Audit Report 2009
"'
Audit Report Comments
The following section is a detailed listing of each deficient issue discovered
during compilation of the audit inspection report for the below listed subject site.
The listed issues reflect the answers to the audit questions 1 topics in the New
York State Department of Environmental Conservation Petroleum Bulk Storage
(PBS) Reaulations Inspection Report - PBS Inspection Form VA (4/1/2005).
The issue numbers listed below corresponds to the question 1 topic number from
the PBS Inspection Form. The following issues will be tracked until compliance
is achieved.
Subject Site:
PBS # 3-601192
Greystone Property
Wheeler Hill Road
Cobblestone Road
Wappingers Falls, New York 12590
Inspection - July 28, 2009
Mr. Joseph Jordan and Mr. Evan Stankunas of Enviro Clean Services, LLC
(ECS) conducted the inspection. Mr. Mark Liebermann of Town of Wappinger
was also present.
Audit Issue Comments
Issue NO.2
PBS Registration - Information corrections need to be made to the PBS
registration to reflect the current tank and piping information as observed on July
28, 2008. An information correction needs to be made to reflect the current tank
and piping. ECS will submit an amended PBS application.
Issue NO.4
Tank M001 is listed as "in service", however the tank was removed. An
inadequate Tank Closure Report was submitted to the NYSDEC. A tank closure
report must contain a site assessment, which includes laboratory analysis of the
soil samples from around the former tank. A proper tank closure report must be
obtained or generated prior to submission of PBS application.
Issue NO.8
The fill port lid should be repainted on Tank M007. The AST fill ports all need to
be color coded. The fill ports must be painted or labeled to indicate the product
stored.
Issue NO.1 0
(8) No tank tag is present for Tank 007. A tank tag must be supplied which
identifies Tank ID, product stored, design and working capacities, dimension,
date of installation and installer, tank model number, PBS number and a
statement that the tank system conforms to NYCRR Part 614.
(9) As-Builts - An as-built plan was available for this location, however did not
include the Part 614 Regulatory Statement. The plan must include a statement
by the installer indicating that the "tank and piping system has been installed in
compliance with the NYS Standards for New and Substantially Modified
Petroleum Storage Facilities, 6 NYCRR Part 614" (6 NYCRR Part 614.7 (d)).
ECS can provide an "as-built" for the facility if requested.
Issue No. 11
Leak Monitoring is being conducted utilizing the EBW system. Weekly records of
the interstitial monitoring were incomplete. The EBW tank monitoring system
must be certified for accuracy at least annually. The Town will be supplied with a
new weekly checklist and trained on the proper documentation and record
keeping.
Issue No. 17
No monthly inspections are being conducted for Tank M003-M006. ECS will
provide the necessary documentation and training to complete the inspections.
Issue No. 19
The secondary containment is not adequate for Tanks MOOS, and manifolded
tank system M003 & M006. The volume of the dikes for the tanks must be at
least 110% of the largest tank design capacity; ie. The dike for Tanks M003 &
M006 must be able to contain 303 gallons (110% of 275 gallons).
Tank M004 is single walled and does not have adequate secondary containment.
The Town must be able to provided adequate secondary containment as per
NYSDEC SPOTS 17. ECS recommends constructing a dike or similar structure
around the belly tank or install an alternate fuel tank to supply the generator
which meets SPOTS 17.
Issue No. 21
A gauge was present on Tank M003, however no gauge was present on Tank
M006. The manifold on the tanks allows product to be pushed from one tank to
the other during a fill. This tank system is compliant withNFPA regulations
however conflicts with NYSDEC regulations which state that all tanks must be
equipped with an overfill prevention device. ECS recommends re-piping the
existing tanks with separate fills and vents to prevent overfilling of the first tank.
Each tank could then be supplied with a whistlel gauge to satisfy NYSDEC
regulations.
Issue No. 22
None of the AST were labeled. All ASTs must be labeled with Tank #, product,
design and working capacity.
Issue No. 27
The overfill prevention (high level alarm) was not functioning during the
inspection on Tank M007. The high level alarm must be repaired.
