Title Page

  • Conducted on

  • Prepared by

  • Location
  • Do you have regulated above ground or under ground storage tanks on site?

J&J World Wide EHS&S Standards

  • Are all new or replacement tank systems above ground?

  • If there are any underground tanks, are they approved by EHS&S?

12.1.2 Effective Leak Detection Systems (Process and Tank System Management)

  • Do all storage tank systems have leak detection systems that are proven to be effective, efficient and responsive in providing early warning of any release?

  • Has the organization performed a risk assessment of all process tank systems prior to installation to establish the need for leak detection systems?

  • Are the systems appropriate to the task? (ie, simple liquid detection may suffice in normally dry areas but specific parameter, such as TPH, may be required to be assessed in wet locations.)

12.1.3 Proper Installation and Maintenance of Tank System Components (Process and Tank System Management)

  • Are all tank system components (such as liquid level monitoring, alarms, and switches) installed and maintained properly to ensure their functionality?

  • Are testing and frequency of testing of each component conducted based on criticality evaluation, risk-based maintenance and/or supplier specifications?

  • Are documentation maintained on all tank component maintenance activities?

  • Are tank systems and components, including connection stations, racked piping, and pumps, afforded proper protection against physical contact by traffic and/or equipment? (Not in current standard)

12.1.4 Inspection Program (Process and Tank System Management)

  • Has the organization established, implemented, and maintained a documented inspection program, with specified schedules, to detect or predict potential failures of all tank systems?

12.1.5 Prevention and Containment of Overflows (Process and Tank System Management)

  • Are adequate preventive measures and containment provided to prevent and capture all overflows or releases from tank vents, overfill lines, rupture disks, and emergency vents?

  • Has the organization established, implemented, and maintained procedures to dispose of the overflowed materials properly?

12.1.6 Removal of Underground Storage Tank System (Process and Tank System Management)

  • Are all abandoned or decommissioned underground tank system removed, except where removal would undermine the foundations of existing structures or is not permitted by laws or regulations?

12.2.1 Inventory of Storage Tanks

  • Has the organization established and maintained up to date, a documented inventory of all its storage tanks that includes the following information?

  • Type of tank (aboveground or underground)

  • Tank identification number

  • Tank location

  • Tank capacity

  • Installation date

  • Contents of the tank (both currently and at any time in the past)

  • Spill or overfill protection devices associated with the tank

  • Leak detection methods associated with the tank

  • Material of primary tank construction and any external protection (for example, coating, secondary containment, and corrosion protection)?

12.3.1 Above Ground Storage Tank Elements (Performance Standards for Above Ground Storage Tanks)

  • Do all aboveground storage tank system(s) contain the following elements?

  • Internal tank wall and piping material that is compatible to the contents and non-corrosive

  • Periodic integrity evaluation, i.e. in accordance with manufacturer instructions

  • Electronic in-tank gauging or other appropriate level indicator

  • Overfill protection (overfill shut-off valve or high-level indicator and alarm)

  • Double wall piping with leak detection or single wall aboveground piping with visual inspection, daily or on a frequency determined by the organization based on risk

  • Vapor recovery or treatment, as necessary, when storing VOCs

  • Appropriate protection, such as cathodic protection, for all metal underground and on-ground components, including piping, that are in contact with the earth

  • If tank system is located outdoors, documented procedure(s) for managing rainwater that accumulate in the secondary containment dikes or sumps, and properly treating contaminated rainwater before discharge

  • Secondary containment for liquid transfer operations such as truck loading/unloading area

  • Fire protection for all tank systems containing flammable liquids, except gas oils, diesel and light heating oils in the flash point range of 55°C to 75°C?

12.3.2 Additional Requirements for Single Wall Storage Tanks (Performance Standards for Above Ground Storage Tanks)

  • Do all single wall storage tanks include the following additional elements?

  • Secondary containment dike or vault with chemical impervious material or chemical-compatible coating and water stops and/or a liner for storage tanks containing hazardous chemical or waste

  • Secondary containment in good condition and free of cracks and gaps

  • Electronic leak detection system (such as sump monitor) for prompt detection of leakage from storage tanks and piping containing toxic chemicals or flammable liquids

  • Are Alternative leak detection systems, e.g. visual inspection (daily or on a frequency determined by the organization based on risk). employed for storage tanks and piping

12.3.3 Additional Requirements for Double Wall Storage Tanks (Performance Standards for Above Ground Storage Tanks)

  • Do all double wall storage tank(s) also include leak detection system (such as interstitial monitor)?

