SPCC Compliance Update – Integrity Testing of Aboveground Storage Tanks Reply

In accordance with the US Environmental Protection Agency (US EPA) Oil Spill Prevention regulations found at 40 CFR 112.8(c) owners and operators subject to the Spill Prevention, Control, and Countermeasure (SPCC) rule are required to test or inspect each aboveground container for integrity on a regular schedule. Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing.

The type of inspection to be performed is generally determined by the registered Professional Engineer certifying the SPCC Plan. Many SPCC plans reference the Steel Tank Institute Standard for Inspection of Aboveground Storage Tanks (SP001) as the accepted industry standard that the tanks will be inspected against. SP001 stipulates the recommended inspection frequency for various tank configurations.

While SP001 allows qualified facility personnel to perform the inspections and this is appropriate for monthly visual checks of the tank integrity, CAPACCIO recommends that tanks be inspected by a certified STI inspector at least once per year. A certified STI inspector will often uncover issues of non-compliance that are missed by facility personnel.

If you need assistance with AST integrity testing or SPCC compliance, or have general questions, please contact Jeff Briggs, certified STI inspector, at jbriggs@capaccio.com or 508-970-0033 ext.  120.

MassDEP Extends Deadline for Submittal of Certain Third-Party Inspection Reports Reply

Taken from recent MassDEP email sent by Nancy L. Seidman

Due to the extraordinary accumulation of snow over the past 6 weeks, MassDEP recognizes that performing Third Party Inspections and Stage I/II annual compliance testing may have been and could still be difficult to complete. Given this unique circumstance, MassDEP will accept as compliant TPI reports and Stage I/II certifications that were scheduled to be completed between January 15 and March 15, if they are submitted no later than March 31, 2015. This extra time will not affect a facility’s future compliance date(s).

MassDEP expects that facilities will return to normal operation as quickly as feasible so that receipt of product and all required regulatory obligations such as A/B operator inspection, system testing and TPI reports will be accomplished.

If you have additional questions please call the Stage I/UST assistance line at 617-556-1035.

If you need any additional assistance, please call Chris Walton, PE, BCEE, Senior Associate and Technical Area Leader for Tank Services at CAPACCIO at 508-970-0033 ext. 139 or cwalton@capaccio.com.

Department of Fire Services Issues Revision to 502 CMR 5 Reply

502 CMR 5 governs the permitting and use of containers greater than 10,000 gallons in capacity used for the storage of fluids other than water. On January 16, 2015, the new regulations went into effect, resulting in significant changes to the program.

Beginning with the next permit cycle, the use permit will be issued for five years. However, along with the next inspection report, owners must declare what nationally recognized standard applies to their tank. Future use permits will be issued contingent upon operators maintaining their tanks per the declared standard. Records must be kept in accordance with new recordkeeping requirements.
In addition, the new regulations clarify and expand application requirements, describe actions that must be taken to bring an unpermitted tank into the program, and specify how to apply for a change in use for a permitted tank.

CAPACCIO has extensive experience assisting clients with program compliance, through application preparation to inspections. Please contact Chris Walton, PE, BCEE, at (508) 970-0033 x139 or cwalton@capaccio.com for more information.

Changes to Aboveground Storage Tank Annual Inspection Program Reply

The Commonwealth of Massachusetts’ Office of the State Fire Marshal (OSFM) recently announced some proposed changes to the program for annual inspections of aboveground storage tanks (ASTs) greater than 10,000 gallons containing fluids other than water (502 CMR 5). The changes are part of the Commonwealth’s effort to move to electronic permitting and licensing programs.

In one significant change to the program, OSFM will be mailing renewal notices three months prior to the expiration date of each AST use permit to the person in charge of the tanks. These renewal notices must be submitted along with the completed inspection forms, so remember to give them to the inspector. In another program change, the completed inspection forms must now be submitted to the OSFM at least 30 days prior to the use permit expiration date. These and other changes are designed to streamline the inspection process prior to the move to electronic filing.

Finally, remember the OSFM considers tanks containing any fluid (including gases, such as propane or nitrogen) subject to the annual inspection program.

If you have any questions about the Commonwealth’s program for annual inspection of ASTs, please contact Christopher Walton at cwalton@capaccio.com or 508.970.0033 ext. 139.