Department Editor: Scott Jenkins

he ultimate objective of storing liquid, fluid and gaseous products, which may be corrosive, flammable or unstable, is to store material in an environmentally safe and economically viable manner. Storage tanks in the chemical process industries (CPI) can be most broadly divided into those buried underground, and those constructed aboveground. The following is an outline of considerations associated with each category and positive and negative aspects of each. Also included are potentially applicable regulations and codes from the U.S. Environmental Protection Agency (EPA), the Occupational Health and Safety Administration (OSHA) and others.

Aboveground and underground storage tanks

RegulAtions And codes potentiAlly ApplicAble to ust And Ast Regulation name Resource Conservation and Recovery Act Subtitle C hazardous waste regulations Spill Prevention, Control and Countermeasures within Clear Air Act amendments of 1990 Hazardous Waste Operations and Emergency Response Regulations 29 CFR 1910.120 Flammable and Combustible Liquids Standard 29 CFR 1910.106 Hazard Communication Standard 29 CFR 1910.1200 Confined Space Safety Standard 29 CFR 1910.146 Oil Pollution Act of of 1990 National Pollutant Discharge Elimination System Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Benzene 29 CFR 1910.1028 Process Safety Management of Highly Hazardous Chemicals, Explosives and Blasting Agents 29 CFR 1910.119 Resource Conservation and Recovery Act Subtitle I regulations addressing USTs storing petroleum and hazardous substances 40 CFR 280 Stage II Vapor Recovery Regulations established in Clean Air Act Amendments of 1990 Clean Air Act Title V operating permits Emergency planning and Community Right-to-know Act Title III of Superfund Amendments and Reauthorization Act. National Fire Protection Association NFPA 30 (Flammable and Combustible Liquids Code) International Code Council (ICC) International Fire Code Applicability AST and UST AST and UST AST and UST AST and UST AST and UST AST and UST AST only AST only AST only AST only AST only UST only Governing Body EPA EPA OSHA OSHA OSHA OSHA EPA EPA EPA OSHA OSHA EPA

UnderGroUnd SToraGe Tank (UST) advanTaGeS

Physical safety USTs are out of the way of automobile traffic Fire safety With a relatively constant underground temperature, USTs have superior vapor suppression and fire protection for flammable and volatile contents, as well as a reduced need for fire hazard permits Security The American Petroleum Institute has shown that vandalism is a leading cause of tank failures. USTs are less subject to vandalism and easier to protect Aesthetics USTs are out of sight, which eliminates a possible public objection Land use USTs offer a more efficient use of land space and allow more flexibility in placement location

UST only UST only UST only AST and UST AST and UST

EPA EPA EPA NFPA code ICC code

UST diSadvanTaGeS
Leak detection and containment Leak monitoring, detection and containment is more difficult and more expensive underground Installation complexity and cost Excavation and special backfill materials add costs Depreciation Real estate depreciation is possible due to threat of contamination

aST diSadvanTaGeS
Physical safety ASTs are more vulnerable to vandalism, contact with automobiles and external damage Fire safety ASTs have an elevated fire risk relative to USTs Aesthetics ASTs may be objectionable in certain locations Space use more real estate required to house ASTs Temperature variation ASTs experience greater ambient-product-temperature fluctuations than USTs

and federal requirements. Regulatory frameworks are different for AST and UST Space Space requirements to separate an AST from traffic, buildings, property lines, present and future can be significant, while they are not an issue for USTs. Fire codes generally dictate separation distances Security Protection from vandalism is more difficult for ASTs Cost Several aspects of cost should be considered, including: storage tank, tank system equipment, initial installation cost, ongoing maintenance cost, security cost, land cost, regulatory cost and secondary containment cost References:
1. Geyer, W.B. To Bury or Not to Bury: Steel Tank Technology Decisions. In: Handbook of Storage Tank Systems, Marcel Dekker, New York, 2000. 2. Cheremisinoff, P.N., and Vallamar, O. Aboveground and Underground Storage Tank Comparison. In: Storage Tanks. Advances in Environmental Control Technology Series, Gulf Publishing, Houston, 1996.

aboveGroUnd SToraGe Tank (aST) advanTaGeS

Construction ASTs are simpler and less expensive to construct and install. One significant aspect eliminated is the need for excavation and special backfill materials Maintenance Visual inspection is possible, which leads to more reliable leak detection and easier repair Insurance Lower pollution insurance premiums because of reduced risk of groundwater contamination Regulatory burden ASTs are subject to less regulatory requirements than USTs Costs ASTs have lower monitoring and record-keeping costs

MakinG The ChoiCe

When making decisions about whether to use an AST or a UST, consider the following: Regulatory The local authority in the area where the tank system will be assembled has control of whether a tank permit will be issued, based on whether plans for the tank comply with local, state