Did you receive an AST form from the DFS? Reply

If your organization uses an aboveground storage tank (AST) with capacity greater than 10,000 gallons, you may have received a letter and an “AST Approved Standard Declaration Form” from the Department of Fire Services (DFS) and you may wonder why.

The form is not a cause for alarm, but DFS requires AST permit-holders to complete one form for each permitted tank and return the form to DFS.

To refresh memories, in 2016 the DFS standards were changed and now each permitted AST must be inspected and maintained in accordance with an “Approved Standard” – a standard proposed by the permit-holder and approved by the DFS.  The Approved Standard you propose specifies the nature and frequency of the inspections you will perform for each tank.

As a holder of an AST Use Permit, organizations are responsible for ensuring the tank is inspected in accordance with an Approved Standard and that they maintain the records of inspections and maintenance performed in between renewals (Use Permits for ASTs renew every five years).  As part of the renewal process, a Qualified Inspector (as defined in 502 CMR 5.03) must inspect the tank and review the tank inspection and maintenance records to ensure that the tank has been inspected and maintained in accordance with its Approved Standard.  The findings of the tank inspection and documentation review are submitted to the DFS for review before the DFS will issue another Use Permit.

If you are an AST permit-holder, you may self-perform the inspections if you have a Qualified Inspector on staff. Otherwise you can retain an outside firm (e.g. an engineering firm, a tank supplier, or a chemical or industrial gas supplier) to provide the inspections and maintenance.  CAPACCIO recommends that if you utilize an outside firm, make sure to obtain documentation after each inspection and confirm that maintenance action is performed to ensure employee safety and regulatory compliance.

Ensuring your organization’s AST tanks are being maintained in accordance with the Approved Standard is an important aspect in avoiding and mitigating risks and ensuring business continuity for your organization.

If you received one of these letters from DFS, make sure to pay attention to the due date at the bottom of the letter as some we have seen are due as soon as August 30, 2019.

If you have any questions, please contact Chris Bannon, EIT or Art Cunningham, PE, or utilize our chat feature on our website.

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At CAPACCIO, we live our mission of “Helping Industry and the Environment Prosper”. We align EHS with your overall business objectives to strategically position you for success.  Our unique approach combines our extensive EHS experience with innovative tools, such as our EHS DashboardTM, to effectively address your challenges.  Our comprehensive solutions have resulted in award-winning EHS and overall business performance for our clients. We are certified WBENC, WBE. To learn more visit us at www.capaccio.com.

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.