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.

Carbon Disclosure Project – Reporting Dates Released Reply

The Carbon Disclosure Project (CDP) is an independent, not-for-profit organization which works to drive greenhouse gas emissions reduction and sustainable water use by business and cities. For those that participate, the CDP has posted its guidelines and dates for carbon, water, and supply chain reporting. The CDP will also be posting information on how to access the Online Response System (ORS) for each of these programs. CAPACCIO will continue to track the CDP for updates and will send along the ORS information as soon as it becomes available.

Carbon Reporting

–          Guidelines available                        January 2012

–          ORS instructions to be sent         early February 2012

–          Reports due                                    May 31, 2012

Water Reporting

–          Guidelines available                       January 2012

–          ORS instructions to be sent         February 2012

–          Reports due                                    June 30, 2012

Supply Chain Reporting

–          Guidelines available                       January 2012

–          ORS instructions to be sent         early April 2012

–          Reports due                                    July 31, 2012

Additional reporting information on each program, as well as past reports, are available on the CDP website: https://www.cdproject.net/

For more information or assistance in preparing reports, please contact Wayne Bates, PhD, PE, at 508.970.0033 ext. 121 or wbates@capaccio.com.

Tier 2 Reporting Update Reply

Tier 2 reports for reporting year 2011 are due by March 1, 2012.  Facilities covered by Emergency Planning and Community Right-to-Know Act Section 312 Hazardous Chemical Inventory Reporting (i.e., Tier 2 reporting) must submit a Tier 2 form to the Local Emergency Planning Committee (LEPC), the State Emergency Response Commission (SERC), and the local fire department annually.

Facility site plans are not required in Massachusetts, but are encouraged by the state and local agencies.  Site plans are required to be submitted with the Tier 2 form in New Hampshire and Rhode Island.

Transportation information including carrier name, the carrier’s emergency contact phone number, as well as routes and frequency of shipment were required on Tier 2 report in Massachusetts starting for reporting year 2010.  The SERC (the Massachusetts Emergency Management Agency) recently released guidance for 2011 Tier 2 reporting.  The guidance clarifies that transportation information is only required for Extremely Hazardous Substances.  http://www.mass.gov/eopss/home-sec-emerg-resp/emergency-info/haz-mat/serc/guidance-to-massachusetts-tier-ii-reporting-entities.pdf

Environmental Protection Agency (EPA) staff in the Spill Prevention Control and Countermeasures (SPCC) program will be reviewing Tier 2 reports.  If a facility has reported oil on the Tier 2 report in an amount that exceeds the threshold required for SPCC, the EPA will be inspecting your facility to ensure that there is an SPCC Plan in place, if it’s required.

Facilities should prepare the 2011 Tier 2 report using the Tier2Submit2011 software.  The zip file should be emailed to the SERC. The SERC urges facilities to properly name their t2s or zip file.  For example, the tier 2 file for Capaccio Environmental Engineering would be labeled CapaccioEnvironmentalEngineering2011Tier2.t2s.  If the facility has multiple locations within the state, name each file name with the facility’s city.  For example, CapaccioEnvironmental-Marlborough2011Tier2.t2s

Contact your LEPC and local fire department to determine whether to submit the 2011 Tier 2 report via email or CD, or paper. As always, early reporting is encouraged.  The majority of submissions are received during the last two weeks of February.  In past years, the SERC has had issues with processing last minute submissions due to the large volume of submissions at the last minute.  CAPACCIO recommends that facilities submit before the last week of February to ensure submissions are processed on time.

Please contact Linda Swift at 508.970.0033 ext. 119 or  lswift@capaccio.com with any questions you may have regarding Tier 2 reporting.

Oh Snow, Where Art Thou? SPCC Winter Update Reply

While the local cross country ski enthusiasts and snowshoers may be a little disappointed at the lack of white stuff this year, I’ll bet the majority of us are wiping our brows in relief.  As I type, I can see the sun’s rays bouncing off the cars in the parking lot giving a glimmer of hope that spring is soon on its way.  But, being a New Englander all my life, I know that winter is likely to rear its ugly head a few times before we see the crocuses make their first appearance. 

During these winter storms, the top priority should be getting walkways and parking areas clean to ensure the safety of employees and visitors. This often puts other important areas like secondary containment for oil tanks at the back of the list, but, in accordance with the Oil Spill Prevention Control and Countermeasures (SPCC) regulations (40 CFR 112), structures used for secondary containment of oil must be kept clean and free of debris including snow and ice.  On several occasions, we have inspected secondary containment structures only to find them full of ice and snow. To prevent this from happening at your facility, secondary containment areas should be cleaned of snow before it has the chance to ice up and become a “drain freeze” during an oil spill.

For more information on SPCC Plans and SPCC compliance, contact Josh Fawson at 508-970-0033 ext. 120 or jfawson@capaccio.com.