example inspection checklist is provided in Appendix C.

4.10 Conformance with Other Applicable Requirements (40 CFR 112.7(j))

4.10.1 State of South Dakota Requirements

The State of South Dakota does not have any additional requirements for spill prevention, control, and countermeasures. However, the State does have additional reporting, monitoring, O&M, compliance testing, inspections, and recordkeeping requirements applicable to facilities with USTs and/or ASTs.

• Each UST/AST owner or operator shall report any spill or overfill of a regulated substance that exceeds its reportable quantity under CERCLA 1980 (40 C.F.R. 302, July

1, 1990) or threatens the waters of the state and any spill or overfill of petroleum that exceeds 25 gallons or causes a sheen on surface water to the department immediately.

• UST owners or operators shall contain and clean up any spill or overfill of petroleum of

25 gallons or less immediately. If the cleanup is not accomplished within 24 hours, the department or the Division of Emergency Management and applicable local agencies must be notified.

• Each UST owner or operator must report suspected releases from USTs. The owner or operator shall report any of the following conditions to the department within 72 hours:

Hot Springs VA Medical Center Page 22 of 62

1. Test, sampling, or monitoring results from a release detection method that indicate a release may have occurred; and

2. Unusual operating conditions, such as the erratic behavior of product dispensing equipment, the sudden loss of product from the UST system, or an unexplained presence of water in the tank.

• Automatic Tank Gauge (ATG) Monitoring DENR_UST_Owners_Operators_Guide_Final_Version_July_2019.pdf (sd.gov):

An automatic tank gauging (ATG) system consists of a probe permanently installed in an UST and wired to a monitor to provide information on product level and temperature. ATG systems automatically calculate changes in product volume that can indicate a leaking UST. If an ATG system detects a leak or unusual conditions, a visual and audible alarm will trigger. Never ignore or silence ATG system alarms without investigation. It is the responsibility of the owner or operator to be knowledgeable and appropriately responsive to the indications of triggered alarms. If an alarm indicates a suspected or confirmed release, the DANR must be notified.

Operation and Maintenance:

o The UST must contain enough product to ensure the validity and accuracy of ATG system test results.

o Most ATG systems require a minimum amount of product in the UST to properly perform a leak detection test. To determine the minimum amount of product required, refer to the ATG system operator manual or third-party certification.

Compliance Testing:

o An ATG system, as a primary form of leak detection, must test for a 0.2 gallon per hour leak and produce a passing record for each UST in the system every 30 days.

o By October 13, 2021, all ATG systems must be tested annually for proper functionality by a qualified service contractor. At a minimum, the test must include alarm operability, system configuration verification, battery backup, and inspections of probes and sensors to ensure floats move freely, shaft is https://denr.sd.gov/des/gw/tanks/DENR_UST_Owners_Operators_Guide_Final_Version_July_2019.pdf

Hot Springs VA Medical Center Page 23 of 62 not damaged, cables are free of kinks and breaks, and controller communication is functioning properly.

Compliance Inspections and Recordkeeping:

o Owners or operators must provide the most recent 12 months of passing

ATG records for each UST in the system to the DANR for review.

o Owners or operators must provide the most recent annual ATG system functionality test to the DANR for review during compliance inspections.

o Owners or operators must retain the most recent 12 months of passing ATG records for each UST in the system.

o Owners or operators must retain the most recent ATG system functionality test results for 12 months, or until the next functionality test shows satisfactory operation of the ATG system.

• Interstitial Monitoring

DENR_UST_Owners_Operators_Guide_Final_Version_July_2019.pdf (sd.gov):

Secondary containment with interstitial monitoring is a leak detection method that detects leaks in the space between the primary wall and a secondary barrier (interstitial space) of a UST. Interstitial monitoring may be used as a release detection method provided the interstitial space is monitored manually or automatically for evidence of a leak at least every 30 days and the secondary barrier is designed, constructed, and installed to ensure detection of any release from the UST system so corrective action can be initiated. The DANR must be notified if a leak is suspected or confirmed.

Operation and Maintenance:

o Interstitial monitoring liquid sensors will alarm if water accumulates within the interstitial space. Any water detected in the interstice must be removed and properly disposed.

Compliance Testing:

o The interstitial monitoring system must be tested or inspected for a leak every 30 days.

o Interstitial monitoring testing or inspection results must be documented every 30 days.

https://denr.sd.gov/des/gw/tanks/DENR_UST_Owners_Operators_Guide_Final_Version_July_2019.pdf

Hot Springs VA Medical Center Page 24 of 62 o The interstitial monitoring liquid sensor for each UST in the system must be annually tested for proper functionality by a qualified service contractor.

Compliance Inspections and Recordkeeping:

o Owners or operators must provide the most recent 12 months of interstitial monitoring records for each UST in the system to the DANR during compliance inspections.

o Owners or operators must provide the most recent interstitial monitoring liquid sensor test results for each UST in the system to the DANR during compliance inspections.

o Owners or operators must retain the most recent 12 months of interstitial monitoring records for each UST in the system.

o Owners or operators must retain the most recent interstitial monitoring liquid sensor tests for each UST in the system for 12 months, or until the next functionality test shows satisfactory operation of the sensor.

4.10.2 Industry Standards

Discussions regarding conformance with the requirements of API, NFPA, STI standards, and other industry standards are integrated where applicable throughout this SPCC Plan.

Additionally, NFPA 30 Flammable and Combustible Liquids Code specifies in Section

21.7.2.1, Identification for Emergency Responders, that a sign or marking that meets the requirements of NFPA 704 or another approved system be applied to storage tanks containing liquids. Section 21.7.2.2 of NFPA 30-2012 requires that unsupervised, isolated

ASTs shall be secured and marked to identify the fire hazards of the tank and the tank’s…