attach G- Cost-Free Design Analysis.pdf

Replace UST and Leak Detection 06-01-24

VA Project #437-24-101

00 01 10-1

Table of Contents

DEPARTMENT OF VETERANS AFFAIRS

VHA MASTER SPECIFICATIONS

TABLE OF CONTENTS

Section 00 01 10

SECTION NO DIVISION AND SECTION TITLES DATE

DIVISION 00 - SPECIAL SECTIONS

00 01 15 List of Drawing Sheets 05-20

DIVISION 01 - GENERAL REQUIREMENTS

01 00 00 General Requirements 11-21

01 33 23 Shop Drawings, Product Data, and Samples 11-23

01 35 26 Safety Requirements for Major Projects 05-24

01 45 29 Testing Laboratory Services 11-18

01 57 19 Temporary Environmental Controls 01-21

01 74 19 Construction Waste Management 04-22

01 81 13 Sustainable Construction Requirements 10-17

01 91 00 General Commissioning Requirements 04-22

DIVISION 02 – EXISTING CONDITIONS

02 41 00 Demolition 08-17

02 65 00 Underground Storage Tank Removal 01-21

DIVISION 03 - CONCRETE

03 30 00 Cast-in-Place Concrete 01-21

DIVISION 07 - THERMAL AND MOISTURE PROTECTION

07 84 00 Firestopping 01-21

07 92 00 Joint Sealants 04-22

DIVISION 23 – HEATING, VENTILATING, AND AIR

CONDITIONING (HVAC)

23 05 10 Common Work Results for Boiler Plant and Steam

Generation

06-24

23 08 00 Commissioning of HVAC Systems 03-23

23 10 00 Facility Fuel Systems 04-20

DIVISION 26 – ELECTRICAL

26 05 11 Requirements for Electrical Installations 11-22

26 05 19 Low-Voltage Electrical Power Conductors and Cables 11-22

26 05 26 Grounding and Bonding for Electrical Systems 11-22

26 05 33 Raceway and Boxes for Electrical Systems 11-22

26 05 41 Underground Electrical Construction 11-22

26 08 00 Commissioning of Electrical Systems 11-22

Replace UST and Leak Detection 06-01-24

VA Project #437-24-101

00 01 10-2

Table of Contents

SECTION NO DIVISION AND SECTION TITLES DATE

26 27 26 Wiring Devices 11-22

26 42 00 Cathodic Protection 11-22

DIVISION 27 – COMMUNICATIONS

27 05 11 Requirements for Communications Installations 09-19

27 05 26 Grounding and Bonding for Communications Systems 06-15

27 05 33 Raceways and Boxes for Communications Systems 10-18

27 08 00 Commissioning of Communications Systems 11-16

27 10 00 Control, Communication and Signal Wiring 06-15

DIVISION 31 – EARTHWORK

31 20 11 Earthwork (Short Form) 10-12

DIVISION 32 – EXTERIOR IMPROVEMENTS

32 05 23 Cement and Concrete for Exterior Improvements 08-16

32 12 16 Asphalt Paving 09-15

32 17 23 Pavement Markings 08-16

Attachments:

• Environmental Assessment

- Remedial Action Plan

- Contamination Area Plan & Profile

Page i

TABLE OF CONTENTS

1.0 Introduction

2.0 Purpose and Need

3.0 Project Area

3.1 Physical Setting

3.2 Specific UST Locations

3.3 Environmental Conditions

4.0 Timing of Implementation

4.1 Design and Pre-Construction Phase

4.2 Construction Phase

4.3 Post-Construction Monitoring

5.0 Alternatives Analysis

5.1 Alternative 1: Proposed Action – Remove and Replace USTs with Enhanced

Containment and Leak Detection Systems

5.1.1 Description:

5.1.2 Environmental and Operational Benefits:

5.1.3 Environmental Considerations:

5.2 Alternative 2: Repair and Retrofit Existing USTs

5.2.1 Description:

5.2.2 Environmental and Operational Drawbacks:

5.3 Alternative 3: No Action

5.3.1 Description:

5.3.2 Environmental and Operational Consequences:

5.4 Summary of Alternatives

6.0 Affected Environment and Environmental Impacts – Hazardous Materials

6.1 Existing Conditions – Hazardous Materials

6.1.1 Subsurface Soil and Groundwater

6.1.2 Historical Impacts and Mitigation

6.1.3 Receptors and Exposure Pathways

Page ii

6.2 Environmental Impacts – Proposed Action

6.2.1 Soil and Groundwater Protection

6.2.2 Human Health and Worker Safety

6.2.3 Hazardous Materials Handling and Waste Management

6.3 Environmental Impacts – Alternatives

6.3.1 No Action Alternative

6.3.2 Retrofit Alternative

6.3.3 Proposed Action – Tank Replacement Alternative

6.4 Cumulative Impacts

7.0 Mitigation Measures

7.1 Soil Contamination Mitigation

7.2 Groundwater and Surface Water Protection

7.3 Worker and Public Health Protection

7.4 Spill Prevention and Containment

7.5 UST Decommissioning and Replacement Controls

7.6 Coordination and Documentation

8.0 Conclusion and Summary

8.1 Summary of Findings

8.2 Conclusion

9.0 References

ATTACHMENTS

Attachment 1 - Remedial Action Plan

Attachment 2 - Drawing

1.0 INTRODUCTION

This Resource-Specific Environmental Assessment (RSEA) has been prepared in accordance with the National Environmental Policy Act (NEPA) of 1969, as amended (42 U.S.C. §§ 4321–4370h), and follows the Department of Veterans Affairs (VA) NEPA Interim Guidance for Projects (PG-18-17). The RSEA evaluates potential environmental impacts associated with the removal and replacement of underground storage tanks (USTs) and associated leak detection systems at the Fargo VA Health Care System, located at 2101 Elm Street in Fargo, North Dakota (VA Facility ID #5857).

