From an article in
Environmental Protection Magazine)
There has been a push for more liberal interpretations of
codes to allow thanks with lower testing criteria to be allowed
in more situations due to cost factors
By David Harris |
The
words "aboveground storage tanks" (ASTs) bring different
pictures to mind depending on the individual. While the term AST
generally refers to a wide variety of storage units containing various
fuels and chemicals over a capacity range of 100 gallons to 20 million
gallons, the federal government has defined an AST as any tank with
contents 90 percent or more above the surface of the ground.
Most people are familiar
with ASTs but don't think about them. They are used for heating oil at
homes, by farmers, by fleets (government, utility and private), marinas,
golf courses, universities, fire stations, fuel delivery companies,
airports, oil fields, refineries, storage "tank farms," in
manufacturing and sometimes at retail gas stations. They provide fuel
for backup power at hospitals, emergency buildings, food storage
warehouses, hotels, condos, shopping malls and computer companies. And
this is only a partial list. If you watch, you will probably see several
this week.
This article will not cover
any pressurized tanks; it instead will cover only tanks designed to be
operated at atmospheric or close to atmospheric pressure. Additionally,
only tanks designed for storage of flammable and combustible liquids
such as petroleum fuels are included in this discussion.
In the United States, ASTs
are built and tested according to nationally recognized standards. Let
us divide ASTs into smaller categories according to the testing
standard.
When buying an
AST, check with your insurance company's agents for their input
because -- like them -- you are trying to reduce your liability.
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Field Erected
The largest ASTs are usually
field erected vertical cylindrical tanks and are built according to
American Petroleum Institute (API) Standards 620 or 650. These tanks are
typically used by oil companies (for storing fuel during production,
refining and wholesale distribution) and large industrial users. These
tanks are sometimes referred to as "on ground storage tanks"
because the entire bottom of the unit rests on the ground or foundation.
Sizes are usually measured in barrels (one barrel = 42 gallons) due to
the large capacities. Dikes or berms built around the tank or set of
tanks provide secondary containment (in case of leak or rupture). The
advantage of these systems is the ability for high capacity at the most
reasonable cost.
Vaulted
A vault system, usually
installed below grade, has recently become popular for larger fleet and
retail gas stations. These systems consist of a shop-fabricated steel
tank inside a larger concrete vault, which is assembled on site. The
system is designed so the primary tank can be visually inspected by
entry into the vault and is therefore considered an aboveground tank
even though the tank is not visible to the public. The concrete vault
provides the required secondary containment. These systems are built
according to Underwriter's Laboratories (UL) Standard 2245, Below
Grade Vaults for Flammable Liquid Storage Tanks and usually range in
sizes of 500 to 15,000 gallons. The advantage of these systems is that
tanks do not use up valuable real estate, while certain tax and
environmental liability advantages of aboveground tanks are retained.
Shop Fabricated
The third category contains
the greatest number of tanks and has the widest variety of users. Tank
sizes typically range from 100 to 12,000 gallons, although some
manufacturers may produce up to 50,000 gallons under special
circumstances. These ASTs are usually shop-fabricated, so the reasonable
size is limited by shipping restrictions. They are normally mounted on a
stand or saddle or have built-in supports allowing visual inspection
under the entire unit. Secondary containment on newer units is provided
by a second wall that is an integral part of the system. Installations
may be vertical or horizontal and tanks may be either cylindrical or
rectangular.
The advantages of these
units are ease of installation and flexibility, because the units can be
moved if requirements change. They are also considered to be an asset
instead of a liability to the property. The majority of the owners of
these tanks are only involved in fuel storage, because it is necessary
in the performance of their job or as part of the physical plant
operation. They are not part of a tank owner organization or petroleum
distributor group and have, until recently, largely been ignored by big
oil and federal regulators. Today, tanks in these sizes can be
subdivided according to the following manufacturing standards:
Prepare and
implement a Spill Prevention Control and Countermeasures (SPCC)
plan if required, as the penalty for failure to comply may cost
more than the tank system.
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UL Standard 142 ,
Steel Aboveground Tanks for Flammable and Combustible Liquids;
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UL Standard 2080 ,
Fire Resistant Tanks for Flammable Liquids;
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SwRI 93-01
Testing Requirements for Protected Aboveground Flammable Liquid/Fuel
Storage Tanks; and
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UL Standard 2085 ,
Protected Aboveground Tanks for Flammable and Combustible Liquids.
