Petroleum Bulk Storage Compliance Services
Posted on July 14, 2015
Client: Petroleum Bulk Storage Compliance Services
Project Type: Compendium of Public and Private Sector Clients
- Inspections of Petroleum Bulk Storage Tanks
- Regulatory Compliance Audits/Inspection
- Closure of Class V Injection Wells
- Removal and Closure of Underground Storage Tanks (USTs)
- Remedial Site Investigation
- Oil Recovery Programs
- Design and Retrofit Services
The 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 operations and maintenance procedures. To limit the potential liabilities associated with bulk storage of petroleum and chemical products, the firm provides comprehensive engineering services to both public and private sector concerns through a team of multi-disciplined professionals with decades of experience.
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 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, reviews of documentation and reporting programs, tank closure, release investigation/corrective action and preparation of contingency plans and spill response, prevention, cleanup and control plans.
The firm has provided petroleum bulk storage compliance services for the following clients:
• New York City Department of Environmental Protection
• PETRO (Petroleum Heat and Power Corporation), Southampton, New York
• Northrop Grumman Corporation (formerly Grumman Aerospace Corporation), Bethpage and Calverton Facilities, New York
• International Business Machines Corporation, Yorktown Heights and Valhalla, New York
• Long Island University – C.W. Post Campus
• United States Merchant Marine Academy
• Mount Sinai Medical Center
• Mount Sinai Hospital Queens
• Town of Oyster Bay Department of Public Works, Syosset, New York
• Nassau County Department of Public Works
• Village of Mineola Department of Public Works
• Village of Kings Point, Nassau County, New York
New York City Department of Environmental Protection
Removal and Closure of Underground Storage Tanks (USTs)
Dvirka and Bartilucci Consulting Engineers (D&B) was retained by the New York City Department of Environmental Protection (NYCDEP) to provide oversight activities associated with the removal and closure of underground storage tanks (USTs) located at the following Pump Stations:
• East New York Pump Station (Tank No. 217107)
• New Clove Pumping Station (Tank No. 3)
D&B provided oversight activities associated with the excavation and removal of USTs located at the East New York Pump Station in Brooklyn, New York and at the New Clove Pumping Station in Staten Island, New York. The NYCDEP planned to excavate and remove the USTs and collect endpoint samples to determine if the tanks had impacted subsurface soil. The NYCDEP and D&B personnel were on-site to document field activities. D&B provided daily field activity reports (DFARs) and photographic logs documenting the daily field activities. Clean Venture, Inc. (CVI) was contracted by the NYCDEP to remove the USTs.
CVI excavated soil from around the USTs with the use of an excavator. The excavated soil was stockpiled on poly sheeting. The USTs were purged using dry ice and readings were measured using a four gas meter. The USTs were removed from the ground and placed on poly sheeting for inspection and cleaning. The NYCDEP collected endpoint samples of soil within each of the tank excavations utilizing the bucket of the excavator as well samples from the stockpile of excavated material. CVI removed the excess material from the exterior of the shells, and the NYCDEP and D&B personnel conducted inspections of the USTs to confirm the condition of the tanks. D&B retained Action Remediation to sign off on the Tank Removal Affidavits since a Certificate of Fitness was required for this process.
CVI power washed the interior of the USTs and ran a vactor truck concurrently to avoid any potentially spills. After the tanks were cleaned, CVI drilled holes through the sides of the tanks to render them useless. The former tanks were sent off-site on a Straight Bill of Lading (BOL) and disposed as scrap metal. Analytical results were tabulated and compared to NYSDEC STARS Criteria.
Once the USTs had been excavated, removed, transported off-site and end point samples were collected, the New York State Department of Environmental Conservation (NYSDEC) authorized the NYCDEP to backfill the excavations up to grade.
Petroleum Heat and Power Corporation
Regulatory Compliance, Site Investigation and Oil Recovery Programs
Petroleum Heat and Power Corporation (PETRO) is one of the largest fuel oil retailers in the Northeast. PETRO retained the firm to provide full service engineering in areas of environmental compliance, design and implementation of subsurface soil and groundwater investigations, oil recovery programs, tank inspection and testing programs, tank registrations and permits, tank closures and generally assuring that its Long Island facilities are in compliance with applicable USEPA, NYSDEC (6 NYCRR) and Nassau and Suffolk County environmental requirements.