The proposed action involves the decommissioning and removal of USTs 1, 2, 3, 4, and 8, and the complete installation of new double-wall fiberglass reinforced plastic (FRP) USTs and upgraded leak detection systems as part of Phase 2 of the ongoing infrastructure upgrade. These activities are being undertaken to improve operational safety and reduce the risk of petroleum release to surrounding soils and groundwater.

Although previous contamination in the vicinity of USTs 2 and 3 was reportedly remediated in 1992, the presence of petroleum hydrocarbons (TPH-DRO) in the upper 2 feet of soil at boring B-06 during a 2025 subsurface investigation warrants further environmental review. The presence of shallow petroleum-impacted soils and the proximity of the Red River (~375 feet east of the site) are considered in evaluating potential hazardous materials impacts, particularly with respect to soil and groundwater pathways, human exposure during construction, and regulatory compliance.

This RSEA focuses specifically on hazardous materials-related environmental conditions, including petroleum hydrocarbons in soil and groundwater, potential contact with utilities, exposure risks to construction personnel, and mitigation strategies. This assessment supports federal decision-making under NEPA and provides documentation necessary to determine whether the proposed action will have significant impacts on human health or the environment or whether a Finding of No Significant Impact (FONSI) is appropriate.

This RSEA is intentionally resource-specific to hazardous materials because the primary environmental concern associated with the proposed project is the presence, removal, and future prevention of petroleum hydrocarbon contamination linked to the Fargo VA Health Care System’s underground storage tank (UST) systems. The scope of work focuses exclusively on UST decommissioning, soil remediation, and installation of modern fuel storage infrastructure, with no expansion of facility footprint, change in land use, or alteration of site operations beyond the fuel system upgrades. Environmental investigation identified contamination only in shallow soils adjacent to UST 2 (boring B-06), and no groundwater or surface water impacts were observed.

Additionally, the work occurs entirely within previously developed and disturbed areas, eliminating the potential for impacts to biological resources, wetlands, cultural or historic properties, threatened or endangered species, air quality (beyond minor, temporary construction emissions), noise (beyond temporary equipment operation), or socioeconomics. Because the project does not trigger impacts to these other resource categories and is confined to localized soil disturbance related to hazardous materials management, further analysis of other environmental resources is not warranted within the context of this RSEA.

In accordance with VA NEPA guidance, this RSEA includes an evaluation of reasonable alternatives, including a No Action alternative, and integrates findings from the Site Assessment Report prepared by American Engineering Testing, Inc. (April 2025) in support of the Statement of Work (SOW) for Project #437-24-101.

2.0 PURPOSE AND NEED

The purpose of the proposed action is to ensure the continued safe operation and environmental compliance of the Fargo VA Health Care System’s fuel storage and distribution infrastructure by replacing aging underground storage tanks (USTs) and associated leak detection systems. This action is necessary to protect human health and the environment from potential hazardous materials releases, maintain compliance with federal and state regulatory requirements, and support critical backup power and heating systems vital to the Fargo VA campus.

The existing UST systems, including tanks 1, 2, 3, 4, and 8, are nearing or have exceeded their service life and were installed using earlier-generation materials and monitoring technologies. These tanks store diesel and fuel oil critical to the facility’s boiler plant and emergency generator systems.

Current system components lack tertiary containment and feature outdated leak detection technologies, increasing the risk of undetected fuel releases that could impact subsurface soils, groundwater, and potentially the nearby Red River, located approximately 375 feet east of the project site.

The need for the project is further underscored by findings from the 2025 Site Assessment Report conducted by American Engineering Testing (AET), which identified residual petroleum hydrocarbon contamination (TPH-DRO at 1,120 mg/kg) in shallow soils (0–2 feet below grade) at boring B-06, near UST 2. While groundwater was not impacted in any of the borings and the surface is currently capped by pavement, the contamination presents a potential exposure pathway to construction workers during excavation and tank removal activities. Moreover, due to subsurface utility conflicts, full characterization of soils adjacent to USTs 1–3 could not be completed, creating additional uncertainty that must be managed through preemptive removal planning and field monitoring during construction.

The proposed action directly supports the VA’s commitment to managing its facilities in a manner that protects human health and the environment while maintaining operational reliability. Replacing the USTs with new double-wall FRP tanks equipped with tertiary containment and modern, interconnected leak detection systems will:

• Minimize the risk of future hazardous materials releases into soil and groundwater;

• Ensure compliance with federal (40 CFR Part 280), state (NDDEQ UST Program), and local environmental regulations;

• Provide real-time system monitoring and integration with the campus-wide Building Automation System (BAS);

• Address known areas of residual soil contamination and reduce risk to construction personnel and the public;

• Support continuity of operations for critical medical infrastructure reliant on uninterrupted fuel supply.

Without implementation of the proposed project, the VA would face increasing maintenance costs, the risk of regulatory noncompliance, potential exposure to liability for environmental contamination, and increased vulnerability to service disruptions in the event of UST system failure.

