FMS State wide AST Replacement SOW rev 2.pdf

SOW Acceptance Form Under $25,000

Project_________________________________________ Project Number:__________

Location:_______________________________________ Facility Number:__________

Problem // Issue Description

Scope of Work:

POC Name/Email/Phone:_______________________________________

Initial Qualifications: ________________________________________

Estimated Project Cost: ______________

Environmental State Quartermaster (If State-Share) CFMO Approved

Approve Approve Approve

Hold Hold Hold

*Share with Chief Procurement officer for Review.

ASSOCIATED FINDINGS :

SUMMARY:

Waste oil gauge is not in working condition

DETAILS:

The waste oil tank onsite has a gauge to read the vacuum pressure of the interstitial space of the double walled bowser. The gauge is cloudy making it hard to read and the tank is not holding the correct pressure.

REQUIREMENTS:

Hazardous waste tank systems must meet secondary containment requirements.

REGULATORY CITATION:

310 CMR 30.694(1)

EPAS CODE: ST.115.12.MA

CLASS: Class I

PREVIOUS FINDING: NO PREVIOUS REGULATORY ACTION: NO

ROOT CAUSE:4.5.3

JUSTIFICATION:

Statewide issues with the waste oil bowsers have been identified and they are all beyond their life expectancy. The FMO office has been made aware of the failing parts on the bowsers.

Implement and/or maintain procedures for investigating nonconformance and taking corrective and preventive action.

ENVIRONMENTAL THREAT: POSSIBLE

IMPACT ON READINESS: UNLIKELY

REOCCURING ISSUE: Recurring finding in this state REGULATORY ACTION: Action likely in the event of regulatory inspection

RATING: Medium

SITE: WORCESTER SKLYINE DRIVE PROTOCOL: Storage Tank OpenICAP STATUS:FMS SPACE WORCESTER

SKYLINE DRIVE

BLDG NAME:

RESPONSIBLE PARTY: FMO ICAP STATUS DATE: 09/13/2022

Elizabeth WilderCREATED BY:

250NG-025966-00000L0001ID:

OWNERSHIP: DOD Owned

LAST EDITED BY: Elizabeth Wilder

REFERENCE: MA-0513 DATE ASSESSED: 05/25/2022

FOR OFFICIAL USE ONLYMA-0513 Page 4 of 7

FOR OFFICIAL USE ONLY

FINDING DETAIL

04 April 2024

MA - ARMY NATIONAL GUARD

NOTES:

PREVIOUS FINDING INFO:

COMPLIANCE CORRECTIVE ACTION:

ROOT CAUSE CORRECTIVE ACTION:

FOR OFFICIAL USE ONLYMA-0513 Page 5 of 7

FOR OFFICIAL USE ONLY

FINDING DETAIL

SQG hazardous waste storage tanks do not meet operational requirements.

DETAILS:

The secondary containment does not indicate the proper negative pressure within the interstical space of both waste oil bowsers; the vacuum gauge should read approximatley 41 kPA and is currently reading at 0 kPA.

Site personnel state that they are manually checking the dipstick between the two tank walls and ensuring there is not a leak.

REQUIREMENTS:

SQGs must comply with certain storage tank requirements.

REGULATORY CITATION:

40 CFR 262.16(b)(3)(ii) through 262.16(b)(3)(iv) and 262.16(b)(6)(ii)

EPAS CODE: ST.100.01.US

CLASS: Class I

PREVIOUS FINDING: YES PREVIOUS REGULATORY ACTION: NO

ROOT CAUSE:4.4.1

JUSTIFICATION:

FMO needs to provide the financial resources to fix the interstitial space.

Provide resources essential for environmental management.

ENVIRONMENTAL THREAT: POSSIBLE

IMPACT ON READINESS: UNLIKELY

REOCCURING ISSUE: Recurring finding in this state REGULATORY ACTION: Action likely in the event of regulatory inspection

RATING: Medium

SITE: MTA CAMP CURTIS GUILD PROTOCOL: Storage Tank OpenICAP STATUS:FIELD MAINTENANCE SHOP

READING

BLDG NAME:

RESPONSIBLE PARTY: ICAP STATUS DATE: 09/13/2021

Elizabeth WilderCREATED BY:

250NG-025C50-00000L0009ID:

OWNERSHIP: State Owned

LAST EDITED BY: Elizabeth Wilder

REFERENCE: MA-0504 DATE ASSESSED: 07/22/2021

FOR OFFICIAL USE ONLYMA-0504 Page 24 of 54

FOR OFFICIAL USE ONLY

FINDING DETAIL

STATUS NAME DATE NOTES

Open Wilder, Elizabeth 09/19/2022 6/1/2022 it was noted that the guage still had not been fixed since the last site visit. Shop personnel still have to check the interstitial space manually on the tank.

PREVIOUS FINDING INFO:

COMPLIANCE CORRECTIVE ACTION:

ROOT CAUSE CORRECTIVE ACTION:

FOR OFFICIAL USE ONLYMA-0504 Page 25 of 54

FOR OFFICIAL USE ONLY

FINDING DETAIL

Untitled

Waste oil gauge is not in working condition

DETAILS:

The waste oil tank onsite has a gauge to read the vacuum pressure of the interstitial space of the double walled bowser. The gauge is cloudy making it hard to read and the tank is not holding the correct pressure.

REQUIREMENTS:

Hazardous waste tank systems must meet secondary containment requirements.