Selection of the firm was primarily based on our knowledge and familiarity with appropriate regulatory agencies and the firm’s long-standing experience and understanding of Long Island’s environmental conditions, including groundwater.
Southampton Terminal Site Investigation
Project included the completion of a site investigation of an oil storage/loading terminal in Southampton, New York. The project consisted of the following activities:
• The completion of a detailed multimedia compliance inspection in accordance with 6 NYCRR Parts 612-614 and the Suffolk County Sanitary Code.
• Engineering inspection of all existing above and underground fuel oil storage tanks (12 tanks with a combined storage capacity of approximately 500,000 gallons) to determine compliance with 6 NYCRR Parts 612-614 and the Suffolk County Sanitary Code.
• An evaluation of the proper closure of all “out-o-service” above and underground tanks.
• Installation of soil borings with laboratory analysis of soil samples for benzene, toluene, ethylbenzene and xylene, along with total petroleum hydrocarbons and fuel related constituents.
• A review of Suffolk County Department of Health Services files to establish an historical compliance record.
• Preparation of a comprehensive engineering report summarizing all regulatory interpretations and findings.
Petroleum Bulk Storage Compliance Program
The project includes all aspects of assuring compliance of a major petroleum bulk storage facility (containing twelve tanks with a combined storage capacity of approximately 500,000 gallons) with federal, state and local regulations. The project consisted of the following activities:
• Conduct a detailed facility-wide environmental compliance audit and engineering inspection of all aboveground and underground fuel oil storage tanks to assure compliance with the Clean Water Act (Spill Prevention Control and Countermeasure provision), New York State 6 NYCRR Parts 612-614 and the Suffolk County Sanitary Code.
• Undertake topographic survey to determine acceptability of secondary containment of aboveground storage tank area.
• Prepare and update Spill Prevention Control and Countermeasure Plan (SPCC).
• Submit updated registration/permit applications to the NYSDEC and the Suffolk County Department of Health Services for aboveground and underground storage tank system.
• Prepare specifications and oversee the installation of equipment for the upgrade of specific aboveground and underground tanks including cathodic protection, alarm systems, appropriate signage in accordance with 6 NYCRR Parts 612-614 and Suffolk County Sanitary Code – Article 12.
• Prepare engineering drawings for and provide oversight of the modification (reduction) of tank capacity for aboveground fuel oil storage tanks to be in compliance with the existing capacity of secondary containment system.
• Prepare an updated Major Oil Storage Facility (MOSF) license application in accordance with the requirements of 6 NYCRR Part 612-614. License granted by NYSDEC.
• Prepare specifications and provide engineering oversight for a comprehensive ultra-sound tank testing program for all aboveground fuel oil tanks at the facility.
• Coordinate with USEPA-Region II and provide regulatory interpretations regarding the applicability of a Major Oil Facility Response Plan in accordance with the Oil Pollution Act of 1990.
• Provide all coordination with the USEPA-Region II, NYSDEC and the Suffolk County Department of Health Services regarding regulatory interpretation.
• Prepare preliminary design drawings, permit/registrations, etc., for the upgrade of the facility’s primary load/unload facility for trucks including secondary containment system and roof structure.
Closure of Class V Injection Well, Westbury, New York
The project provided engineering services to prepare an approved Underground Injection Control (UIC) closure plan in conformance with the Safe Drinking Water Act and oversee implementation of selected remedy. The project consisted of the following activities:
• Coordination with USEPA-Region II regarding the provisions of the Safe Drinking Water Act and the most recent guidance concerning the Underground Injection Control (UIC) program.
• Coordination with the Nassau County Department of Health regarding all field investigation activities.
• Preparation of UIC closure plan for a Class V injection well. Closure plan approved by USEPA-Region II.
• Preparation of a Materials Management Plan in accordance with Nassau County Department of Health (NCDH)
regulations. Materials Management Plan approved by NCDH.
• Design and implementation of pre-closure delineation program, including the installation of soil borings and collection/analysis of soil samples.
• Evaluation of various engineering alternatives, including bioremediation and excavation and disposal.
• Preparation of pre-closure program reports, including recommendations for remedial action for submission to USEPA-Region II and Nassau County.