3.0 PROJECT AREA

The project area is located at the Fargo VA Health Care System, situated at 2101 Elm Street North, Fargo, North Dakota 58102. The campus is registered with the North Dakota Department of Environmental Quality (NDDEQ) under Facility ID #5857. The site lies in a developed urban area in Cass County and occupies a predominantly paved campus with buildings, parking areas, and utility infrastructure. The proposed project is concentrated in several key locations across the campus where underground storage tanks (USTs) and their associated components are installed.

3.1 PHYSICAL SETTING

The project site is positioned approximately 375 feet west of the Red River, which forms the eastern natural boundary of the greater Fargo area. According to the U.S. Geological Survey (USGS) topographic map, the site elevation is approximately 906 feet above mean sea level, and the surrounding terrain slopes gently to the east-southeast toward the river. Soils at the site consist of interbedded clay, silt, sand, and gravel, with groundwater encountered at depths ranging from 10 to 16 feet below grade, consistent with the underlying Oahe Formation, a fluvial deposit system of varying permeability.

3.2 SPECIFIC UST LOCATIONS

The USTs targeted for removal and replacement are located in three discrete areas on the Fargo VA campus:

• USTs 1, 2, and 3 are located in a parking area east of the Boiler Plant (Building 10) and west of the Warehouse (Building 50). This location is within a highly developed and trafficked zone, requiring coordination with existing utilities and traffic-rated surface covers for reinstatement.

• UST 4 is situated south of the Boiler Plant, near the internal roadway between the Boiler Plant and the Chiller Plant. The surrounding area includes subsurface utilities, concrete pads, and limited green space.

• UST 8 is buried just outside the generator room at Building 1 (Room BE-98), on a sloped grass-covered hillside above the Canteen Patio. This area is also scheduled for upcoming construction under VA projects 437-21-150 and 437-21-210, requiring careful integration of work scopes and physical site coordination.

Each tank basin is connected to critical infrastructure, such as fuel lines servicing emergency generators and boiler systems. The new design will incorporate tertiary containment liners, double-wall FRP tanks, flexible double-wall piping, and interstitial leak detection sensors connected to the existing Building Automation System (BAS) in Room BD-62 of the Medical Center.

3.3 ENVIRONMENTAL CONDITIONS

As documented in the April 2025 Site Assessment Report (AET Project No. P-0040293), soil borings were advanced near the UST basins to evaluate subsurface environmental conditions. Petroleum hydrocarbon contamination (TPH-DRO) was detected in surface soil from 0–2 feet below grade at boring B-06, adjacent to UST 2, with concentrations exceeding North Dakota Risk-Based Screening Levels (RBSLs). No petroleum impacts were observed in groundwater, and all other borings showed either non-detect or below-threshold concentrations. Additionally, lean clay that will have a low permeability is present immediately beneath the contaminated soil which further limits the potential vertical pathway to groundwater.

The Red River, a sensitive ecological receptor, is located downgradient from the UST sites. However, given the impermeable site cover (asphalt and concrete), the surface water protection pathway is currently considered incomplete. Similarly, groundwater protection, utility contact risk, and direct exposure pathways have been evaluated as part of the assessment and will be addressed through engineered controls and source removal during construction.

4.0 TIMING OF IMPLEMENTATION

The proposed underground storage tank (UST) removal and replacement project at the Fargo VA Health Care System is scheduled for implementation during Fiscal Year 2025, following completion of final design and environmental documentation. The anticipated timeline reflects considerations for construction sequencing, coordination with concurrent infrastructure upgrades, seasonal conditions, and required environmental permitting.

4.1 DESIGN AND PRE-CONSTRUCTION PHASE

The architectural/engineering (A/E) design phase is allotted a maximum of 262 calendar days from contract award to completion of 100% bid-ready construction documents. Key milestones within this period include:

• Schematic Design (35%) Submission: 105 days from notice-to-proceed (NTP)

• Design Development (65%) Submission: 167 days from NTP

• Contract Documents (95%) Submission: 229 days from NTP

• Bid Documents (100%) Submission: 262 days from NTP

As part of the design phase, environmental due diligence—including NEPA compliance, soil testing, and incorporation of remediation and permitting requirements—must be completed and integrated into construction bid documents. Coordination with the North Dakota Department of Environmental Quality (NDDEQ) UST Program is required at least 30 days prior to decommissioning existing tanks.

4.2 CONSTRUCTION PHASE

Construction is expected to span approximately 270 calendar days, beginning in mid-to-late FY25.

The construction schedule must be planned around:

• Seasonal climate factors, including the northern Plains’ freeze/thaw cycle and wet spring/fall conditions that could limit excavation and backfilling;

• Site-specific utility coordination with concurrent projects affecting the UST 2 area, such as the Building 1 generator room upgrades (Project 437-21-150) and Tier 2 electrical distribution improvements (Project 437-21-210);

• Temporary utility support, including provision of mobile fuel tanks, generator connections, and continuous operations of boiler and emergency systems; and

• Environmental remediation, specifically removal and off-site disposal of impacted soils around boring B-06 to a depth of 2 feet, with contingency planning for additional removal if unexpected contamination is encountered.

Contract documents will specify phasing requirements that limit work to one tank removal at a time, ensuring fuel supply continuity and safety. Final implementation tasks will include leak detection system testing, connection to the Building Automation System (BAS), surface restoration, and submission of final environmental documentation and certifications (e.g., UST Closure Reports, Certificates of Destruction, Soil Sample Results).

4.3 POST-CONSTRUCTION MONITORING

While permanent groundwater monitoring wells are not anticipated based on current data, the Fargo VA will evaluate the need for soil confirmation testing after the removal of existing tanks or surface inspections based on construction-phase findings and in consultation with NDDEQ. All environmental closeout documentation will be submitted to the VA COR and regulatory agencies as part of project demobilization.

