Compliance, Engineering, and Third-Party Inspections
Call AEEG if you are faced with any Compliance, Engineering, and Third-Party Inspection issues.
MDE Third-Party Underground Storage Tanks and Steel Tank Institute (STI) SP001 Aboveground Storage Tank Inspections
AEEG has the trained and certified personnel to complete underground storage tank (UST) third-party inspections for the Maryland Department of the Environment (MDE) and the District of Columbia Department of Energy and the Environment (DOEE). In addition, we are also certified to complete inspections following the Steel Tank Institute (STI) SP01 Standard for the inspection of shop-fabricated aboveground storage tanks (ASTs). This standard includes safety considerations, periodic and formal internal/external inspections, and the suitability for continued service. This information is also useful in the development of Spill Prevention and Countermeasure Control Plans (SPCC). In addition, we are also well-versed in the new MDE AST regulations effective July 1, 2022. If you are a facility owner, you should be aware of specific deadlines outlined in the new regulations including AST registration requiring SP001 inspections of facility ASTs.
Personnel are proficient in the new MDE regulations under COMAR 26.10.17 for shop-fabricated ASTs. The regulations became effective in July 2022 with implementation dates through October 2023. Under the previous COMAR 26.10 regulations, there were comparatively few requirements for facilities with ASTs with an aggregate oil storage capacity of less than 10,000 gallons (i.e., did not require an individual oil operations permit. The June 13, 2022, rule updates establish new requirements for shop fabricated and field constructed ASTs found at COMAR 26.10.17 and COMAR 26.10.18, respectively. Notable new requirements for shop fabricated ASTs [particularly those requiring action or are more stringent than Spill Prevention, Control, and Countermeasure (SPCC)] regulations include:
1. Registering facilities with an aggregate regulated AST capacity of 2,500 gallons or more by December 13, 2023. ASTs excluded from registration and the requirements described below include those that have a capacity of 250 gallons or less, stores edible oils, and oil-filled operational equipment (e.g., oil-filled transformers and hydraulic elevator reservoirs).
2. STI SP001 INSPECTIONS: Conducting monthly and annual inspections, beginning no later than June 13, 2024. The inspection requirements generally follow the STI Standard for The Inspection of Aboveground Storage Tanks (SP001), with the addition of needing to clean normal and emergency vents during the annual inspections (Note: STI SP001 is typically used as the inspection standard for shop fabricated ASTs).
3. Installing tank gauges (e.g., mechanical level gauge or automatic tank gauge) and a method of release detection (e.g., interstitial monitoring on double-walled ASTs) by June 13, 2024, and completing annual testing of the equipment.
4. Meeting similar requirements to piping for UST systems if the AST system has underground piping.
5. Maintaining records of routine inspections and testing for at least 5 years (note that this is more stringent than the SPCC requirement of maintaining records for at least 3 years). Records of integrity testing, repairs, spills, and other formal reports are required to be maintained for at least 5 years after permanent closure or removal of the AST system.