Oil Recovery Program, Bellmore, New York
The Petroleum Release Investigation and Response Program for Reliance Rite Fuel was undertaken in response to a release of No. 2 fuel oil from a 275-gallon underground storage tank utilized for space heating purposes at a residence in Bellmore, Nassau County, New York. The program included, but was not limited to, the following inspection to identify source of release and potential receptors, source removal (tank excavation), soil gas survey, soil boring program, evaluation of hydrogeologic site characteristics, groundwater monitoring program, evaluation of remedial alternatives, computer modeling, preparation of remedial plan, design and construction oversight of passive collection system and active dual pump selective skimming system, and operational oversight of remedial systems. The above-referenced investigatory and remedial activities were undertaken in consultation with the NYSDEC and owners of affected properties and resulted in the recovery of over 1,100 gallons of product, and the reduction of floating product thicknesses from over 1 foot to a sheen on a site-wide basis.
Oil Recovery Program, Brentwood, NY
The project provided engineering support to investigate and characterize the extent of a release of No. 2 fuel oil. The project included the installation of soil borings and a groundwater monitoring well. The project consisted of the following activities:
• Notification and coordination with the NYSDEC and Suffolk County Department of Health Services.
• Installation of a number of soil borings to ascertain the vertical and horizontal extent of the subsurface fuel oil plume.
• Installation of a monitoring well to determine the degree of groundwater contamination.
• Project currently ongoing and in discussion with the NYSDEC.
Northrop Grumman Corporation
Tank Inspection, Design and Retrofit Service, Calverton, New York
This project involved a “ten year inspection” of Northrop Grumman’s One Million Gallon JP-5 Jet Fuel Storage Facility and a 250,000-gallon No. 6 fuel oil tank in Calverton, New York. Based upon the findings of the inspection, the firm was also retained to design and provide engineering oversight of various tank upgrades and retrofitting activities. The project included the following activities:
• Development of the inspection and tank lining protocol in accordance with the applicable requirements of SCDHS
Article XII, NYSDEC 6 NYCRR Part 613.6(b), American Petroleum Institute (API) Standard 653, API Standard 652,
and the National Leak Prevention Association (NLPA) 631
• Engineering oversight of tank cleaning
• Tank Inspections in accordance with API-653
• Visual inspection with photographs and/or a record of any visible defects
• Tank Lining (Tank 06-05-7)
• Steam Pipe Retrofit
• Secondary Containment and Overfill Alarm Retrofit
Design of Heated Underground Storage Tanks for No. 6 Fuel Oil, Bethpage, New York
This project involved the removal of two 20,000-gallon underground storage tanks for No. 6 fuel oil. The project required the removal of the existing steel tanks, removal of residue and cleaning to a vapor-free condition, disposal of the existing tanks and the design of two new 10,000-gallon tanks. The installation included overfill protection and a heating system for the piping and storage tank. Due to the requirement to heat No. 6 fuel oil to enhance flow characteristics, fiberglass tanks could not be used. An investigation into alternative tank materials indicated a fiberglass-clad steel tank would be appropriate to withstand the elevated fuel oil temperature and provide corrosion resistance. Construction plans, specifications and construction cost estimates were prepared as part of this project.
Design of 10,000-Gallon Underground Diesel Oil Storage Tank, Bethpage, New York
The project involved removing four 15,000-gallon underground diesel oil storage tanks and replacement of these tanks with a 10,000-gallon double-wall steel tank and double-wall pipe underground storage system. In conformance with the New York State Bulk Storage Law and the Nassau County Fire Ordinance, a double-walled, steel underground storage tank utilizing a fiberglass-reinforced polyester resin coating system was utilized. The design incorporated a continuous leak detection system to permit monitoring of the annular space in the tank and piping to determine whether water or oil is present. The leak detection system utilized a capacitance-type level indicator and hi-level alarm probe to monitor volume of product in storage, and provide audible and visual warning signals to prevent overfilling the tank during filling operations. Construction plans, permit applications and construction cost estimates were prepared as part of this project.
Design of Heated 20,000-Gallon Underground Storage Tank for No. 6 Fuel Oil, Bethpage, New York
This project involved the removal and replacement of a 20,000-gallon underground storage tank for No. 6 fuel oil. In conformance with Suffolk County Sanitary Code – Article 7 and local building codes, a double-wall steel underground storage tank utilizing a fiberglass-reinforced polyester resin coating system was used. The design incorporated a hot water heat exchange unit installed inside the storage tank to maintain an elevated temperature (70°-100°F) to allow the No. 6 fuel oil to flow at the proper viscosity. Leak detection and overfill alarm probes were incorporated in the design to detect the presence of product within the double-wall tank and tank piping system. Construction plans, permit applications and construction cost estimates were prepared as part of this project.