5.0 ALTERNATIVES ANALYSIS

The National Environmental Policy Act (NEPA) requires federal agencies to rigorously explore and objectively evaluate all reasonable alternatives to a proposed action. This section outlines and analyzes the proposed action and its alternatives, including the No Action alternative, to identify the environmentally preferable option in light of potential soil impacts and operational needs.

Although this RSEA is intended to analyze the effects of the identified contaminated materials and their specific removal action, the action alternatives identified include repairs and retrofits to the existing USTs or the removal and replacement of the USTs with modern tanks that have additional leak protection measurements and leak detection systems.

5.1 ALTERNATIVE 1: PROPOSED ACTION – REMOVE AND REPLACE USTS WITH

ENHANCED CONTAINMENT AND LEAK DETECTION SYSTEMS

5.1.1 Description:

The proposed action involves the complete removal and off-site disposal of USTs 1, 2, 3, 4, and 8 along with their associated piping, leak detection, and monitoring components. These will be replaced with new double-wall fiberglass reinforced plastic (FRP) tanks, interstitial leak detection systems, and tertiary containment liners to prevent future hazardous material releases. Updated Automatic Tank Gauges (ATGs) and integration with the Building Automation System (BAS) will ensure centralized monitoring and compliance.

5.1.2 Environmental and Operational Benefits:

• Proactively mitigates the risk of petroleum product releases;

• Eliminates outdated, potentially vulnerable infrastructure;

• Addresses shallow soil contamination detected at boring B-06 through source removal;

• Prevents future soil and groundwater contamination via advanced leak containment and detection systems;

• Ensures compliance with federal (40 CFR Part 280), state (NDDEQ UST Program), and local regulations; and

• Maintains mission-critical backup power and heating system functionality.

5.1.3 Environmental Considerations:

• Requires excavation of contaminated soils near B-06.

• Temporary disturbance during construction; mitigated by best management practices (BMPs).

• Requires coordination with concurrent projects and careful utility location.

This alternative is the preferred option due to its long-term protection of environmental and human health, compatibility with ongoing site upgrades, and alignment with regulatory compliance requirements.

5.2 ALTERNATIVE 2: REPAIR AND RETROFIT EXISTING USTS

5.2.1 Description:

This alternative would attempt to retain the existing UST infrastructure, performing targeted repairs, retrofits, and component replacements to extend the service life of the system. Leak detection would be enhanced through upgraded sensors, and individual tanks might be lined or patched rather than fully removed.

5.2.2 Environmental and Operational Drawbacks:

• Existing USTs are near or past design life and may not be structurally suitable for retrofitting.

• Does not address known petroleum contamination at B-06 or provide for full soil remediation.

• May not meet current regulatory requirements for secondary/tertiary containment.

• Higher long-term maintenance and liability risks.

• Limited compatibility with modern BAS integration and automation.

This alternative is not preferred, as it poses continued environmental risk, leaves potential contamination in place, and does not provide a robust long-term solution for hazardous materials management.

6.1 EXISTING CONDITIONS – HAZARDOUS MATERIALS

6.1.1 Subsurface Soil and Groundwater

A Site Assessment Report (AET Project No. P-0040293, dated April 2, 2025) evaluated subsurface conditions at the Fargo VA Health Care System. Soil borings were advanced at five locations across the UST basins associated with USTs 1–4 and 8. The investigation revealed:

• Detectable petroleum contamination (TPH-DRO at 1,120 mg/kg) in shallow soil (0–2 feet below grade) at boring B-06, adjacent to UST 2.

• All other samples, including those near USTs 1–3 and UST 4, showed petroleum analyte concentrations below North Dakota Risk-Based Screening Levels (RBSLs).

• Groundwater was encountered at 10–16 feet below grade at most boring locations. However, no petroleum impacts to groundwater were identified.

• A soil boring could not be completed to the east of USTs 1, 2, and 3 due to a subsurface utility conflict, leaving a minor data gap in that area.

• The soils consist of alternating layers of clay, silt, sand, and gravel, consistent with the Oahe Formation.

• The site is paved in the vicinity of all USTs, reducing potential surface infiltration.

6.1.2 Historical Impacts and Mitigation

Historical documentation from the VA indicates that contaminated soils were discovered and fully removed in 1992 around USTs 2 and 3. No evidence of remaining contamination was found during the current investigation. However, these areas are flagged for careful visual and olfactory screening during construction.

6.1.3 Receptors and Exposure Pathways

• The Red River, a sensitive environmental receptor, is located approximately 375 feet east-southeast of the project site. Due to topography and lack of active surface drainage pathways, the surface water protection pathway is considered incomplete.

• The groundwater protection pathway is also considered incomplete, as no groundwater impacts were observed and shallow contamination has not penetrated below 2 feet.

• Construction workers are considered potentially exposed receptors due to shallow contamination at B-06. The pathway for soil ingestion, inhalation, and dermal contact is considered potentially complete during excavation unless mitigated.

6.2 ENVIRONMENTAL IMPACTS – PROPOSED ACTION

6.2.1 Soil and Groundwater Protection

The proposed action includes full removal of petroleum-impacted soils near boring B-06 and replacement of aging UST infrastructure with double-wall FRP tanks, tertiary containment liners, and interstitial leak detection sensors. These upgrades will substantially reduce the likelihood of future leaks or environmental releases. Impacts include:

• Excavation and off-site disposal of contaminated soil from the B-06 area, preventing migration or exposure.