12.4.1 Stand-Alone Day Tanks Elements (Performance Standards for Stand-Alone Liquid Fuel Day Tanks)

  • Do all stand-alone day tanks containing liquid fuel that are aboveground, not connected to a fuel storage tank, and with capacities less than 500 gallons or 1893 liters, contain the following elements?

  • Internal tank wall and piping material that is compatible to the contents and non-corrosive

  • Periodic integrity evaluation

  • Double wall piping with leak detection or single wall aboveground piping with visual inspection, daily or on a frequency determined by the organization based on risk

  • Appropriate protection, such as cathodic protection, for all metal underground and on-ground components, including piping, that are in contact with the earth

  • Secondary containment for liquid transfer operations such as truck loading/unloading area

  • If tank system is located outdoors, documented procedure(s) for managing rainwater that accumulates in the secondary containment dikes or sumps, and properly treating contaminated rainwater before discharge?

12.4.2 Additional Requirements for Single Wall Day Tanks (Performance Standards for Stand-Alone Liquid Fuel Day Tanks)

  • Do all single wall day tank(s) also include secondary containment dike(s) or vault(s) constructed of or coated with material that is impervious to the fuel stored

12.4.3 Additional Requirement for Double Wall Day Tanks (Performance Standards for Stand-Alone Liquid Fuel Day Tanks)

  • Do all double wall day tank(s) also include leak detection system (such as interstitial monitor)

12.5.1 Training and Supervision of Personnel Who Manage Tanks (Training and Supervision)

  • Has the organization established, implemented, and maintained a tank training and supervision program to ensure that all personnel including contractors who operate and/or manage tank systems are adequately trained and supervised to perform their assigned functions?

  • Is there a documented procedure controlling and requiring manned tank filling and transfer?

  • Does it include initiation of emergency response?

12.6.1 New Hydraulic Elevators

  • Do all new elevator installations include the following system components?

  • Secondary containment system for hydraulic shaft?

  • Monitoring system for hydraulic oil leaks from the shaft?

  • Use of food-grade oil in the hydraulic system, whenever possible?

Hydraulic Elevators

  • Are all hydraulic power transmission systems, including dock levelers, compactors, and hydraulic elevators, subject to a periodic documented inspection based on risk of release?

  • Are procedures in place to immediately notify EHSS of a release from this equipment?

  • For all single-walled tanks with secondary containment (regardless of service), confirm the capacity of the containment is adequate.?

  • Review capacity calculation to ensure adequate capacity

  • Check to ensure that there is not additional equipment or material stored in the containment that displaces/reduces capacity

  • Check to ensure that no electrical equipment is installed within the containment. This is a particular concern with tanks of water treatment chemicals.

2.5.3 Physical Security

  • Has the organization established, implemented, and maintained procedures to ensure compliance with any applicable hazardous materials security regulations or requirements, as directed by government agency(s)?

State Specific Requirements

  • Are tanks properly registered with the state?

  • Is the registration current?

  • Are all tanks accounted for in the site's tank inventory (Residual Waste, Hazardous Waste, Raw Materials, Process Storage Tanks)?

  • Are state required monthly and annual inspections conducted? Are identified issues tracked and addressed?

  • Have tank integrity inspections been conducted at the required frequency by PADEP certified tank inspectors?

  • Is periodic training conducted regarding state specific requirements to all that inspect or conduct maintenace on tanks?

  • Have downstream notifications been sent anually as per PADEP?

  • Are tanks that are out of service or temporarily out of service been properly managed to meet state requirements (Labeled OOS, Out of service >5 years??)? For tanks that have been emptied and cleaned have associated lines and equipment also been flushed and cleaned?

  • Are tanks properly labeled as per state and federal requirements? (Residual Waste, Hazardous Waste, NFPA labels)

  • Do residual waste tanks meet the PADEP requirements regarding labeling, monitoring, overflow protection, inspections, secondary containment, etc..?

  • Are temporay tanks (Frac tanks) used at the facility?