Northrop Grumman Corporation
Evaluation Program and Design of Overfill Protection
Alarm System for 50 Underground Storage Tanks
In conjunction with an evaluation of a manufacturing facility for compliance with standards under the New York State Major Petroleum Storage Facility Regulations and the Nassau County Fire Ordinance, an evaluation of 50 USTs was conducted. The evaluation included identifying the location, storage capacity, construction material, age, type of protective coatings and type of overfill protection of all USTs used for the storage of petroleum products.
In addition, to conform with the requirements of the New York State Major Petroleum Storage Facility Regulations and the Nassau County Fire Ordinance, all USTs were required to have overfill protection alarms. This portion of the project involved a field survey of all tank locations, development of alarm system specifications, and estimation of construction costs. An investigation of several available overfill alarm systems was also conducted.
Plant 15 UST Assessment and Investigation
This project involved the assessment of an UST in accordance with the NYSDEC guidance documents entitled Spill Prevention Operations Technology Services (SPOTS) Memo #14 (Site Assessments at Bulk Storage Facilities), and Spill Technology and Remediation Series (STARS) Memo #1 (Petroleum-Contaminated Soil Guidance Policy). The project provided for an evaluation of the tank’s history (system design, tightness testing, previous owners/operators), as well as investigatory activities to determine the extent of the release (field measurements and laboratory analyses).
International Business Machines Corporation, Valhalla
and Yorktown Heights, New York
Closure of Underground Storage Tank
This project involved the closure of a 30,000-gallon underground steel tank utilized for the storage of No. 4 fuel oil. The firm provided engineering services in connection with the oversight of activities performed by subcontractors associated with the permanent closure, excavation, and removal of the storage tank and prepared the Closure Report that documented all activities. All work was performed in consultation with the NYSDEC and the Closure Report was submitted to the NYSDEC.
Underground Storage Tank Excavation and Removal
This project involved the excavation and removal of a 1,000-gallon underground storage tank that was utilized for the storage of No. 2 fuel oil. The project included oversight of the excavation and removal of the storage tank, removal of fuel stained soil, and backfilling to grade in consultation with the NYSDEC. A closure report was prepared and submitted to the NYSDEC that documented all activities associated with the closure of the tank.
Long Island University – C.W. Post Campus
The firm was retained by the C.W. Post Campus of Long Island University to oversee and document the closure of four USTs located at its campus in Brookville, New York. The tanks were historically used to store fuel oil for on-site heating at the Mary Lai Building, Little Theater, Brookville Hall and Riggs Hall. During each project, D&B was responsible for overseeing the tank removal contractor, checking the tank for holes and/or other signs of potential compromised integrity, visually assessing and screening soil beneath and adjacent to the tank with a photoionization detector (PID), directing the contractor to remove impacted soil present within the excavation, collecting endpoint soil samples for laboratory analysis and coordinating the activities with both C.W. Post and regulatory agency personnel. Following completion of the field activities, D&B prepared a letter report to document the closure activities, present photographs of the field activities and provide the analytical results of the soil samples. Following review, C.W. Post forwarded the letters to the appropriate regulatory agencies to complete the closure process.
United States Merchant Marine Academy
D&B was retained to conduct an evaluation of 28 petroleum storage tanks, including seven USTs located at the United States Merchant Marine Academy in Kings Point, New York. The project included an on site inspection of all the tank systems, regulatory review and preparation of a report summarizing the status of each tank system with regard to compliance with the Nassau County PBS regulations, USEPA underground storage tank regulations and various NYSDEC guidance documents including SPOTs Memos #10 and #17. Recommendations for maintenance and tank system upgrades based on best engineering practices were also included in the report. Mount Sinai Medical Center D&B was retained by the Mount Sinai Medical Center to provide independent environmental monitoring services for the construction of the new Center for Science and Medicine located at 102nd Street and Madison Avenue in New York City. As part of this project, D&B coordinated and oversaw the removal of 14 abandoned petroleum USTs that were discovered in three separate locations on the site. In each case, D&B registered the tanks with the NYSDEC and made arrangements with a tank removal contractor, certified by the New York City Fire Department (FDNY), to remove any remaining contents from the tanks and to clean tank shells. During the tank removal process, D&B conducted visual inspections, screened the adjacent soil with a PID to detect petroleum contamination and collected endpoint soil samples for laboratory analysis. Following the tank removal D&B prepared a closure report documenting the closure activities, including manifests for off site disposal of any petroleum and impacted soil, bills of lading for recycling of the tank shells, laboratory analysis and the FDNY affidavit of closure of the tanks.