• Short-term soil disturbance during excavation and tank removal, which will be mitigated through BMPs (e.g., dust control, covered stockpiles, silt fencing).

• No significant impact to groundwater is expected, and no permanent monitoring wells are warranted based on existing data.

6.2.2 Human Health and Worker Safety

Construction workers could encounter shallow contaminated soils at B-06. However, impacts will be mitigated by:

• Use of personal protective equipment (PPE) and OSHA-compliant health and safety protocols.

• Field monitoring using a photoionization detector (PID) to confirm successful removal of contaminated soils.

• Construction phasing to minimize open excavations and exposure time.

No long-term risks to site personnel or visitors are expected once contaminated soils are removed and the upgraded systems are operational.

6.2.3 Hazardous Materials Handling and Waste Management

Removed tanks, piping, and associated components will be handled as regulated waste:

• All hazardous materials will be removed off-site by licensed contractors.

• The contractor will provide certificates of destruction, tank closure forms, and soil sample results to the VA for regulatory compliance.

• Old fuel will be either recycled for temporary use during construction or disposed of in accordance with applicable laws.

6.3 ENVIRONMENTAL IMPACTS – ALTERNATIVES

6.3.1 No Action Alternative

The No Action Alternative assumes that the existing UST systems would remain in place without remediation of the petroleum-contaminated soils at B-06 and without any upgrades to containment or monitoring systems. Under this scenario, the existing contamination would persist, presenting ongoing environmental risks.

Failure to address the TPH-DRO contamination at B-06 leaves the petroleum-impacted soils in place, maintaining a potential exposure pathway to construction personnel, maintenance workers, or other future ground-disturbing activities. The No Action Alternative also perpetuates the risk of additional petroleum releases from aging UST infrastructure, which lacks secondary and tertiary containment and uses outdated leak detection technology.

This alternative would likely result in regulatory noncompliance with state and federal UST closure and monitoring requirements, exposing the VA to potential enforcement actions, liability, and costly emergency remediation in the event of a release. Additionally, the potential for migration of contamination to groundwater or utilities, though currently incomplete, could become significant over time as infrastructure continues to degrade.

Under the No Action Alternative, the existing UST systems would remain in place. This would result in:

• Continued risk of future petroleum releases due to aging tanks and outdated leak detection technology.

• Unaddressed shallow soil contamination at B-06, presenting potential exposure risk to future workers during ground disturbance.

• Eventual regulatory noncompliance and increased liability for the VA.

• Possible impairment of essential heating and backup power systems if a tank failure were to occur.

• Over time, petroleum contaminants could migrate vertically through permeable soils to shallow groundwater, or laterally toward nearby surface water bodies, such as the Red River approximately 375 feet east of the site.

The No Action Alternative does not meet the VA’s operational, environmental, or regulatory objectives and is therefore not considered environmentally acceptable. Overall, the No Action Alternative would result in negative long-term consequences for human health, environmental quality, and facility operations, and is therefore not a practicable option.

6.3.2 Retrofit Alternative

The Retrofit Alternative involves retaining the existing UST infrastructure with targeted repairs and component upgrades to extend the service life of the tanks and monitoring systems. Under this approach, enhancements may include lining tank interiors, replacing sensors, or upgrading certain leak detection components without full tank removal.

While the Retrofit Alternative could potentially improve monitoring capabilities, it would fail to remediate the petroleum-contaminated soils at B-06, leaving the existing contamination in place and allowing the exposure risk to remain. Furthermore, the structural integrity of the aging USTs may not be fully addressed through retrofit measures, leaving the possibility of system failure or undetected releases due to incomplete containment improvements.

The Retrofit Alternative presents higher long-term environmental risks than the Proposed Action because it does not eliminate the source of existing contamination and provides only partial assurance against future leaks. It may also fail to achieve full compliance with modern UST standards, particularly regarding tertiary containment and sensor integration with the BAS.

Retrofit of existing USTs may reduce short-term disruption but does not fully address:

• Soil contamination at B-06, which would remain unmitigated.

• The lack of tertiary containment and incomplete leak detection capabilities in the current infrastructure.

• Potential structural integrity issues with older tanks.

This alternative provides limited environmental benefit and does not eliminate known risks.

6.3.3 Proposed Action – Tank Replacement Alternative

The Proposed Action involves the full removal and replacement of USTs 1, 2, 3, 4, and 8, combined with the excavation and off-site disposal of petroleum-contaminated soils identified near B-06. This alternative directly addresses the diesel-range organic (TPH-DRO) contamination detected at concentrations exceeding the North Dakota Risk-Based Screening Levels (RBSLs) and removes the aging UST systems that are at risk for future failure.

The Proposed Action is expected to result in short-term, localized environmental disturbances during construction, including soil excavation, temporary dust generation, equipment-related emissions, and minor noise impacts. These temporary effects will be mitigated through best management practices (BMPs), including erosion control measures, dust suppression, spill prevention, and use of personal protective equipment (PPE) for worker safety. Air quality will be monitored through field screening with a photoionization detector (PID) to prevent exposure to volatile organic compounds (VOCs).

Importantly, the Proposed Action provides significant long-term environmental benefits, including the elimination of known contamination at B-06, prevention of potential future releases, and installation of modern UST systems equipped with tertiary containment and real-time leak detection integrated into the Building Automation System (BAS). These measures ensure regulatory compliance and substantially reduce the risk of soil and groundwater contamination in the future.