Issue No. 58 and 59
Leak Monitoring is being conducted utilizing the EBW system. Weekly records of
the interstitial monitoring were incomplete. The EBW tank monitoring system
must be certified for accuracy at least annually. The Town will be supplied with a
new weekly checklist and trained on the proper documentation and record
keeping.
Double wall piping is present at the facility and the Town is not performing weekly
manual monitoring of the tank sumps for leak detection. ECS will provide the
Town with the necessary forms and training to complete the required inspection.
A sensor can also be installed within the sump to automatically detect liquid.
Issue No. 64
The tanks and piping are monitored monthly for releases as required by Federal
Regulations; however most documentation was missing or unavailable. The
Town will be provided with new inspection and checklist forms and a compliance
binder for all necessary record keeping documents.
Issue No. 65
See Issue NO.4
Additional Reaulatory Comments
Spill 0211922 - There is an NYSDEC Spill listed as "not closed" from March 3.
2003. According the NYSDEC documentation a Tank Test Failure occurred. No
further information was available regarding the status of the Spill or re-test(s).
ECS recommends conducting a limited subsurface investigation in the former
area of Tank M001 in order to compile a proper Tank Closure Report! Site
Assessment and to seek closure of Spill 0211922.
PBS InspecliOn Form v. 4 (4/1/2005)
Page 1
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL C.ONSERV ATlON
PETROLEUM BULK STORAGE (PHS) REGULATIONS INSPECTION REPORT
PBS#:
DATE:
or 0 Unregistered
GIS: N
TIME (24 hr):
Owner Name: "\ftl/V\. C't- l,'\!rf'IlJ-€Y
E
+IZ3.JvC\
Facility Name: f \ (\..Y/:::/fVY"f
Facility Address: v')~~ \.Q..."
f~~.\")z ~hf . '
\- \ \ \ \2..o"""'C\
Owner Address:
Operator:
Phone Number:
Emergency Contact:
Phone Number:
FACILITY Representative and Title:
!\YSDEC Representative and Title:
FACILITY REGISTRATION
1. Is the registration certificate posted at the facility? See Part 612.2.
(Y\li/k l) es.u M i"-IJ h
2. Is registration information current & correct? See Part 612.2.
3. Are monitoring wells marked and secured? See Part 613.3(b)(4).
Ai
IV'
yr-
fZe. CO'VV"-f"",,1"S
Tank Registration Identification Number MOO I I fY\CX)J frw,x' 1. /Ylt{) ~- .rntW~-"
-
Underground or Aboveground Tank vST /t~i It.!. itS! ASt
10060 "'2:~...l..... is" SOo__ -1-
Product Stored / Tank Volume if different than registered .."".~,~.""",....~'o.'''".".~" .:~..:,.:>.-
+tl.. "#,:). D,C.u I \)\'L,)<! t \t-~
Date Installed '/'jqb iI /1 jqc Ilj,/q?, 11/,/96
4. Are tanks properly permanently closed? Y/N/X (n/a) r~'rI~ N >< X .X'" ;><
5. Are tanks properly temporarily closed? YI NI X (n/a) ;X .x- X ..k- ~:
! 6. Were any unreported spills observed during the inspection (also include X N jlJ IV
suspected releases from leak detection equipment and un investigated fV
inventory discrepancies)? Y/N
7. Have tank top and dispenser sumps as well as fill port catch basins been )(
properly maintained? X X X X
Y I N (accumulation of product)1 I (poor condition)1 X (n/a)
8. Is the fillport color coded to identify the product in the tank? See 613.3(b). X rv y Ai
Y/N ~. (c--vn-V/Y1 +-s A;
9. If motor fuel tank has pressurized piping, is it equipped with a shear valve? X: X
Y! N (no shear valve)! I (inoperative valve)1 X (n/a) X X ~
//1<'.'(,'1-
\'.IST
i5lz
-it <2
x
X
/1./
y
I
/)(
Underground Tanks
(Y1O: i-
10. For tank systems installed after 12/86, does the tank system meet
standards? Y / X(n/a) [tank system installed prior to 12/86]
Ifnot, missing items? (I) corrosion resistant! (2) secondary containment! (3)
leak monitoring/ (4) overfill prevention [auto shut-off valve, high level alarm
or ball float valve] and (5) corrosion resistant piping with (6) leak monitoring
[line leak detector for pressurized piping] or (7) only one check valve under
the pump in suction piping system! (8) tank label/ (9) as.built plans or
drawings.
<7f) (I
PBS Inspection Form v. 4 (4/1/2005)
Page 2
Underground Tanks (cont'd)
."t'\1; C :t-
J1. Is leak monitoring (UST) being done [double-wall tank - interstice is
checked]?
Y/ N/ ] (inoperative system)/ 2 (monitoring records not maintained)/
3 (inappropriate method)/ X (n/a) .50- ~*S
12. Is cathodic protection for steel UST and piping systems monitored annually?
YI X (n/a) [not steel system]/ N (missing both)/ (1) no monitoring on
tank! (2) no monitoring on line/ (3) records not maintained! (4 )system
not maintained to achieve protection/ (5) inadequate method
13. Does the facility have adequate inventory records for ~ USTs?
Y/ X (n/a)
If not, missing items? (I) no records/ (2) poor equipment!
(3) no reconciliation/ (4) reconciliation performed other than 10 days/
(5) no investigation of discrepancy
14. Do un metered tanks have annual standpipe analysis or tank test, or other
acceptable leak detection method? Y/N/X(n/a)
15. Has tightness testing (USTs) been conducted on the tank and piping system?
[Check both tank and piping.]
Y / N/ 1 (entire tank not tested)/ 2 (no test on line)! X (n/a)
1
x
x
'Y
}
A.boveground Tanks
rf}o~ ":' (11 ti I'1It . - !ro' (,
\.0 ~ c.' c,} . (...~
16. For tank systems installed after 12/86, does the tank system meet standards?
If not, missing items? ASTs must be (1) welded steel with (2) adequate y \' 'I y
surface coating [paint]; if on soil, must have (3) cathodic protection and if on j
grade, must have an (4) impermeable barrier under the tank with the ability to
(5) monitor for leaks. SQ,L. C0VYV'"Q..VI~~
i 1'7 Does the facility conduct monthly inspections for all ASTs?
I ).. ('J N r
Y! N/ I (records not maintained) N N
18. Does the facility conduct ten year inspections for ASTs? X' )<. >< )(
Y! N! I (records not maintained)! X (n/a)
19. For ASTs ? 10,000 gallons, is the secondary containment adequately
designed and in good condition? )
Y! Nil (not maintained)/ 2 (poor design) '1 N ~
For ASTs < 10,000 gallons, if using alternatives to secondary containment, """".
are SPOTS # 17 issues addressed? c;..t (U('i~V"~
Y / N! I (equipment not maintained)1 X (n/a)
20. Are dike drain ,,'alves locked in a closed position? 'X X- X
YI N (unlocked)/ 1 (no valve)! X (n/a) X
21. Does the AST have a gauge, high level alarm or other equivalent device? ."/ 'Y Y hJ
Y I Nil (inoperative) i
22. Is the design/working capacity, and id number marked on AST and at N N
the gauge? N N
Y/ NJ ] (tank not labeled)/ 2 (not marked at gauge)
'J' Is a solenoid or equivalent valve in place for gravity-fed motor fuel X
.....J. X
dispensers? X X
YI N! 1 (inoperative)/ X (n/a)
24. Is a check valve in place for pump-filled tanks with remote fills? X X- X X
Y! N! 1 (inoperative)1 X (n/a)
25. Is an operating valve in place on every line with gravity head? X. X ~ )(
Y/N/l (inoperative)/X (n/a)
PBS inspection Form v. 4 (4/1/2005)
Page 3
FEDERAL UST Questions - Release Prevention
1Ylc)() :r
26. Is the spill prevention device (catch basin) present and functional? y
YI N (not present)1 I (not functional- holes or cracks present)!
