Chemical Bulk Storage Compliance Services, Compendium of Public and Private Sector Clients

Posted on July 29, 2015

Client: Compendium of Public and Private Sector Clients
Project Type: Chemical Bulk Storage Compliance Services

Major Components

  • Initial Inspections of Chemical Bulk Storage Tanks
  • Annual Inspections of Chemical Bulk Storage Tanks
  • 5-year Inspections of Chemical Bulk Storage Tanks
  • Update and Amendment of Spill Prevention Reports
  • Chemical Bulk Storage Tank Design Services
  • Preparation of Contract Documents

Project Description

CBS-Photo-1The storage of chemical and petroleum products in tanks and containers has become a highly regulated activity in many jurisdictions. These units often represent the source of greatest potential environmental liability resulting from leaks, spills, failures or improper operation and maintenance procedures. To limit the potential liabilities associated with bulk storage of petroleum and chemical products, the firm, through a team of multi-disciplined professionals with decades of experience, provides comprehensive engineering services to both the public and private sector.

Our staff of chemical, electrical, mechanical, structural and environmental engineers has been responsible for projects ranging from the full service design of 5,000-gallon chlorine storage tanks to the inspection of a 500,000-gallon petroleum storage tank. In addition to design and construction oversight, the services offered by the firm also include regulatory compliance/auditing programs, tank/storage area registrations, tank inspections, review of documentation and reporting programs, tank closure, release investigation/corrective action and preparation of contingency plans and spill response, prevention, cleanup and control plans.

For the purpose of demonstrating our experience in the area of chemical bulk storage compliance services, we have elected to present profiles of assignments with municipal water supply and wastewater treatment facilities as well as private sector clients in the utility, semiconductor, pharmaceutical and food processing industries. Examples include the following clients:

  • New York City Department of Environmental Protection
  • Consolidated Edison Company of New York, Inc.
  • The Whiting-Turner Contracting Company
  • International Business Machines Corporation, East Fishkill and Poughkeepsie Facilities, New York
  • Entenmann’s, Inc., Bay Shore, New York
  • Industrial Design & Construction, Inc.
  • Pizzagalli Construction Company
  • PE-Bay Shore, LLC
  • City of Yonkers, New York

New York City Department of Environmental ProtectionNYCDEP Logo

Annual and 5-year Inspections of Chemical Bulk Storage Tanks at New York City’s Reservoirs and Chlorination Plants

For calendar years 2001 through 2013, the firm has provided engineering support to the Bureau of Water and Sewer Operations with regard to its chemical bulk storage program. Specifically, the firm was retained to conduct annual and 5-year inspections at twenty-four (24) registered chemical storage tank systems in accordance with regulations found at 6 NYCRR Part 598.7(c) and (d). The tanks, which are located at New York City’s Reservoirs and Chlorination Booster Plants, are used to store and feed water treatment chemicals into the New York City water supply. They are constructed of fiberglass-reinforced plastic and range in size from 300 gallons to 9,000 gallons. Chemicals stored in these tanks include sodium hydroxide, phosphoric acid and sodium hypochlorite.

As part of this project, inspection protocols were developed for each group of similar tank systems detailing the procedures to be used during the tank cleanout and inspection process. In addition, checklists were developed that were utilized to conduct the annual and 5-year inspections.

Prior to inspection, all tanks were emptied of remaining product, residual sludge was removed and the tank interior was rinsed. Waste generated as a result of the cleaning process was disposed of in accordance with applicable federal and state regulations. Internal and external visual inspections were conducted on each chemical storage tank system.

