Special Topics in Environmental Management

The DOT and OSHA Rules That Regulate Your ASTs

DOT – Natural Gas Storage Tanks

DOT’s liquefied natural gas (LNG) facility safety standards govern natural gas storage tanks at facilities used in the transportation of gas by pipeline.

DOT – Pipeline Breakout Tanks

DOT’s hazardous liquid pipeline safety regulations cover ASTs known as pipeline breakout tanks. The standards apply to the design, construction, and testing of new tanks, and the repairs, alterations, and replacement of existing tanks. All new and existing breakout tanks are also subject to the operation and maintenance requirements specified in 49 CFR 193. The incorporation by reference of these 13 standards will significantly improve the minimum level of safety applicable to the transportation and storage of petroleum and petroleum products at breakout tanks throughout the United States.

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DOT – Field-Erected Tanks

Field-erected steel tanks are constructed of steel plates by final assembly on-site at a facility and are generally larger than a 50,000-gal design capacity. Most field-erected steel ASTs must be internally and externally inspected on a routine basis and repaired, if necessary, to ensure tank integrity and to prevent leaks, spills, and ruptures. An inspector certified by the American Petroleum Institute (API) must perform each inspection in accordance with API Standard 653, "Tank Inspection, Repair, Alternation, and Reconstruction."

Some field-erected steel tanks may be exempt or partially exempt from inspection by the applicable permit or rules. For example, tanks that do not contain either petroleum products or hazardous materials (49 CFR 172.101) and are not located at a major facility need not be inspected.

Field-erected tanks at major facilities are initially inspected according to the schedule contained in the facility permit. These inspections must be performed by a certified API 653 inspector. Most field-erected tanks must be externally inspected every 5 years and internally

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OSHA – Flammable Liquids

OSHA’s flammable liquids rules provide design and construction standards for tanks that will hold flammable liquids. It details materials that must be used in the construction of these tanks, minimum spacing distances between the tanks, criteria for constructing tank supports and foundations, and tank testing requirements that must be met before the tanks can be filled.

The primary basis of the OSHA rules for flammable liquids is the National Fire Prevention Association (NFPA) 30 industry standard, Flammable and Combustible Liquids Code. This standard applies to the handling, storage, and use of flammable and combustible liquids with a flash point below 200ºF. There are two primary hazards associated with flammable and combustible liquids: explosion and fire. In order to prevent these hazards, the regulations also address tank ventilation, ignition sources, and storage requirements.

Remember that these are the federal programs that regulate ASTs; there may also be local requirements imposed by state and local authorities.

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