No 14 Revised TMFJB SCBG Environmental Assessment Report.pdf

Potential Root Cause CBS Action Response

Design deficiency. Per Debriefing with AOC Team on 12/4/19 AOC Team to provide RFP for work to be performed. 1/16/2020 MC Dean performed inspection and found line to be properly installed and no further action required.

Notified ACO on 1/21/2020, awaiting update.

Personnel were unaware of requirements.

CBS Posted on 12/10/19.

Completed. T‐226428

Personnel were unaware of requirements.

CBS completed removal and relocation to the Hazard Material cage in the Loading Dock area and has scheduled a pick up for December 2019, and will provide transcript to team and post on the I drive. T‐226429

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40 CFR 112.8(d)(3): Properly design pipe supports to minimize abrasion and corrosion and allow for expansion and contraction.

In the equipment penthouse on the roof, the metal fuel piping for the 900 kW emergency generator is in direct contact with the concrete as it passes through the wall. The metal piping should not be in direct contact with the concrete to prevent corrosion.

Widen wall penetrations and insert a liner between the metal piping and the concrete to prevent direct contact with the concrete.

Observed Date

Building Citation Finding Recommendation

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AOC Environmental Manual: The AOC Environmental Manual, Chapter 6 (Petroleum Storage Tanks), Section

4.2.1 requires that facilities prepare a Spill Prevention, Control, and Countermeasure (SPCC) plan when oil storage capacity is greater than 1,320 gallons and update the plan as required by 40 CFR 112. The SPCC plan requires that an emergency contact information sheet be posted at the site and that the information be kept up to date.

Room LB‐21 (Fuel Oil Pump Room) does not have a spill notification sign posted and Room LB‐20 (Fuel Oil Tank Room) has a spill notification sign that is out of date.

Post current spill notification signs in Rooms LB‐20 and LB‐21.

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40 CFR 262.11: A person who generates a solid waste, as defined in 40 CFR 261.2, must make an accurate determination as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations.

In Room LB‐87 (Elevator Maintenance Room), a can with a hazardous waste label had “N/A” listed as the accumulation start date and “hydraulic fluid” listed as the contents. At the time of the inspection, facility personnel were unsure of the contents of the container.

As a result, a proper waste determination was not made on the contents of the container.

Label the container with the phrase "pending analysis" on the hazardous waste label and add the accumulation start date. Move the container to the hazardous waste accumulation area.

Perform a waste characterization. Label and dispose of the waste properly based on the results of the characterization.

Personnel were unaware of requirements.

CBS Completed this item as part of the new Grease Interceptor project.

September 2019 . T‐226430

Personnel were unaware of requirements.

CBS Completed this item as part of the new Grease Interceptor project.

September 2019. T‐226431

Fill port requires structural modifications.

CBS completed on 12/10/19, per our meeting with AOC Team on 12/4/19, we have created a reoccuring CRO tas part of a monthly inspection to remove water from area.

T‐226432

Personnel were unaware of requirements.

CBS Completed in October 2019 and shared with AOC Team as well as posted on the I drive. T‐226433

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Best Management Practice In Room LB‐64 (South Sump Pump Room), a blue 55‐gallon drum had a universal waste label with the words “Garage Waste” and an accumulation start date of 5/24/17. The drum was empty and facility personnel indicated it is no longer used.

Remove the drum from the facility or remove the universal waste label and mark the drum with the word “empty”.

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40 CFR 112.1(d)(2)(ii):

(d) Except as provided in paragraph (f) of this section, this part does not apply to:

(2) Any facility which, although otherwise subject to the jurisdiction of EPA, meets both of the following requirements:

(ii) The aggregate aboveground storage capacity of the facility is 1,320 U.S. gallons or less of oil. For the purposes of this exemption, only containers with a capacity of 55 U.S.

gallons or greater are counted.

In Room LB‐64 (South Sump Pump Room), there is an unlabeled 55‐ gallon drum to catch kitchen grease. The drum is not in the Spill Prevention, Control, and Countermeasure (SPCC) plan.

Facility personnel indicated the system was installed in June 2019.

Either add the 55‐gallon drum to the SPCC plan and manage the drum in accordance with the requirements of the plan or replace the drum with a container that has a capacity of less than 55 gallons. Label the drum with an indication of the contents.

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40 CFR 112.7(c): Provide appropriate containment or diversionary structures or equipment to prevent a discharge.

The spill bucket on the fill port for the 2,000‐gallon diesel fuel aboveground storage tank (AST) at the Thurgood Marshall Building contained water.

Spill prevention equipment must be kept clean and dry. Make sure fill ports are covered and sealed.

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20 DCMR 500.8: The owner or operator of a stationary source shall maintain the records required by this chapter for not less than three (3) years.

Records for the Thurgood Marshall Building emergency generators do not specify the time and reason for each generator start‐up, as required by condition VI.a.1 of the air permit.

For each generator start‐up, record the date, time, duration and reason for operation.

Personnel were unaware of requirements.

CBS Completed in October 2019 and shared with AOC Team as well as posted on the I drive. T‐226434

Personnel were unaware of requirements.