X (nla for tanks receiving <25 gal. at one time)
27. Is the overfill prevention device (Le., automatic shutoff, high-level alann, ball y
float valve) present? yV-.^,,",,~
YI NI X (n/a for tanks receiving <25 gal. at one time) ((jl/'l'l""
28. Is-the overfill prevention device operational? YI X (nla)
If not operational:
! ) Automatic shutoff is not operational (Le., device tampered with or
inoperable; gauging stick in drop tube). 1
2) A larm is not operational.
3) Alarm is not audible or visible to delivery driver.
Ball float is not operational because:
4) Stage I vapor recovery is present.
5) Piping system is suction.
6) Drain valve on spill catch basin is broken or is impaired by debris.
29. Were structurally repaired tanks and piping tightness tested within 30 days of X
repair completion (not required wi internal inspections after repair or if
monthly monitoring is in use)? YI NI X (nla)
30. Were CP systems tested/inspected within 6 months of structural repair to tank X
or piping on any cathodically protected UST system?
YI NI X (n/a)
31. If an impressed current system is in use:
I ] ) System has been operated continuously. 'J
If system has not been operated continuously:
2) Rectifier is not operational.
3) Rectifier does not have electrical power 2417.
4) Clock (if present) shows that power has been turned off.
X) N/A (no impressed current system used).
~.., Does the corrosion protection system provide continuous protection? K
.l~.
YI X (nla)
If not:
1 ) CP system is not performing adequately based on results of testing.
2) CP system tested within required period and operator is not conducting or
has not completed appropriate repair in response to test results reflecting
that CP system is not providing adequate protection.
33. Are UST systems with impressed current cathodic protection inspected every
I 60 days (only required to keep 6 months of readings; at least 2 of last 3 X'
readings are required if system is operational at time of inspection)?
YI N/ X (n/a)
34. Are lined tanks inspected periodically (within 10 years of installation and
eve!)' 5 years thereafter) and is lining in compliance? X
YI (1) not inspected periodicallyl (2) lining not in compliance, Le., lining
was tested and failedl (3) inspection procedure not acceptablel (X) nla
35. Is buried metal tank and piping (which includes fittings, connections, etc.)
corrosion protected? YI X (n/a)
[fnot: I
! ) Buried metal piping components (such as swing joints, flex-connectors,
etc.) are not isolated from the ground or cathodically protected.
For new USTs - tanks and piping installed after 12/22/88:
2) Tank or piping does not meet new tank/piping standards for corrosion.
For existing USTs (tanks and piping installed on or before ]2/22/88) where tank or
piping does not meet new UST requirements:
3) Steel tank is not internally lined.
4) Metal tank or piping is not retrofitted with cathodic protection.
PBS Inspection Form v. 4 (4/1/2005)
Page 4
Federal UST Questions - Release Detection
36. Specify methodes) of tank release detection used:
A. Inventory Control with Tank Tightness Testing - answer questions 39-43
B. Automatic Tank Gauge (A TG) - answer questions 44-46
C. Manual Tank Gauge (MTG) - answer questions 47-50 f
D. Tightness Testing (safe [European] suction piping does not require testing)-
answer questions 51-53
E. Groundwater or Vapor Monitoring - answer questions 54-57
F. Interstitial Monitoring - answer questions 58-59
G. Automatic Line Leak Detector (ALLD) - answer questions 60-62
H. Statistical Inventory Reconciliation (SIR) - answer questions 63-65
37. Specify methodes) of piping release detection used.
If pressurized (choose two):
D. Tightness Testing - answer questions 51-53 '/
E. Groundwater or Vapor Monitoring - answer questions 54-57
F. Interstitial Monitoring - answer questions 58-59
G. Automatic Line Leak Detector (ALLD) - answer questions 60-62
H. Statistical Inventory Reconciliation (SIR) - answer questions 63-65
38. Specify method of piping release detection used (NOTE: safe [European]
suction piping does not require release detection).
