November 8, 2017
“Following the Great Molasses Flood in Boston’s North End on January 15, 1919, Massachusetts began regulating aboveground storage tanks (AST’s) greater than 10,000 gallons storing any fluid other than water. The molasses flood killed 21 people and injured 150 more. Many claim you can still smell the molasses in the North End on hot summer days.” – MA Department of Fire Services Website (http://www.mass.gov/eopss/agencies/dfs/osfm/fire-prev/aboveground-storage-tanks.html)
On June 1, 2001, the Massachusetts Office of the State Fire Marshal (OSFM) required the annual inspection of certain aboveground storage tanks (ASTs) in Massachusetts, specifically ASTs containing greater than 10,000 gallons of liquid “other than water”, pursuant to 502 CMR 5.06. OSFM amended the regulation in 2015, resulting in two significant changes:
- Prior to 2016, the OSFM required annual inspections and renewal of a Use Permit under 502 CMR 5.06. Starting in 2016, the requirement for submitting the application for a Use Permit was changed from annual to pentannual, or every 5 years.
- As part of the 5-year Use Permit renewal, a “Qualified Tank Inspector must certify, on a form prescribed by the Marshal, that the Qualified Tank Inspector has verified the inspections required under the Approved Standard have been completed, such as, but not limited to: visual, internal inspections, ultrasonic thickness inspections, and certified integrity inspections”.
The key component of the second change is the addition of the verification, by a Qualified Tank Inspector, that inspections have been completed as required under the “Approved Standard”. According to 502 CMR 5.03:
Approved Standard. A technical standard that has been proposed by the tank owner and approved by the Marshal, which establishes the ongoing inspection, maintenance and record keeping practices required to be followed for the life of the tank. Such standard is based upon the type, design and usage of the particular aboveground storage tank regulated by 502 CMR 5.00 and is usually a standard that has been adopted by a nationally recognized standardization body.
502 CMR 5.00 applies broadly to any AST containing liquid “other than water”. For ASTs containing petroleum products, there is, in most cases, an established industry standard:
- Shop-built tanks (ie. UL-142) and small field erected tanks up to 50,000-gallon capacity can be inspected using STI SP001: Standard for the Inspection of Aboveground Storage Tanks.
- Field-erected tanks (welded or riveted) can be inspected using API 653 – Tank Inspection, Repair, Alteration and Reconstruction
- Pressure vessels, such as propane tanks, can be inspected using API 510 – Pressure Vessel Inspection Code
However, these standards may not be suitable for tanks containing all petroleum products. For example, ASTs containing heated products, such as asphalt cement (AC) and waxes, do not have a directly applicable inspection standard; in these cases, a hybrid inspection program should be developed, and will require specific approval from OSFM. OSFM is expecting that owners will continue to inspect tanks using an industry approved standard, or in the absence of an approved standard, submit a proposed inspection program for approval. In 2021, OSFM will provide the form that will be used to confirm that an “approved standard” has been used for inspecting each tank.
Ultimately, it is the responsibility of the owner to determine which standard is applicable to their tanks, and to perform the inspections on the frequency prescribed in the standard. The standard should be selected in 2017, and once selected, the standard will apply for the life of the tank. It is important to note that EVERY storage tank that is subject to the EPA’s SPCC rule, e.g. any bulk storage tank containing oil with a capacity greater than or equal to 55 gallons, MUST have an inspection program based upon an industry standard, or an alternative program certified by a Professional Engineer.
Compliance with the OSFM Use Permit and Federal SPCC requirements is a continuous effort. ATC can help you develop pragmatic maintenance and compliance programs for your AST systems, including routine inspections. Please feel free to contact us if you have any questions regarding your storage tank compliance.
 It should be noted that several states have specifically exempted tanks containing AC and waxes from some or all inspection requirements. For example, Pennsylvania does not require inspection of asphalt cement or wax tanks as these products are not listed as regulated substances, though asphalt emulsion tanks are regulated; Minnesota requires field erected tanks containing asphalt to have an external inspection by an API 653 certified inspector every 5 years, but exempts these tanks from the internal inspection requirements of API 653. Work is currently underway at both API and STI, as well as industry groups such as the National Asphalt Pavement Association (NAPA), to develop appropriate, risk based standards for tanks containing heated products.
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