  • Are temporary tanks moved or replaced on an annual basis(PADEP)?

  • Are temporary tanks properly labeled?

  • Are temporary tanks inspected on some frequency?

Tank Safety and Federal Programs

  • Are PMs in place for safety critical devices and are they traceable and current?

  • Are materials of construction used for tanks and ancillary equipment fully compatible with stored materials.

  • Are tanks, totes and IBCs storing flammable hazardous materials properly bonded/grounded?

  • Are safety relief devices properly sized for the tank and it's contents to prevent over pressurization of tanks?

  • Is the site considered a PSM facility?

  • Are applicable tank systems managed according to PSM requirements?

  • Does the site have Process Safety Information for applicable tanks?

  • Was a PHA conducted and PSSR conducted at time of installation?

  • Has a follow up PHA been conducted since installation?

  • Are applicable tanks included in Mechanical Integrity program?

  • Does the site have regulated substances in storage tanks above the threshold quantities listed by EPA under Risk Management Plan(RMP)?

  • Are requirements for RMP met?

  • Are tanks labeled properly labeled for confined spaces and do procedures (HECPs) exist for entrance into the tanks for cleanings or repairs?

  • Are tanks, totes and IBCs storing flammable hazardous materials properly bonded/grounded?

  • Are all relative tanks listed in the sites PPC/ICP/SPCC and include information regarding contents, capacity, safeguards, spill prevention procedures and countermeasures procedures?

Bulk Tanker Transfers to Storage Tanks & Secondary Containment

  • Are tankers properly grounded (and verifed) prior to connecting transfer hoses and initiating transfers of flammable/combustible materials to bulk storage tanks?

  • Is there a procedure in place to ensure that materials being transferred to storage tanks is the correct material prior to initiating transfers?

  • Are there adequate procedures for truck loading/unloading to prevent overflows and verify capacity exists prior to transfers?

  • Is guarding being used for pumps that transfer hazardous materials to prevent the possibility of exposure if a hose or line was to disconnect or rupture?

  • Are secondary containment areas checked for vegetation and debris presence?

  • Is there a preventative maintenance schedule on pumps used for the automatic detection of chemicals present in secondary containments prior to discharge of stormwater?

  • Are tank secondary containment areas inspected as part of routine stormwater inspections?

  • Are truck unloading dikes and tank secondary containment coatings in good condition?

  • Have valves used to prevent stormwater contamination during truck loading/unloading activities been tested and on a preventative maintenance schedule?

  • Have truck unloading sumps been inspected for integrity and confirmed that they are properly coated to prevent leaching to ground water?

  • Are PMs in place for truck unloading sumps?

  • Have there been any releases from tanks either static or during transfers in the last 3 years?

  • Are releases included in the site's PPC/ICP/SPCC plan?

Storage Tanks and Air Pollution

  • Are tank emissions (fugitive & working) tracked in the sites synthetic minor operating permit or Title V air permit?

  • Are fugitive emissions controlled from hazardous material tanks?

  • Is the site subject to Leak Detection & Repair (LDAR) requirements?

  • Is there a program in place to comply with LDAR requirements for both RCRA & HON?

  • Is the site subject to the Chemical Manufacturing Area Source Requirements (CMAS) regulations?

  • Does the site have a Title V air permit as part of the CMAS requirement?

  • Are hazardous materials in storage tanks, subject to EPCRA Tier II requirements, tracked and submitted on an annual basis?

Documents Reviewed

  • Written Program (procedures, PPC, SPCC, ICP)

  • Training Programs

  • Training Records

  • Tank Inventory

  • Tank Inspection Forms

Employee Discussions

  • Discussions were held with the following groups of employees on site. List number of people where applicable.

  • Were employees familiar with tank procedures, practices and regulatory requirements?

Facility Tour

  • If observations were made during the facility tour list observations.

General Information

  • Site Name

  • Address
  • Date of APR

  • Site Contact

  • List Partcipants in APR

  • Any recent Tank Releases?

  • Any projects planned for tanks or tank systems?

  • Does the storage tank program tie into the EMS? If so list and example.

  • Are tank systems currently identified in your aspects and impacts as a risk? If so what has been identified?

  • If Yes, were these aspects, impacts and actions reviewed during EHS&S management reviews?

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