The client owns and operates a 10,000 gallon aboveground storage tank for vegetable oil at its facility, which was installed in 1988. In accordance with the federal Environmental Protection Agency (EPA) regulations for Oil Spill Prevention, Control, and Countermeasures (SPCC) found in 40 CFR 112, spill containment was required. In addition, in accordance with 502 CMR 5.00, all ASTs greater than 10,000 gallons in capacity are required to undergo an annual inspection by a qualified tank inspector, and tanks over 20 years of age must undergo ultrasonic thickness testing (UTT) for corrosion. A record did not exist of an annual inspection or UTT tank inspection. An API 653 Inspector, a Steel Tank Institute (STi) Certified Inspector, or a Massachusetts Registered Professional Engineer (PE) must conduct the AST inspection. A CAPACCIO registered PE inspected the AST under 502 CMR 5.00, “Permit Requirements and Annual Inspection of Aboveground Storage Tanks or Containers of More Than Ten-Thousand Gallons Capacity.” CAPACCIO submitted the completed forms along with the required fees to the Massachusetts Office of the State Fire Marshall on behalf of the client. CAPACCIO also prepared a draft SPCC, a letter summarizing containment options, and a draft plan of a containment system.


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