CBS Completed by providing confirmation to AOC team on 12/4/19 this is part of the brand new Pneumercator system that was installed as we as placed on the new CAD drawing for building equipment updates. T‐ 226435

Lack of training or records. CBS Completed in October 2019 and shared with AOC Team as well as posted on the I drive. T‐226436

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40 CFR 112.7(a)(3)(iv): You must also address in your plan countermeasures for discharge discovery, response, and cleanup (both the facility's capability and those that might be required of a contractor).

Facility personnel could not confirm that there are leak detection sensors in the secondary containment of the fuel pumps in Room LB‐21 (Fuel Oil Pump Room) of the Thurgood Marshall Building to prevent a significant release from the area containing the pumps.

Use liquid sensors in the secondary containment to detect a release from a component failure of a pump.

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20 DCMR 500.8: The owner or operator of a stationary source shall maintain the records required by this chapter for not less than three (3) years.

While records of operating hours are recorded for the Thurgood Marshall Building emergency generators, total operating hours for maintenance checks and readiness testing of the preceding rolling 12‐month period are not determined each month, as required by condition VI.a.3 of the air permit.

For each generator, determine and record total operating hours for maintenance checks and readiness testing for each rolling 12‐month period within 15 days of the end of each month.

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40 CFR 112.7(f): (1) At a minimum, train your oil‐handling personnel in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols;

applicable pollution control laws, rules, and regulations; general facility operations; and, the contents of the facility SPCC Plan. (2) Designate a person at each applicable facility who is accountable for discharge prevention and who reports to facility management. (3) Schedule and conduct discharge prevention briefings for your oil‐handling personnel at least once a year to assure adequate understanding of the SPCC Plan for that facility. Such briefings must highlight and describe known discharges as described in §112.1(b) or failures, malfunctioning components, and any recently developed precautionary measures.

Personnel performing monthly oil storage container inspections for the Thurgood Marshall Building could not provide records verifying that they completed Spill Prevention, Control, and Countermeasure (SPCC) training within the last year.

Ensure all personnel who conduct aboveground storage tank inspections attend annual training on the content of the SPCC plan and maintain documentation that such training is completed.

Inspections not completed or documented.

CBS Team creates this on a monthly basis shares with AOC team as well as places on the I drive for future reference if required. T‐ 226437

Inspections not completed or documented.

CBS Team are utilizing when system is being filled, but we will make sure our team is fully aware of this process when we perform filling as we focus forward. We also have created Tank Filling Checklist book for proper documentation filling and reference. T‐226438

Personnel unable to locate plan.

CBS team has posted in the CBS Control room for the entire team to utilize. We also utilize and review as part of our annual Spill Containment Training. T‐ 226439

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40 CFR 112.7(e): Conduct inspections and tests required by this part in accordance with written procedures that you or the certifying engineer develop for the facility. You must keep these written procedures and a record of the inspections and tests, signed by the appropriate supervisor or inspector, with the SPCC Plan for a period of three years. Records of inspections and tests kept under usual and customary business practices will suffice for purposes of this paragraph.

Tank filling checklists are not being completed in accordance with the Spill Prevention, Control, and Countermeasure (SPCC) plan for the Thurgood Marshall Building.

Complete tank filling checklists and maintain records of the checklists for a period of three years.

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40 CFR 112.7(e): Conduct inspections and tests required by this part in accordance with written procedures that you or the certifying engineer develop for the facility. You must keep these written procedures and a record of the inspections and tests, signed by the appropriate supervisor or inspector, with the SPCC Plan for a period of three years. Records of inspections and tests kept under usual and customary business practices will suffice for purposes of this paragraph.

Monthly oil storage container inspections are not being performed or documented in accordance with the Spill Prevention, Control, and Countermeasure (SPCC) plan for the Thurgood Marshall Building.

Perform monthly oil storage container inspections and maintain inspection records for a period of three years.

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40 CFR 112.3(e): If you are the owner or operator of a facility for which a Plan is required under this section, you must:

(1) Maintain a complete copy of the Plan at the facility if the facility is normally attended at least four hours per day, or at the nearest field office if the facility is not so attended, and (2) Have the Plan available to the Regional Administrator for on‐site review during normal working hours.

A copy of the Spill Prevention, Control, and Countermeasure (SPCC) plan for the Thurgood Marshall Building was not available for review at the facility.

Maintain a copy of the SPCC plan at the facility.

Lack of training or records. CBS Team has these items posted on the I drive as well as being part of our contracual deliverables with AOC provide each year of the following month:

November. At this time all Hazat and other training credentials are updated. T‐ 226440

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AOC Environmental Manual: The AOC Environmental Manual, Chapter 3 (Hazardous, Universal, and Non‐ Hazardous Waste), Section 4.3 requires that records documenting that personnel received the required hazardous waste management training must be maintained at the facility.

Facility personnel were unable to provide records documenting that personnel responsible for hazardous waste management at the Thurgood Marshall Building had received annual Resource Conservation and Recovery Act (RCRA) hazardous waste management refresher training within the past year.

Ensure that attendance records of annual RCRA hazardous waste management refresher training are maintained for three years.