The groundwater protection pathway remains incomplete under this alternative, as groundwater was not impacted during investigation, and the Proposed Action eliminates potential contamination sources. Similarly, no adverse impacts are anticipated to surface water receptors, including the Red River of the North, due to the shallow nature of contamination, impermeable surface coverage, and effective containment strategies. In summary, the preferred alternative provides the following measures:

• Complete removal and decommissioning of five existing underground storage tanks (USTs 1, 2, 3, 4, and 8) and associated piping systems.

• Excavation and off-site disposal of petroleum-contaminated soils identified at boring B-06, where diesel-range hydrocarbons (TPH-DRO) exceeded North Dakota Risk-Based Screening Levels (RBSLs).

• Installation of new double-wall fiberglass reinforced plastic (FRP) USTs with:

o Secondary and tertiary containment systems.

o Interstitial leak detection sensors integrated into the campus-wide Building

Automation System (BAS).

• Connection of new piping systems, including supply, return, vent, and leak detection conduits, designed to meet current EPA (40 CFR Part 280) and NDDEQ UST regulations.

• Field screening and confirmation sampling using a photoionization detector (PID) and laboratory analysis to verify complete removal of contaminated soils.

• Implementation of best management practices (BMPs) for:

o Erosion and sediment control.

o Dust suppression and air quality monitoring.

o Spill prevention and emergency response during construction.

• Backfilling and compaction of excavation areas with certified clean fill to meet VA engineering standards and prevent settlement.

• Full restoration of disturbed areas, including:

o Pavement replacement (asphalt and concrete).

o Grading and re-seeding of landscaped and grass-covered zones.

o Resetting utility vaults, manholes, and stormwater drainage features to final grade.

• Verification of system performance and compliance through:

o Pressure testing of tanks and piping.

o Leak detection functionality checks.

o System startup and commissioning prior to acceptance.

• Documentation and reporting, including:

o UST Closure Reports.

o Soil removal and disposal manifests.

o Final Remediation Completion Report submitted to VA Engineering Service and

NDDEQ for regulatory closure.

6.4 CUMULATIVE IMPACTS

No cumulative hazardous materials impacts are anticipated. Adjacent VA projects (e.g., Building 1 generator and electrical upgrades) are being coordinated to prevent overlap or duplication of excavation in impacted areas. All work will comply with NDDEQ requirements, minimizing potential additive environmental effects.

The proposed action is expected to result in positive environmental outcomes by eliminating contaminated soils, modernizing hazardous material containment systems, and substantially reducing the risk of future fuel releases. The temporary impacts during construction will be controlled through best practices, and the long-term effect will be increased protection of soil, groundwater, surface water, human health, and the environment.

7.0 MITIGATION MEASURES

Mitigation measures are essential to reduce or eliminate the potential environmental and human health impacts associated with hazardous materials during implementation of the Fargo VA Health Care System Underground Storage Tank (UST) Replacement Project. The following measures have been developed in accordance with NEPA, VA policy, OSHA regulations, and guidance from the North Dakota Department of Environmental Quality (NDDEQ).

7.1 SOIL CONTAMINATION MITIGATION

Contaminated Soils (Boring B-06 Area):

• Excavation and Removal: Petroleum-impacted soils from 0–2 feet below grade at boring B-06 will be fully excavated and removed as part of construction. Excavation will extend beyond visibly impacted zones as necessary based on field screening with a Photoionization Detector (PID).

• Confirmation Screening: On-site PID measurements will be taken during soil removal to confirm the absence of residual volatile organic compounds (VOCs). Soils exhibiting organic vapor readings above background will continue to be excavated until clean margins are achieved.

• Disposal of Impacted Soils: Contaminated soils will be transported and disposed of at a licensed disposal facility. The contractor will provide documentation of disposal, including waste manifests, analytical reports, and disposal facility receipts, to the VA.

7.2 GROUNDWATER AND SURFACE WATER PROTECTION

• Although no petroleum-related groundwater impacts were identified, excavation practices will prevent vertical migration of contaminants by:

o Excavating and disposal of shallow contaminated soils prior to UST removals.

o Avoiding over-excavation into saturated zones.

o Stabilizing open trenches to prevent collapse or cross-contamination.

o Covering exposed soils and implementing stormwater BMPs to prevent surface runoff.

• To prevent discharge of contaminants into stormwater systems or the nearby Red River, the contractor will implement erosion and sediment control measures, including:

o Silt fencing, wattles, and catch basin protection.

o Temporary stockpile covers and perimeter berms around storage areas.

o Spill containment during refueling, fuel transfer, or equipment maintenance activities.

7.3 WORKER AND PUBLIC HEALTH PROTECTION

• Health and Safety Plan (HASP): The construction contractor will develop and implement a site-specific HASP in accordance with OSHA 29 CFR 1910.120 (Hazardous Waste Operations and Emergency Response Standard). The HASP will address:

o Identification of hazardous material exposure risks.

o Required PPE (e.g., gloves, respirators, Tyvek suits) during contaminated soil handling.

o Emergency response procedures in the event of a spill, release, or exposure incident.

• Access Controls: During construction, the project area will be fenced or otherwise restricted to authorized personnel. Public access will be prohibited to minimize accidental exposure.

7.4 SPILL PREVENTION AND CONTAINMENT

• A Spill Prevention, Control, and Countermeasure (SPCC) plan will be implemented throughout the project. This will include:

o Proper storage of fuels, lubricants, and hazardous materials in secondary containment.

o Spill kits available on-site at all times, including absorbent materials, booms, and waste containers.

o Immediate response protocols for any accidental release, with notification to VA, NDDEQ, and local emergency services as needed.

