Aboveground Storage Tanks. . . Things You Should Know
By Douglas Graham, CHMM, Sr. Compliance Advisor & Training Coordinator
Storage of oils and/or hazardous materials (OHM) in aboveground storage tanks has certain advantages over underground storage. Ease of monitoring and inspection through visual contact without the need of remote electronic leak detection and testing equipment is one big advantage. Any facility or EHS Manager who has lived through a leaking underground storage tank ordeal, with all its remediation costs and compliance headaches, can testify to the comfort they feel when glancing over at their AST installation.
With those ASTs however, there remain numerous compliance standards that impact both new and existing installations. Rarely do we see such a collision of both environmental and safety requirements coming from all three levels of governmental oversight- federal, state and municipal, as we do when storing those OHMs in bulk tanks on top of good old terra firma.
I like to think of bulk AST storage compliance in six categories-
2. Permitting and Registration
3. Spill prevention
4. Spill response
5. Tank integrity; and
6. Hazard communication
Installation requirements are very much driven by the actual type of material to be stored in the AST. Installations for materials that present a fire hazard, such as liquefied oxygen, propane, and flammable and combustible liquids must meet very specific fire safety design and installation specifications. The National Fire Protection Association (NFPA) is the primary source of those spec-based standards (e.g., NFPA 58 for propane, NFPA 30 for flammable liquid). Industry standards may also exist for the specific tank type, for example the steel tank institute- STI standards.
Permitting and Registration-
The government agency to which an AST installation permit application is submitted is highly variable depending on where a facility is located. Permitting is the domain of either the state and/or the municipality and may require permit renewals at regular renewals, often annually. By far the most common permitting for an AST is through the local fire department.
Spill prevention techniques may include methods such as overfill protection (e.g., alarms, overflow tanks), monitoring, and/or release prevention barrier, i.e., secondary containment. One or more methods may be mandated through specific regulation or may be driven by plain old common sense. The two most common spill prevention mandates appear in the hazardous waste (RCRA) regulations and the Clean Water Act. Spill Prevention Control and Countermeasures (SPCC) planning requirements under the federal Clean Water Act require that certain facilities develop plans to minimize the risks of releases of oil from bulk storage units to surface waters. Additionally, Hazardous waste generators are required to minimize the risk of a release of hazardous wastes that could threaten human health or the environment and may need to develop specific procedures in their contingency plan.
Releases of hazardous materials may trigger numerous regulatory reporting requirements. Releases may threaten individuals' safety, the general public, the environment, or property. There's hardly a local, state or federal agency that isn't interested in being notified in the event of a significant release of oil or hazardous materials from an AST, however the actual reporting triggers are highly specific and variable upon circumstance. All such requirements should be researched ahead of time, so that notifications can be made promptly. Additionally, actual spill response activities that must be implemented to mitigate the release are just as variable. With any releases from ASTs, remember your priorities- protect people first, the environment second, and property third.
Tank integrity is about having a system in place to ensure an AST installation (tank and associated piping) is in good working condition and not at risk of failure due to corrosion or other factors. The two primary methods are regular visual inspection and tightness testing. Either or both methods may be mandated, as with SPCC plans and hazardous waste tanks, or may be implemented as a best management practice. Individual testing methods and frequencies are dependent upon the tank type and construction. One commonly cited standard is Steel Tank Institute Standard SP001.
Communicating the hazards related to the contents of an AST is required per OSHA's HazComm standard, but potentially even more important for emergency response. ASTs should be marked with the contents and hazard. Because emergency responders are trained to recognize and reference DOT shipping names and identification numbers, it's helpful to reference these on the AST, for example, "Diesel Fuel, NA1993", in characters large enough to be seen from a distance. Additionally, fire-fighter are trained specifically in the recognition of the familiar numbered four-color NFPA warning placard- these should also be used- see NFPA standard 704 for rules of use.