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Aboveground storage tanks (ASTs) have many different uses across industries, but regulation of them (including the very definition of them) is somewhat piecemeal at the federal level. Unlike underground storage tanks (USTs), which have their own set of regulations, requirements for ASTs depend on their usage. Depending on the function of the tank, rules enforced by the Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) may apply.
Most regulations concerning ASTs are at the state level, so facilities must be sure to consult state and local agencies and regulations to ensure compliance with any unique rules regarding storage, labeling, recordkeeping, registration, and/or training. At the federal level, it is necessary to look in several different places for requirements that apply to ASTs, dependent on their function.
Regulations under the Resource Conservation and Recovery Act (RCRA) at 40 CFR 260 through 268 govern the storage of hazardous waste, including any hazardous waste stored in ASTs.
ASTs that hold oils of any kind may be subject to EPA’s Spill Prevention, Control, and Countermeasure (SPCC) regulation at 40 CFR Part 112. Note that this SPCC regulation does not specifically use the term AST, but rather includes ASTs under the term “bulk storage container.” OSHA’s flammable liquids standard at 29 CFR 1910.106 covers specific requirements for ASTs storing flammable or combustible liquids.
Because of the patchwork nature of federal regulation surrounding ASTs, the requirements for a given facility are highly dependent on the specific purpose(s) for that facility’s ASTs. Here are the primary requirements for common uses: