Annual Program Review - Storage Tanks Pilot V4

• Conducted on

  Date

• Prepared by

• Location
  Address

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

  Yes

  No

  N/A

J&J World Wide EHS&S Standards

• Are all new or replacement tank systems above ground?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• 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.)

  Yes

  No

  N/A

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?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• Are documentation maintained on all tank component maintenance activities?

  Yes

  No

  N/A

• 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)

  Yes

  No

  N/A

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?

  Yes

  No

  N/A

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?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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?

  Yes

  No

  N/A

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?

  Yes

  No

  N/A

• Type of tank (aboveground or underground)

  Yes

  No

  N/A

• Tank identification number

  Yes

  No

  N/A

• Tank location

  Yes

  No

  N/A

• Tank capacity

  Yes

  No

  N/A

• Installation date

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• Spill or overfill protection devices associated with the tank

  Yes

  No

  N/A

• Leak detection methods associated with the tank

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• Electronic in-tank gauging or other appropriate level indicator

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• 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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• 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

  Yes

  No

  N/A

• Secondary containment for liquid transfer operations such as truck loading/unloading area. Are Spill containment buckets used at the tank fill point or containment at the remote fill point.

  Yes

  No

  N/A

• 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?

  Yes

  No

  N/A

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?

  Yes

  No

  N/A

• 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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• 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

  Yes

  No

  N/A

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)?

  Yes

  No

  N/A

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?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• Periodic integrity evaluation

  Yes

  No

  N/A

• 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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• 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?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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)

  Yes

  No

  N/A

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?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• Does it include initiation of emergency response?

  Yes

  No

  N/A

12.6.1 New Hydraulic Elevators

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

  Yes

  No

  N/A

• Secondary containment system for hydraulic shaft?

  Yes

  No

  N/A

• Monitoring system for hydraulic oil leaks from the shaft?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• Review capacity calculation to ensure adequate capacity

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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)?

  Yes

  No

  N/A

State Specific Requirements

• Are tanks properly registered with the state? (PADEP - USTs >110 gallons containing regulated substances, ASTs >250 gallons containing regulated substances, Fuel Tanks >1,100)<br>

  Yes

  No

  N/A

• Is the registration current?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• Are state required 72 hour, monthly and annual inspections conducted? Are identified issues tracked and addressed?

  Yes

  No

  N/A

• Have tank integrity inspections been conducted at the frequency required by the state? (PADEP certified tank inspectors? (>5,000 gallons every 10 years, >21,000 gallons every 5 years PADEP)

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• Have downstream notifications been sent anually as per PADEP? (PADEP requirement for Large AST Systems and large AST facilities that are defined as having more than or equal to 21,000 gallon capacity or facilities with an aggregate AST storage capacity exceeding 21,000 gallons)

  Yes

  No

  N/A

• 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?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• Are tanks protected from collisions with vehicles/PIVs (Bollards) and other equipment and access restricted ?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• Are temporary tanks properly labeled?

  Yes

  No

  N/A

• Are temporary tanks inspected on some frequency?

  Yes

  No

  N/A

Tank Safety and Federal Programs

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• Is the site considered a PSM facility?

  Yes

  No

  N/A

• Are applicable tank systems managed according to PSM requirements?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• Has a follow up PHA been conducted since installation?

  Yes

  No

  N/A

• Are applicable tanks included in Mechanical Integrity program?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• Are requirements for RMP met?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• 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?

  Yes

  No

  N/A

• Are secondary containment areas checked for vegetation growth and debris presence that may indicate issues with the integrity?

  Yes

  No

  N/A

• Is there a preventative maintenance schedule on automatic detection systems used to detect releases of chemicals in secondary containments?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• Are PMs in place for truck unloading sumps?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

Storage Tanks and Air Pollution

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

  Yes

  No

  N/A

• Does the site have a Title V air permit as part of the CMAS requirement or a Synthetic Minor Operating Permit?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

• Are fugitive emissions controlled from hazardous material tanks?

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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

  Yes

  No

  N/A

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?

  Yes

  No

  N/A

Facility Tour

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

ISO 14001

• Does the storage tank program tie into the site's Environmental Management System (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?

• Any projects planned for tanks or tank systems?

General Information

• Site Name

• Address
  Address

• Date of APR

  Date

• Site Contact

• List Partcipants in APR