7.5 UST DECOMMISSIONING AND REPLACEMENT CONTROLS

• Removal of existing tanks and piping will follow all applicable NDDEQ and EPA UST Closure

Regulations, including:

o Notification of NDDEQ at least 30 days prior to closure.

o Performance of tank cleaning and purging by certified personnel.

o Field screening of backfill material and tank basin for contamination during removal.

o Proper abandonment of associated infrastructure (e.g., piping, gauges) not intended for reuse.

• New USTs will be installed with enhanced protection measures, including:

o Double-wall FRP construction with continuous interstitial monitoring.

o Tertiary containment liners to isolate potential future leaks from surrounding soils.

o Centralized leak detection reporting to both the Boiler Plant control room and the Building Automation System (BAS).

7.6 COORDINATION AND DOCUMENTATION

• Regulatory Coordination: The VA and its contractor will coordinate with the NDDEQ, City of

Fargo, and any other applicable regulatory entities to ensure all necessary permits and notifications are obtained.

• Reporting and Documentation: The construction contractor will prepare and submit the following:

o UST Closure Report(s) o Certificates of Destruction for tanks and piping o Soil sample analytical results and laboratory chains of custody o Environmental compliance documentation for VA records

• Post-Construction Monitoring: While not required under current conditions, VA will evaluate the need for follow-up soil confirmation testing at B-06 if additional contamination is discovered during excavation. Additional mitigation actions may be implemented if warranted.

These mitigation measures ensure that all activities involving hazardous materials during the project will be conducted safely, in compliance with applicable laws, and with minimal risk to the environment or human health. The measures also support the VA’s long-term stewardship goals and commitment to environmental protection.

8.0 CONCLUSION AND SUMMARY

The proposed action to remove and replace underground storage tanks (USTs) and associated leak detection systems at the Fargo VA Health Care System has been thoroughly evaluated in accordance with the National Environmental Policy Act (NEPA) and the Department of Veterans Affairs NEPA Interim Guidance for Projects. This Environmental Assessment (EA) specifically addresses the presence, handling, and mitigation of hazardous materials, with a focus on petroleum-based substances stored and managed through the existing UST systems.

8.1 SUMMARY OF FINDINGS

• Need for Action: The current UST systems, some of which are decades old, present increasing risks of hazardous material releases due to aging infrastructure, outdated leak detection technology, and known shallow soil contamination adjacent to UST 2.

Replacement is necessary to maintain regulatory compliance, safeguard human health and the environment, and ensure uninterrupted facility operations.

• Environmental Conditions: A 2025 Site Assessment revealed petroleum hydrocarbon contamination in shallow soil at boring B-06, with concentrations of TPH-DRO exceeding North Dakota Risk-Based Screening Levels. No petroleum impacts were found in groundwater, and the site is otherwise free of known contamination.

• Preferred Alternative: The proposed action—complete removal of USTs 1, 2, 3, 4, and 8, along with installation of modern double-wall FRP tanks, tertiary containment, and upgraded leak detection—offers the most effective and sustainable solution for preventing future environmental harm. It eliminates the current contamination, reduces long-term liability, and modernizes the fuel storage infrastructure.

• Impacts and Mitigation: Potential environmental impacts during construction, particularly related to hazardous materials handling and contaminated soil, are temporary and can be fully mitigated through best management practices, health and safety protocols, proper waste handling, and regulatory oversight. Post-construction, the project is expected to result in improved environmental protection and reduced long-term risk.

• Alternatives Considered: Alternatives including "No Action" and retrofit of existing systems were evaluated and determined to be insufficient. The No Action alternative would allow hazardous conditions to persist and increase environmental and operational risks. The retrofit option would fail to fully address contamination and regulatory shortcomings.

8.2 CONCLUSION

Based on the findings presented in this Resource-Specific Environmental Assessment, the proposed action does not constitute a major federal action significantly affecting the quality of the human environment. With appropriate mitigation measures in place, the project is not expected to have significant adverse impacts on soil, groundwater, surface water, or human health. The project offers positive environmental and operational benefits through the removal of existing contamination, modernization of fuel systems, and reduction of potential future hazards.

It is therefore anticipated that the appropriate NEPA determination will be a Finding of No Significant Impact (FONSI), and that no Environmental Impact Statement (EIS) or further NEPA analysis will be required.

9.0 REFERENCES

American Engineering Testing, Inc. (AET). 2025. Site Assessment Report – Fargo VA Health Care System USTs. Project No. P-0040293. Prepared for the Fargo VA Health Care System. April 2, 2025.

Department of Veterans Affairs (VA). 2010. VA NEPA Interim Guidance for Projects (PG-18-17). Office of Construction & Facilities Management, Environmental Program. Available at:

https://www.cfm.va.gov/til.

Department of Veterans Affairs (VA). 2025. Statement of Work – Underground Storage Tank Leak Detection and Replacement, Fargo VA Health Care System. Project No. 437-24-101.

North Dakota Department of Environmental Quality (NDDEQ). 2025. Correspondence Regarding UST Closure and Cleanup Requirements for Fargo VA Facility ID #5857. NDDEQ UST Program, March 2025.

North Dakota Department of Environmental Quality (NDDEQ). 2022. Underground Storage Tank Program Guidelines for Closure and Cleanup. Division of Waste Management, North Dakota Department of Environmental Quality. Available at: https://deq.nd.gov.