The Trend
Although incidents involving
large on-ground tanks are more widely reported than smaller tank
incidents due to the catastrophic nature of the event, most fire
jurisdictions had prohibited or greatly restricted the use of shop
fabricated ASTs for many years due to fires involving ASTs. These
prohibitions and restrictions remained in place until the late 1980s
when a UL 142 tank was equipped with integral secondary containment and
encapsulated in six inches of concrete for protection. Marketed under
the trade name of ConVault, it gradually gained acceptance from the fire
prevention officials in California and then across the United States.
During the early 1990s, with U.S. Environmental Protection Agency's
(EPA) December 1998 deadline for owners and operator to upgrade
underground storage tanks looming just a few years away, other tank
manufacturers (over one hundred) began developing systems with varying
methods and levels of environmental and fire protection. In response to
manufacturers and regulators req uests, UL Standard 2085 was promulgated
in December 1994. This document set down manufacturing and testing
standards for the new "Protected" tank design. An alternate
set of criteria for "Fire Resistant" rating was published as
UL Standard 2080 in 1997, which allowed an 800 degree Fahrenheit average
temperature rise (vs. 260 degrees for UL 2085) and did not require any
impact testing. Also in 1997, Southwest Research Institute published
SwRI 97-04, an AST standard that had no maximum temperature limit
criteria for the fire test and required no impact testing.
In 1997,
Southwest Research Institute published SwRI 97-04, an AST
standard that had no maximum temperature limit criteria for the
fire test and required no impact testing.
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What does all this mean to
the average business that needs fuel on-site? An example might be a
business that is inside city limits. Until at least 1986, an aboveground
gas tank probably would not have been allowed, so the owners of the
business had an underground storage tank (UST). When they removed their
leaking tank (and cleaned up the contamination), it was determined that
it was prudent to place the next tank aboveground. If this took place
prior to December 1991, they probably met with considerable opposition
from regulators with their only AST choice being a protected type tank
(although only listed as UL 142) from one of a few closely monitored
manufacturers. By mid-1995 they could quite easily get approval for a UL
2085 listed tank, and by the end of 1998 they could choose from several
listings and over one hundred manufacturers with a range of quality.
Today, these listings are available, although not all are allowed in all
circumstances. The surge of manufacturers that occurred in the mid to
lat e '90s has dwindled due to excess competition in the market, the
number of which is still changing and hard to determine due to buyouts,
companies changing their focus to other products or just going out of
business.
Recently there has been a
push for more liberal interpretations of codes to allow tanks with lower
testing criteria to be allowed in more situations due to cost factors.
Thus, we have seen the pendulum swing from a very critical and
conservative attitude by fire regulators to a quite liberal approval in
less than 15 years. This is partly due to the demand for an answer to
the leaking underground fuel storage tank problem and partly due to the
excellent track record that the new technology of ASTs has compiled
since 1986. The pendulum swing is a broad generalization, but a look at
the overall picture reveals this strong trend.
What to Do
So what should you do if
your business needs to store fuel on-site? My recommendation would be to
buy the highest rated tank you can afford. When buying an AST, check
with your insurance company's agents for their input because -- like
them -- you are trying to reduce your liability. Consider life cycle
cost, not just initial cost, and take a close look at what the warranty
covers. Make sure you include a determination of the strength of the
manufacturer, because a 30-year warranty is only valuable if the company
remains in business for 30 years. Contact your local authority having
jurisdiction (often the local fire marshal) for their input, even though
they usually are not allowed to make formal recommendations. Use your
own common sense. Just because you are allowed to install a UL 142 or
SwRI 93-01 listed tank doesn't reduce the cost of a cleanup.
Make sure that you have all
the proper approvals, and prepare and implement a Spill Prevention
Control and Countermeasures (SPCC) plan if required, as the penalty for
failure to comply may cost more than the tank system. Consider that the
"approval pendulum" will probably swing more conservative
again some day. And lastly, accidents happen -- but if you can prevent a
spill and/or fire catastrophe, it is not only good for the pocketbook,
it is good for the entire community.
I have only touched on
standards for historical purposes. More information on standards and
fire codes as well as some discussion of federal and state government
regulations will be presented in a later article.
e-sources
Most reputable tank
manufacturers now have Web sites where you can become more familiar with
their products. Their URL's can be found by looking up the manufacturer
by name on the Petroleum Equipment Institute's Web site at www.pei.org/search/
(use Internet Explorer). Links to regulatory organization, listing
organization and petroleum related organization Web sites can be found
at www.convault.com/links3.html.
For Underwriter's Laboratories go to www.ul.com
and for SPCC information go to www.epa.gov/oilspill/spcc/index.htm.
David P. Harris is an engineer and vice president of marketing with
Convault
Inc. The author can be reached via e-mail at dave@convault.com.
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