After the inspection was conducted, a detailed engineering report was prepared to document the inspection findings for each group of tank systems. This document included the following sections:

  • Narrative section
  • Annual inspection and 5-year inspection checklists
  • Assessment of compliance with 6 NYCRR Parts 596 – 599
  • Description of deficiencies
  • Repair recommendations
  • Cost estimate of any recommended repairs
  • Photographic log
  • Determination of expected life of tank and appurtenances

Update and Amendment of Spill Prevention Reports

The firm was requested by the NYCDEP to provide engineering support with regard to the update and amendment of Spill Prevention Reports for chemical storage tank systems located at the Hillview Reservoir, Jerome Park Reservoir, Shaft 8B Chlorination Booster Station and Richmond Chlorination Plant. As part of this assignment, the Spill Prevention Reports were reviewed and updated to assure conformance with the requirements found in 6 NYCRR Parts 595-599. The work included the preparation and inclusion of required Standard Operating Procedures, inspection reports, and other requirements found at 6 NYCRR 598.1(k) and were stamped by a New York State licensed Professional Engineer.

Preparation of Contract Documents

The firm was requested by the NYCDEP to provide engineering support with regard to the preparation of contract documents to address deficiencies identified during the inspection of several chemical bulk storage tanks at the Hillview and Jerome Park Reservoirs. In addition, the firm was retained to support the preparation of contract documents for the installation of secondary containment systems for transfer stations at various water treatment facilities. The contract documents included Technical Specifications and Contract Drawings that identified all work, modifications and additions required to bring the tank systems into compliance and included an engineer’s cost estimate to complete each activity.

The contract documents were incorporated into a bid package by the NYCDEP to retain contractor services to address the tank system deficiencies and fabricate and install secondary containment equipment at the hazardous substance transfer stations. The firm is currently providing contract management/administrative services on these assignments.

Consolidated Edison Company of New York, Inc.ConEd_Logo

Chemical Bulk Storage Spill Prevention Report- Indian Point Nuclear Generating Station
Buchanan, New York

Con Edison operates a sodium hypochlorite feed system at the Indian Point Nuclear Generating Station. The sodium hypochlorite tanks are located in the Screenwell Building located adjacent to the Hudson River. Sodium hypochlorite is used to prevent biological fouling of the screens at the intake bays used to draw cooling water for the facility from the Hudson River.

As part of this assignment, the firm prepared an update to the Chemical Bulk Storage Spill Prevention Report in accordance with 6 NYCRR Part 598.1(k) which included the following:

  • General Information and P.E. Certification;
  • Facility Description;
  • Summary of Releases;
  • Description of Chemical Bulk Storage Tank Systems and Assessment of Discharge Potential;
  • Compliance with 6 NYCRR Parts 596, 598 and 599;
  • Daily, Annual and 5-year Inspections;
  • Financial Responsibility;
  • Spill Response Plan;
  • Discussion and Assessment of Equivalent Equipment, Method or Practice;
  • Site Assessment and Findings
  • Spill Reporting Form; and
  • Written Procedures for Preventing the Mixing of Incompatible Substances.

The update to the Spill Prevention Report involved documenting the installation of a 500-gallon sodium hypochlorite day tank associated with the above-described feed system. In order to certify the tank system prior to operation, the firm performed a visual inspection of the day tank and associated piping systems for weld breaks, punctures, scrapes of protective coatings, cracks, corrosion, other structural damage and improper installation. An inspection certification was prepared documenting that the tank system was properly installed.

The Whiting-Turner Contracting CompanyWhitingTurner_Logo

Initial Inspections of Chemical Bulk Storage Tanks at International Business Machines Corporation, East Fishkill, New York

This project involved conducting the initial inspections of nine chemical storage tanks installed by The Whiting-Turner Contracting Company at the IBM East Fishkill facility and providing certification that the installation was completed in accordance with the chemical bulk storage tank regulations found at 6 NYCRR Part 599. The tanks had been installed as part of an expansion at the IBM East Fishkill facility to support manufacturing operations associated with the “300 mm Development Pilot Line Project.” The tank capacity ranged from 1,358 to 7,670 gallons, and tank construction materials included fiberglass-reinforced plastic, steel and high-density linear polyethylene resin. The chemicals to be stored in the tanks were sulfuric acid, hydrochloric acid, sodium bisulfite, phosphoric acid, sodium hypochlorite and sodium hydroxide.