Occupational Safety and Health Administration (OSHA). 2019. Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard, 29 CFR 1910.120. U.S. Department of Labor.

U.S. Environmental Protection Agency (EPA). 2015. Regulations for Underground Storage Tanks (USTs): Requirements for Petroleum UST Systems. 40 CFR Part 280. Available at:

https://www.epa.gov/ust.

U.S. Environmental Protection Agency (EPA). 2014. Risk-Based Screening Levels (RBSLs) for Petroleum Hydrocarbons. EPA Office of Underground Storage Tanks.

ATTACHMENTS

Remedial Action Plan (RAP) Fargo VA Health Care System Project Number: 437-24-101

UST Replacement and Hazardous Materials Mitigation

1. Introduction

This Remedial Action Plan (RAP) has been prepared to support the implementation of the

Preferred Alternative identified in the Resource-Specific Environmental Assessment (RSEA) for the Fargo VA Health Care System Underground Storage Tank (UST) Replacement Project (Project

No. 437-24-101). This plan provides a detailed framework for conducting corrective and preventive actions related to the presence of hazardous materials—specifically petroleum hydrocarbons—within the project area and outlines the procedures for environmentally responsible removal, disposal, and replacement of existing fuel storage infrastructure.

The RAP has been developed in accordance with the National Environmental Policy Act (NEPA), the Department of Veterans Affairs (VA) NEPA Interim Guidance for Projects, and applicable

North Dakota Department of Environmental Quality (NDDEQ) and U.S. Environmental Protection

Agency (EPA) regulations governing the management of hazardous materials and underground storage tanks.

The Preferred Alternative includes the complete removal and off-site disposal of five aging USTs

(Tanks 1, 2, 3, 4, and 8), associated fuel piping and monitoring systems, and the installation of new steel tanks with tertiary containment liners and advanced interstitial leak detection systems. This action will directly address environmental risks identified during the 2025 Site

Assessment, which confirmed the presence of petroleum hydrocarbon contamination in shallow soil (TPH-DRO at 1,120 mg/kg at boring B-06), and will bring the Fargo VA campus into full compliance with current environmental and operational safety standards.

The goals of this Remedial Action Plan are to:

• Define and guide the safe excavation, handling, and off-site disposal of contaminated soils;

• Ensure the proper decommissioning, removal, and disposal of the existing USTs and associated piping systems;

• Implement engineering and procedural safeguards to prevent future environmental releases;

• Protect the health and safety of workers, patients, visitors, and surrounding communities during project implementation;

• Document and verify that remedial actions comply with applicable federal, state, and local regulations.

This RAP is intended to serve as both a planning and implementation tool for VA project managers, environmental consultants, regulatory reviewers, and construction contractors. It integrates findings from the Site Assessment Report (AET Project No. P-0040293), the

Environmental Assessment, and VA construction and safety standards to ensure a coordinated, transparent, and environmentally responsible approach to remediation and UST system modernization.

2. Objectives

The objectives of this Remedial Action Plan (RAP) are to guide the safe, compliant, and efficient execution of environmental remediation and infrastructure replacement activities associated with the underground storage tank (UST) systems at the Fargo VA Health Care System. This plan specifically supports the Preferred Alternative identified in the Resource-Specific

Environmental Assessment, which calls for the full removal of existing USTs and petroleum-impacted soils, and the installation of modern UST systems with enhanced environmental safeguards.

The RAP establishes clear environmental and operational objectives to address identified petroleum hydrocarbon contamination and to prevent future releases that could impact soil, groundwater, human health, or sensitive receptors such as the Red River. The plan also provides a framework for protecting workers and the public, ensuring regulatory compliance, and documenting the process from initiation through closure.

The specific objectives of the RAP are as follows:

2.1 Environmental Protection

• Excavate and remove petroleum-contaminated soils identified in the 2025 Site

Assessment, particularly in the area surrounding boring B-06, where diesel-range organics (TPH-DRO) were measured at concentrations exceeding state risk-based screening levels.

• Prevent migration of residual contaminants into surrounding soils, utilities, or groundwater through controlled excavation and engineering controls.

• Ensure that all waste materials, including soils and decommissioned tanks, are transported, managed, and disposed of at licensed facilities in accordance with RCRA, NDDEQ, and EPA requirements.

2.2 Human Health and Safety

• Protect on-site personnel, patients, contractors, and visitors from exposure to petroleum-contaminated media, vapors, or hazardous conditions through implementation of a Contractor’s site-specific Health and Safety Plan (HASP) in accordance with OSHA 29 CFR 1910.120.

• Limit potential exposure pathways by enforcing controlled site access, use of personal protective equipment (PPE), and dust and vapor control measures during soil handling and UST removal.

• Establish emergency response procedures for unanticipated discoveries of contamination, product release, or exposure during excavation or tank removal.

2.3 Infrastructure Modernization

• Decommission and remove five existing USTs (Tanks 1, 2, 3, 4, and 8) and associated piping, which are aging and no longer meet current containment and monitoring standards.

• Install new UST systems with double-wall construction, tertiary containment liners, and real-time leak detection systems connected to the Building Automation System (BAS) and Boiler Plant control room.

• Ensure that replacement systems are properly engineered to support long-term heating, fuel delivery, and emergency backup power operations at the Fargo VA campus.

2.4 Regulatory Compliance

• Achieve full compliance with:

o NDDEQ UST closure and cleanup requirements, o EPA UST standards under 40 CFR Part 280, o City of Fargo permitting and utility protection ordinances, and o VA safety and environmental management protocols.

• Submit all required regulatory documentation, including UST…