August 7, 2017 – UST Deadline Reply

The August 7, 2017 deadline for closure of single-walled steel underground storage tanks (USTs) is rapidly approaching per the Massachusetts Department of Environmental Protection (MassDEP) UST Systems regulation 310 CMR 80.15. This regulation applies to all in-service and temporarily out-of-service USTs, with the exception of consumptive use tanks and tanks that were relined prior to August 8, 2007 in accordance with API 1631, 1983 Edition providing that the owner has a permit and approval from the Fire Department and a current, legally valid warranty for the relining.

At this juncture, if you are the owner of an UST that is not exempt from this regulation, the UST should have been or should be scheduled to be properly closed in accordance with MassDEP requirements. If not, you still have time to avoid MassDEP enforcement activity.  The MassDEP is granting extensions of the August 2017 deadline until July 1, 2018 to those who:

  • Take the UST out of service by August 7, 2017
  • File a Single-Walled Steel Tank Out-of-Service Notification to MassDEP within 30 days of the out-of-service date
  • Submit to MassDEP no later than August 7, 2017 a fully executed and signed contract for removing or closing the UST(s) on or before July 1, 2018

Remember that as part of the UST closure regulations, an assessment for contamination is required to be conducted upon in-place closure or, for removed USTs, within 24 hours after the UST is removed and prior to excavation backfill. The results of this assessment need to be reported in an UST Closure Report. Although the assessment is not required to be completed by a Licensed Site Professional (LSP), the UST removal contractor must be knowledgeable in the MassDEP release reporting criteria under the Massachusetts Contingency Plan (MCP). In all cases, if a reportable release condition is identified, an LSP must be involved in conducting remedial actions.

CAPACCIO’s EHS-Dashboard™ software solution can help you track regulatory deadlines associated with UST compliance as well as record monthly inspection data so that you can be ready to demonstrate compliance in real time. Please visit http://www.ehsdashboard.com to schedule a demo of our dashboard or contact Chris or Dawn whose contact information is listed below.

CAPACCIO is available to assist you in determining whether this regulation applies to you, assist you in meeting the August 7, 2017 deadline, and/or providing LSP services and assistance in the UST closure assessment process. Please contact Chris Walton, PE, PCEE at 508-970-0033 ext. 139 or cwalton@capaccio.com or Dawn Horter, PG, LSP at 508-970-0033 ext. 118 or dhorter@capaccio.com for additional information.

 

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