As required by regulations found at 6 NYCRR Part 599.11(f), prior to placing a tank and ancillary equipment in use, the storage tank system must be inspected by a qualified inspector for the presence of any of the following items:

  • weld breaks;
  • punctures;
  • scrapes of protective coatings;
  • cracks;
  • corrosion;
  • structural damage; and
  • improper installation

In addition, the tanks and ancillary equipment must be tested for tightness and inspected in accordance with a consensus code, standard or practice that meets the standards of the section.

To certify compliance with these regulations, internal and external inspections were completed on the newly installed tanks. A statement certifying that the system met the standards of 6 NYCRR Part 599 was prepared for each tank system. In addition, a report certified by a Professional Engineer was prepared to document compliance.

Initial Inspections of Chemical Bulk Storage Tanks at International Business Machines Corporation, East Fishkill, New York

The firm was again retained by The Whiting-Turner Contracting Company to provide engineering support associated with conducting the initial inspections of four chemical bulk storage tanks installed by at the IBM East Fishkill facility and providing certification that the installation was completed in accordance with the chemical bulk storage tank regulations found at 6 NYCRR Part 599. As a result of the initial inspections conducted, the firm identified several repairs and corrective action items that were completed prior to placing the tanks into service.

In order to certify compliance with these regulations, internal and external inspections were completed on the four tanks and a statement certifying that the system met the standards of 6 NYCRR Part 599 was prepared for each tank system. The final report was stamped by a New York State licensed Professional Engineer.

International Business Machines CorporationIBM

Annual Inspections of Chemical Bulk Storage Tanks, East Fishkill, New York

Since 1999, the firm has been providing engineering support to the IBM East Fishkill facility with regard to its chemical bulk storage tank program. As part of this assignment, the firm has conducted annual inspections of approximately fifty-five (55) registered chemical bulk storage tanks at the IBM East Fishkill facility. The annual inspections of the chemical bulk storage tanks were conducted in accordance with 6 NYCRR Part 598.7(c), and included the following:

  • Visually inspecting for cracks, areas of wear, corrosion, poor maintenance and operating practices, excessive settlement of structures, separation or swelling of tank insulation, malfunctioning equipment, safety interlocks, safety trips, automatic shutoffs, leak detection, and monitoring, warning or gauging equipment which may not be operating properly;
  • Visually inspecting dikes and other secondary containment systems for erosion, cracks, evidence of releases, excessive settlement and structural weaknesses;
  • Checking on the adequacy of exterior coatings, corrosion protection systems, exterior welds and rivets, foundations, spill control equipment, emergency response equipment and fire extinguishing equipment;
  • Visual checking of equipment, structures and foundations for excessive wear or damage; and
  • Reviewing compliance with 6 NYCRR Parts 598 and 599.

The firm documents the results of the annual inspections in a summary report.

In addition, the summary report provided a list of concerns pertaining to spill prevention for each tank, which were identified during the annual tank inspections, as well as the recommended corrective action.

Five-year Inspections of Chemical Bulk Storage Tank, East Fishkill, New York

Since 1998, the firm has conducted 5-year inspections of approximately fifty-five (55) chemical bulk storage tanks at the International Business Machines Corporation East Fishkill facility in accordance with the New York State Chemical Bulk Storage Regulations. The tanks ranged in capacity from 300 gallons to 16,000 gallons and were constructed of several different materials including carbon steel, stainless steel, and fiberglass reinforced plastic. The tanks were utilized to store various chemicals including sodium hydroxide, sulfuric acid, ethylene glycol, methanol, sodium hypochlorite, freon, acetone, and methyl isobutyl ketone to support utility and manufacturing operations.

The tanks were inspected in accordance with the appropriate American Petroleum Institute (API) Standards and Technical Association for the Pulp and Paper Industry (TAPPI) Technical Information Papers (TIP), including:

  • API Standard 653, Tank Inspection, Repair, Alteration and Preconstruction
  • API Standard 510, Pressure Vessel Inspection Code: Maintenance Inspection, Rating, Repair and Alteration
  • API 570 – Piping Inspection
  • TAPPI-TIP 0402-28 – Guidelines for Inspecting used FRP Equipment

The project also involved internal inspections of four greater-than-10,000-gallon capacity tanks. This required the development of a project-specific confined space entry plan and coordination with IBM facility and emergency control personnel.