Mount Sinai Hospital of Queens
D&B provided oversight of the closure and removal of two petroleum USTs at the Mount Sinai Hospital of Queens. This project involved coordination with the NYSDEC. The tanks were emptied, cut open, cleaned and the tank shells removed for recycling as scrap metal. D&B conducted visual inspections, screened the soil adjacent to the excavation for petroleum contamination, collected endpoint soil samples and prepared a closure report, including the FDNY affidavit documenting the proper closure of the tanks. D&B also oversaw an internal inspection of a third UST and assisted MSHQ with preparation of a request for proposals to complete upgrades of this tank system.
Town of Oyster Bay, Department of Public Works, Syosset, New York
Technical Assistance with Tank Testing and Remediation Program
The firm has provided technical assistance in support of the Town of Oyster Bay’s Tank Testing and Remediation Program since 1995. The project has included the inspection, testing and management of over 80 underground storage tank systems utilized by various Town facilities. The project has consisted of the following activities:
• High level alarm inspections/tests
• Leak detection alarm inspections/tests
• Reporting findings/recommendations to the Town of Oyster Bay
• Alarm repairs
• Petro-Tite II testing
• Data evaluation
Spill Site Monitoring Subtasks
• Quarterly sampling/analyses
• Data evaluation
Regulatory Compliance Subtasks
• Information review
• Coordination with NYSDEC/NCDH/NCFM
Noteworthy accomplishments have included: reducing the number of tanks requiring annual tightness testing by repairing alarm systems; reducing the number of tanks requiring upgrades by obtaining Nassau County Department of Health (NCDH) variances and placing such tanks on annual tightness testing schedules; successfully petitioning the NYSDEC to decrease monitoring frequency on spill sites which ultimately resulted in the NYSDEC closing the files on such sites; and assisting the Town in appropriately addressing Underground Injection Control (UIC) concerns to the satisfaction of the USEPA and NCDH.
Nassau County Department of Public Works, Mineola, New York
A. Holly Paterson Hospital in Uniondale, New York
Survey and Replacement of Underground Storage Tank
This project completed for the Nassau County Department of Public Works involved the replacement of nine heating oil and diesel fuel tanks with new tanks in accordance with Nassau County Health Department and Fire Marshall requirements. The tanks, ranging in size from 275 gallon aboveground to 25,000-gallon underground, included spill containment for fill and supply piping and leak detection and monitoring systems.
The project also included assistance in the development of a Tank Testing Program with the Nassau County Department of Public Works. The project involves tank tightness testing of over 30 underground storage tanks ranging in size from 2,000 to 40,000 gallons. The firm’s responsibilities included the coordination, scheduling, budgeting, field inspection and obtaining the services of a certified tank tester for each Tank Testing Program.
Village of Mineola Department of Public Works, Mineola, New York
Design of Two 500-Gallon Aboveground Petroleum Storage Tanks
This project involved the removal of five existing underground petroleum storage tanks and the replacement of two of the tanks with 500-gallon steel aboveground storage tanks with integral containment dikes. The tanks serve the auxiliary diesel engine pump drive for a water supply well booster station and the related heating system. Overfill and leak detection alarm systems were provided, as well as an interior day tank to service the diesel engine pump drive. Construction plans, specifications and construction cost estimates were developed for this project.
Village of Kings Point, Nassau County, New York
In response to a discharge of petroleum to a storm water outfall in the Village of Kings Point, D&B was called upon to conduct a spill investigation and oversee response activities, including removal of two petroleum USTs associated with the release. D&B coordinated the removal of the tanks with the NYSDEC and the Nassau County Fire Marshall. Nearly 500 tons of petroleum-impacted soil were excavated, characterized and transported off site for proper disposal as part of this project. Endpoint soil samples were collected and sent for laboratory analysis to verify that no petroleum contaminated soil remained before the excavations were backfilled with clean fill. A closure report was prepared by the firm to document the proper removal of the tanks and remediation of the associated petroleum spill.
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