REGULATORY CITATION:

310 CMR 30.694(1)

EPAS CODE: ST.115.12.MA

CLASS: Class I

PREVIOUS FINDING: NO PREVIOUS REGULATORY ACTION: NO

ROOT CAUSE:4.5.3

JUSTIFICATION:

Statewide issues with the waste oil bowsers have been identified and they are all beyond their life expectancy. The FMO office has been made aware of the failing parts on the bowsers.

Implement and/or maintain procedures for investigating nonconformance and taking corrective and preventive action.

ENVIRONMENTAL THREAT: POSSIBLE

IMPACT ON READINESS: UNLIKELY

REOCCURING ISSUE: Recurring finding in this state REGULATORY ACTION: Action likely in the event of regulatory inspection

RATING: Medium

SITE: WORCESTER SKLYINE DRIVE PROTOCOL: Storage Tank OpenICAP STATUS:FMS SPACE WORCESTER

SKYLINE DRIVE

BLDG NAME:

RESPONSIBLE PARTY: FMO ICAP STATUS DATE: 09/13/2022

Elizabeth WilderCREATED BY:

250NG-025966-00000L0001ID:

OWNERSHIP: DOD Owned

LAST EDITED BY: Elizabeth Wilder

REFERENCE: MA-0513 DATE ASSESSED: 05/25/2022

FOR OFFICIAL USE ONLYMA-0513 Page 4 of 7

FOR OFFICIAL USE ONLY

FINDING DETAIL

COMPLIANCE CORRECTIVE ACTION:

ROOT CAUSE CORRECTIVE ACTION:

FOR OFFICIAL USE ONLYMA-0513 Page 5 of 7

MA (3 findings)

WORCESTER SKLYINE DRIVE (250NG-025966-00000L0001)

MA-0494 [05/07/2021] (I)

MA-0513 [05/25/2022] (I)

MA-0514 [05/25/2022] (I)

SQG hazardous waste storage tanks do not meet operational requirements.

DETAILS:

The secondary containment does not indicate the proper negative pressure within the interstical space of both waste oil bowsers; the vacuum gauge should read approximatley 41 kPA and is currently reading at 0 kPA.

Site personnel state that they are manually checking the dipstick between the two tank walls and ensuring there is not a leak.

REQUIREMENTS:

SQGs must comply with certain storage tank requirements.

REGULATORY CITATION:

40 CFR 262.16(b)(3)(ii) through 262.16(b)(3)(iv) and 262.16(b)(6)(ii)

EPAS CODE: ST.100.01.US

CLASS: Class I

PREVIOUS FINDING: YES PREVIOUS REGULATORY ACTION: NO

ROOT CAUSE:4.4.1

JUSTIFICATION:

FMO needs to provide the financial resources to fix the interstitial space.

Provide resources essential for environmental management.

ENVIRONMENTAL THREAT: POSSIBLE

IMPACT ON READINESS: UNLIKELY

REOCCURING ISSUE: Recurring finding in this state REGULATORY ACTION: Action likely in the event of regulatory inspection

RATING: Medium

SITE: MTA CAMP CURTIS GUILD PROTOCOL: Storage Tank OpenICAP STATUS:FIELD MAINTENANCE SHOP

READING

BLDG NAME:

RESPONSIBLE PARTY: ICAP STATUS DATE: 09/13/2021

Elizabeth WilderCREATED BY:

250NG-025C50-00000L0009ID:

OWNERSHIP: State Owned

LAST EDITED BY: Elizabeth Wilder

REFERENCE: MA-0504 DATE ASSESSED: 07/22/2021

FOR OFFICIAL USE ONLYMA-0504 Page 24 of 54

STATUS NAME DATE NOTES

Open Wilder, Elizabeth 09/19/2022 6/1/2022 it was noted that the guage still had not been fixed since the last site visit. Shop personnel still have to check the interstitial space manually on the tank.

COMPLIANCE CORRECTIVE ACTION:

ROOT CAUSE CORRECTIVE ACTION:

FOR OFFICIAL USE ONLYMA-0504 Page 25 of 54

Reading FMS: Request for Work of installing two new 396 gallon waste oil AST (above storage tank) and replace pump stations if needed to the FMS facility. The contractor shall decommission and dispose of existing tank, select piping, and oily solids IAW 310 CMR 30.00. Contractor shall install a new AST and components as needed that is matching to existing Meyers tank brand and shall be equal to existing footprint. Contractor shall procure and install one Myers Medium Duty 396 gl/2,000 L. AST. Replacement shall include funnel and pumping station. The tank shall follow State Fire Regulation for Waste Oil Tanks 527 CMR 9.06. Work is to also include all electrical hook ups and permitting if needed. Customer will pump down tank prior to AST removal. Remaining residual will be the awarded contractor's responsibility to remove.

Framingham FMS: Request for Work of installing a single new 396 gallon waste oil AST (above storage tank) and replace pump station if needed to the FMS facility. The contractor shall decommission and dispose of existing tank, select piping, and oily solids IAW 310 CMR 30.00. Contractor shall install a new AST and components as needed that is matching to existing Meyers tank brand and shall be equal to existing footprint. Contractor shall procure and install one Myers Medium Duty 396 gl/2,000 L AST. Replacement shall include funnel and pumping station. The tank shall follow State Fire Regulation for Waste Oil Tanks 527 CMR 9.06. Work is to also include all electrical hook ups and permitting if needed. Customer will pump down tank prior to AST removal. Remaining residual will be the awarded contractor's responsibility to remove.

All Work at each location shall be completed within normal business hours, Monday through Friday 0800-1600. Awarded Contractor shall proved a schedule for each location. Schedule will be in PDF format.