Summary reports documenting the 5 year inspections were prepared, including a list of action items for each tank pertaining to spill prevention and tank system integrity, as well as recommendations for corrective action for any items identified during the 5 year inspections.

In addition, the firm also updated the Spill Prevention Report in accordance with 6 NYCRR Part 598.1(k) to include observations and concerns identified during the inspection program, as well as recommendations for corrective action.

Five-year Inspections of Chemical Bulk Storage Tanks, Poughkeepsie, New York

Since 1998, the firm has provided engineering services in support of the chemical bulk storage program for International Business Machines Corporation’s Poughkeepsie facility. As part of this project, the project team conducted the 5-year inspections of approximately thirteen (13) registered chemical bulk storage tanks in accordance with the New York State Chemical Bulk Storage Regulations. The tanks ranged in capacity from 260 gallons to 8,000 gallons and were constructed of several different materials including carbon steel, stainless steel and fiberglass reinforced plastic. The tanks were utilized to store various chemicals including sodium hydroxide, sulfuric acid, ferric chloride, aluminum sulfate, sodium hypochlorite, sodium bisulfite and xylene to support utility and manufacturing operations.

The tanks were inspected in August 1998 and again in October 2003 in accordance with established American Petroleum Institute (API) Standards and Technical Association for the Pulp and Paper Industry (TAPPI) Technical Information Papers (TIP). A summary report documenting the 5-year inspections was prepared, including a list of action items for each tank pertaining to spill prevention and tank system integrity, as well as corrective actions for any items identified during the inspections.

Entenmann’s, Inc., Bay Shore Facility

As part of this project, the firm was retained to provide professional engineering oversight for the completion of annual and 5 year inspections of two chemical bulk storage tanks at the Entenmann’s Bay Shore, New York facility. The inspections were conducted in order to assess compliance with New York State Department of Environmental Conservation (NYSDEC) regulations associated with Chemical Bulk Storage (CBS) found at 6 NYCRR Parts 596, 598 and 599.

Services provided by the firm included inspections and regulatory compliance evaluation of the two tank systems, including ancillary equipment, piping and secondary containment systems. A summary report was submitted to Entenmann’s containing the inspection findings and individual assessments of each tank. The assessments included an engineering analysis of the tank’s integrity and operation/ maintenance recommendations.

Industrial Design & Construction Inc.

The firm was retained by IDC Construction Management, Inc. to provide engineering services with regard to eight new chemical bulk storage tanks to be installed at the IBM East Fishkill facility. The eight (8) tanks ranged in capacity from 12,000 gallons to 28,000 gallons and are utilized to store various chemicals including sodium hydroxide, sodium bisulfate, and ammonium hydroxide. Materials of construction of the tanks included fiberglass reinforced plastic and stainless steel.

As part of this project, the firm reviewed design drawings and specifications for compliance with the NYSDEC CBS regulations found at 6 NYCRR Parts 595 through 599. Specific recommendations regarding compliance with the regulations were provided to IDC with modifications incorporated into the final design documents.

Pizzagalli Construction Company

The firm was retained by Pizzagalli Construction Company to provide engineering services with regard to five new chemical bulk storage tanks to be installed at the IBM East Fishkill facility. The storage tanks ranged in capacity from 5,000-gallons to 28,000 gallons and are utilized to store various chemicals including ammonium hydroxide, sodium hydroxide, sulfuric acid and sodium bisulfite. Materials of construction of the tanks included fiberglass reinforced plastic and stainless steel.

As part of this project, the firm reviewed design drawings and specifications for compliance with the NYSDEC CBS regulations found at 6 NYCRR Parts 595 through 599. Specific recommendations regarding compliance with the regulations were provided to Pizzagalli with modifications incorporated into the final design documents.

Following installation, the firm conducted the initial inspections of the chemical storage tanks and provided certification that the installation was completed in accordance with the chemical bulk storage tank regulations found at 6 NYCRR Part 599.

