Aboveground Tank Inspections in Massachusetts

Facilities in Massachusetts can prevent the risk of oil spills and minimize the loss of fuel due to leaks in aboveground storage tanks by conducting regular inspections. Tanks that have a storage capacity of less than 10,000-gallons are not required to have annual inspections but facilities are required to follow the Spill Prevention, Control and Countermeasure Plan (SPCC) Plan they have developed. If a repair of the tank is made then an integrity test is required. 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.
Failure to follow SPCC Plans can negate insurance coverage. Your facilities insurance coverage may be at risk if you have a spill and do not have the proper records of inspection.

If you own an aboveground tank that is larger than 10,000-gallon capacity and are storing liquids other than water, you are required by Massachusetts 502 CMR 5.00 to have your tank inspected annually. Massachusetts’s regulations refer to API 653 for the frequency of self-inspections, which is classified as “routine” but should not exceed one month. CommTank recommends that the staff at the storage tank facility conduct monthly inspections and an informal walk-through inspection to be conducted daily. The person that conducts the monthly inspection must be knowledgeable about tank components, operation and spill prevention. For a thorough inspection the inspector should follow these steps:

• Use a checklist such as AST Facility Inspection Form found on most state web sites or this Monthly Inspection Checklist provided by the Steel Tank Institute.
• Fill out the form and note conditions of the tank and piping, and initial and date the form.
• Follow up on findings. Report significant issues to management and fix deficiencies.

Documentation for a regulated aboveground storage tank needs to be available for review by the Massachusetts Fire Marshall at all times. The facility is required to keep all inspection, maintenance and repair records for 5-years beyond the demolition of a regulated tank.

Monthly Aboveground Storage Tank Inspection Checklist

• Keep facilities clean and free of unnecessary items because clutter would hinder clean up in the event of a leak or spill.
• Ensure all safety equipment is in place and all safety precautions are followed

1. Fire extinguishers
2. No smoking signs
3. Warning and danger signs

• Verify sound security measures are in place to prevent vandalism

1. Intact fence with a locking gate.
2. Adequate lighting for worker safety and to deter intruders.

• Maintain storage tanks including day tanks. Larger storage tanks should be maintained properly. These items are important components to check:

1. Vents: Make sure they are clear of obstructions and in good working order. Check for insect nests or snow and ice.
2. Gauges and overfill devices: Shutoff devices and overfill alarms must be tested and check that gauges are reading accurately. 
3. Paint: The elements can increase tank corrosion and the paint coating is important to maintain. Make note of any chipping and blistering, repair and recoat as necessary
4. Corrosion Protection: Check welds on the sides and bottom. Make sure the cathodic protection has sufficient metal left or the electricity is flowing to impressed current systems. 
5. Soundness: Check for staining around the tank bottom or on seams or welds.
6. Tank Signs: All tanks must be labeled with the storage capacity, product type and the flammability or combustibility of the product must be indicated.
7. Foundation: The tank must be corrosion free where it meets the foundation. Check beams for cracks and signs of rot. Ensure the concrete is in good condition.

• Piping and Hoses: leaks are commonly found in poorly maintained pipes. Make sure to check:

1. Valves: This is the number one source of pipe leaks. Check that the valves turn properly and seat without resistance. Verify that the valves stop the flow of fuel and can be locked or secured.
2. Nozzles: Inspect for evidence of rust and or leaks around the nozzles.
3. Supports: Check for signs of rot or rust on pipe supports. Insufficient supports can cause cracking of pipes.
4. Coating, paint, and wraps: Wear and chipping can expose piping to the elements. Check for signs of rust.
5. Corrosion protection: Ensure the proper amount of current is flowing to impressed current systems and there is sufficient metal on sacrificial anodes.
6. Soundness: Look for visible stains around pipes and hoses. Check for drips under valve connections and filters.

• Secondary containment: The ability of secondary containment to hold any product during a spill is critical. Check these factors:

1. Size: Containment must hold 110% of the storage tanks capacity.
2. Dry and Clean: Any unwanted material in the containment would reduce the capacity of the tank. Remove water, ice, or vegetation in the secondary containment.
3. Liner: If a liner is not sound it will not hold spilled oil or gas. Verify the liner is in good condition and there are no openings that can’t be plugged.

• Spill Preventions and Response: You can reduce environmental damage and save money by preparing for an oil spill. Here are the items you will need:

1. Response Plan: Operators and workers should be trained in how to deal with emergencies. Response plans must be posted in each area that contains fuel.
2. Responses Equipment: Facility operators should know how to use oil spill response equipment and where it is located. Locate equipment near the storage tanks in good working condition?

Annual Inspection Requirements for Aboveground Storage Tanks

Massachusetts regulations require that all regulated aboveground storage tanks (subject to the requirements of 502 C.M.R. 5.00) have an Use Permit issued by the State Fire Marshal and be inspected annually by a certified inspector. During the inspection, the inspector will list any abnormalities or deficiencies noticed. After the inspection a report is produced that will recommend corrections to any problems that may exist. Use Permits expire every five years at which time a thorough inspection utilizing techniques such as visual, internal inspections, ultrasonic thickness inspections, and certified integrity inspections are performed. 

The American Petroleum Institute (API) Standard 653,“Tank Inspection, Repair, Alteration, and Reconstruction” and the Steel Tank Institute (STI) “SP001 Standard for the Inspection of Aboveground Storage Tanks” (STI SP001) are two commonly used inspection standards for aboveground storage tanks larger than 10,000-gallons.

About the Author: Dan Hoag

Dan Hoag has worked in the environmental and tank storage industry for 16 years. Dan’s range of expertise includes designing systems for oil spill clean-ups, treating soil contamination through "in situ" oxidation and testing, and inspecting underground storage tank systems. As head of Marketing and Information Technologies at CommTank, Dan draws from field experience to write about fuel, water and chemical storage technologies, and the regulations that affect them. He has developed training courses in home inspection, underground storage tank operator, ultrasonic thickness and tank tightness testing. Over the past decade, Dan has published over 60 articles about industry trends and has documented commercial, residential, and environmental projects through illustration, videos, and photography. When Dan unplugs from technology, he spends his time backyard farming, hiking, and kayaking, while masquerading as a hockey player during the wee hours of the morning.