If suction (choose one): ~
D. Tightness Testing - answer questions 51-53
E. Groundwater or Vapor Monitoring - answer questions 54-57
F. Interstitial Monitoring - answer questions 58-59
H. Statistical Inventory Reconciliation (SIR) - answer questions 63-65
X. Exempt Suction Piping
Inventory Control with Tank Tightness Testing 1V(j""t (-\{>P I 'fT P\tS (. \.:'
39. Is tank tightness testing performed as required (also answer questions 51-53)?
Y I N (not performed)1 I (inadequate)
40. Are inventory volume measurements for inputs, withdrawals, and remaining
I amounts recorded each operating day and reconciled as required?
I Y I N (no records)1 I (not reconciled)
41. Is inventory control equipment capable of 1/8" measurement? Y/N
! 42. Is product dispensing metered and recorded to required accuracy within local I
standards for meter calibration? YI N (unmetered)1 I (no records)
43. Is water level in tank monitored at least monthly? Y/N
Automatic Tank Gauge (A TG) f\J (It h-fr ~ 'I: (r+b LE
44. Can A TG detect a 0.2 gal/hr leak rate from any portion of the tank that
routinely contains product (i.e., is A TG on NWGLDE list)?
Y/N
45. Is A TO set up properly? Y/N
I 46. Has A TG been used to check the portion of the tank that routinely contains
I product? Y/N
Manual Tank Gauge (MTG) N (\\ ft~ ~ L \CA-f5L -
to'
I 47. Is tank size appropriate for using manual tank gauging (not valid for tank
size >2000 gal)? Y/N
48. Is method being conducted correctly? Y/N
49. Was any liquid added to or taken out of the tank during the test?
Y/N
50. Is MTG equipment capable of 1/8" measurement? Y/N
PBS inspection Form v. 4 (4/1/2005)
Page 5
Federal UST Questions - Release Detection (coot'd)
- f\ pr-C r-Cft{s r::-
Tightness Testing N cY\
51. Is tightness testing method capable of detecting a 0.1 gal/hr leak rate from
any portion of the tank that routinely contains product? YIN
I 52. Is tightness testing conducted within the specified time frames for the
following methods? (I) tanks - every 5 yearsl (2) pressurized piping -
annuallyl (3) Non-exempt suction piping - every 3 years
53. Is tightness testing conducted per manufacturer's instructions? Y/N
Groundwater or Vapor Monitoring IV {iT M f L-: r-- ( fti3 (/:.-
54. Has site assessment been done for vapor or groundwater monitoring?
Y/N
55. Is groundwater in the monitoring well never more than 20 feet from the
ground surface? Y/N
56. Is vapor moni toring well not affected by high groundwater? Y/N
57. Are wells properly designed and positioned? Y/N
Interstitial Monitoring
58. Can secondary containment be used to detect a release? Y/N f
59. Is the sensor properly positioned? Y/N QJ2.- cC~ r\ -I
Automatic Line Leak Detector (ALL D) IVVT f H ') r t ~ ( f~~.I (";
60. Is automatic line leak detector (ALLD) present and operational?
YI N (not present, but should be)/l (not operational)
61. Has annual function test of the ALLD been conducted. and are records
I available? Y I N (no test)/l (no records)
62. Does release detection system meet the perfonnance standards of 40 CFR
280.43 or 280.44? Y/N
Statistical Inventory Reconciliation (SIR) /J.j fY/ NfL-rIMeC
163. Can statistical inventory reconciliation (SIR) method detect a 0.2 gallhr leak
rate or a release of 150 gal within a month and meet the 9515 requirement
I (i.e.. is SIR method on NWGLDE list of release detection methods)?
YiN
Federal UST Questions - Other
fY/(x) I
64. Are tanks and piping monitored monthly for releases, and are records
available (must have records for the two most recent consecutive months and ~
for 8 of the last 12 months)?
Y/ J (no monthly monitoring)/2 (no records)/3 (inadequate records)
65. For permanently closed tanks, was site assessment perfonned? N
Y/ N/ J (inadequate)
I
66. General Facility Condition: GOOD I FAIR I POOR
COMMENTS (continue on separate paper):
Regional Notes or Fonns attached: _ pages
Refer to:
_ Spills - remediation system not operating
_ Air - vapor recovery problems
_ Water - SPDES problems / illegal floor drains
Solid & HazMat - used oil issues