To certify compliance with these regulations, internal and external inspections were completed on the newly installed tanks. A statement certifying that the system met the standards of 6 NYCRR Part 599 was prepared for each tank system. In addition, a report certified by a Professional Engineer was prepared to document compliance.

PE-Bay Shore, LLC

This project involved providing engineering support with regard to a 19% ammonium hydroxide storage tank located at the PE-Bay Shore facility in Bay Shore, New York. This chemical storage tank is part of a selective catalytic reduction system that is being installed on internal combustion engines at the facility to meet the reduced Oxides of Nitrogen (NOx) emission limits stipulated under regulations found at 6 NYCRR Part 227-2.4(f).

In support of this project D&B assisted the facility in obtaining the necessary permits and registrations for the tank system. As part of the work conducted, D&B ensured compliance with the following requirements:

  • Town of Islip Fire Marshall and Zoning Construction Departments
  • Suffolk County Sanitary Code – Article 12
  • 6 NYCRR Parts 595 through 599 (New York State Department of Environmental Conservation Chemical Bulk Storage Regulations)

Based on the findings of the evaluation, certain upgrades to the design were recommended. D&B then prepared drawings and specifications for upgrades to the proposed tank system that included:

  • A secondary containment area for the tank truck load/unload area, 6,000-gallon aqueous ammonia tank and chemical metering pumps, which included a roof structure above the tank to prevent the accumulation of precipitation
  • Chemical resistant coatings for secondary containment areas
  • Tank overfill protection, including high level alarms and level gauges located at the tank truck load/unload area

City of Yonkers, New Yorkcbsyonkers1

The firm was retained by the City of Yonkers (COY) to conduct 5-year tank inspections of the chemical bulk storage systems operated by the COY. D&B inspected two phosphoric acid tanks at the COY Hillview Corrosion Control Facility, and four phosphoric acid tanks and four sodium hydroxide tanks at the COY Tuckahoe Road Low Service Corrosion Control Facility.

 cbsyonkers2All of the tanks inspected by D&B as part of the program are utilized by the COY to store chemicals for the treatment of potable water. The tanks were all aboveground storage tanks constructed of polyethylene and ranged in size from 260 gallons to 3,000 gallons.

The 5-year inspections were conducted in accordance with the New York State Department of Environmental Conservation (NYSDEC) Chemical Bulk Storage regulations found at 6 NYCRR Part 598.7(d). The inspections consisted of a thorough external inspection meeting the requirements of the NYSDEC document entitled DER-16/Five-Year Inspection of Plastic Tanks, which included the following:

  • External inspection of the tanks and documentation of any visible defects;
  • Informal stress cracking test of the tank shells, if determined necessary after visual inspection; and
  • Inspection and assessment of all ancillary equipment, including piping, pumps and containment systems.

cbsyonkers3D&B prepared a detailed Engineering Report documenting the findings of the inspections and providing a comprehensive evaluation assessing each tank’s compliance with applicable NYSDEC CBS regulations. Based upon the findings of the inspections, D&B provided the COY with detailed recommendations for achieving and maintaining compliance with the regulations, including a tank upgrade alternative analysis. This analysis provided the COY with several different options for upgrading the tanks to meet the NYSDEC CBS regulations, including replacing single-walled tanks with double-walled tanks, containment area modifications and upgrades, tank transfer area upgrades and spill/overfill prevention upgrades.

In addition to the above, it was determined during the inspections that one of the tanks at the Hillview Corrosion Control Facility was out-of-service, contained diluted sodium hydroxide and was situated adjacent to an in-service phosphoric acid tank. Since sodium hydroxide and phosphoric acid are incompatible, and since the COY wanted to bring this tank back into service for the storage of phosphoric acid, D&B recommended conducting a change-in-service for the tank. As a result, the COY retained D&B to oversee the tank and piping decontamination activities conducted in support of bringing the tank back into service for the storage of phosphoric acid. Following tank cleaning, D&B prepared a change-in-service evaluation letter in accordance with 6 NYCRR Part 598.10(b) documenting that the tank was suitable to be returned to service for the storage of phosphoric acid.

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