Item 6 - Safety compliance regulatory standardsYou have asked me to provide information as to our safety compliance regulatory
standards. I wanted to provide that to you in an organized fashion, since the primary
federal regulation incorporates several trade and industry standards.
PHMSA (Pipeline Hazardous Materials Safety Administration under the Department of
Transportation) regulates pipelines and pipeline facilities, which includes storage tank
design, construction, and safety. You can view the entire PHMSA title here: 49 CFR 195
– PHMSA. 49 CFR Part 195.3 incorporates by reference certain American Petroleum
Institute (API) Standards and Recommended Practices, as well as American Society of
Mechanical Engineers (ASME) codes and standards. To help narrow it down I’ve provided
a list of certain codes that pertain specifically to storage tanks. In particular here, API 650
Standards govern design and construction of above ground storage tanks.
The following PHMSA Codes and API Standards & Recommended Practice Sections
apply:
Standard Topic
49 CFR 195.132 (specifically subsection (b)(3)) Design and Construction of Aboveground
Breakout Tanks
API Standards – 650 (49 CFR 195.3(b)(18)) Welded Tanks for Oil Storage
API Standards – 653 (49 CFR 195.3(b)(19)) Tank Inspection, Repair, Alteration, and
Reconstruction
ANSI/API Recommended Practice 651 (49 CFR
195.3(b)(5))
Cathodic Protection of Aboveground Storage
Tanks
ANSI/API Recommended Practice 652 (49 CFR
195.3(b)(6))
Linings of Aboveground Petroleum Storage
Tank Bottoms
API Recommended Practice 2003 (49 CFR
195.3(b)(11))
Protection against Ignitions Arising out of Static,
Lightning, and Stray Currents
API Recommended Practice 2350 (49 CFR
195.3(b)(12))
Overfill Protection for Storage Tanks in Petroleum
Facilities
API Specification 12F (49 CFR 195.3(b)(15)) Specification for Shop Welded Tanks for Storage
of Production Liquids
API Standard 620 (49 CFR 195.3(b)(17)) Design and Construction of Large, Welded, Low-
Pressure Storage Tanks
ANSI/API Standard 2000 (49 CFR 195.3(b)(21)) Venting Atmospheric and Low-pressure Storage
Tanks
We have a number of people within our organization who focus on Department of
Transportation and Regulatory Compliance, as well as tank integrity and maintenance.
Additionally, our storage tanks are monitored by SCADA systems. This list is not
exhaustive – PHMSA also incorporates several codes from the American Society of
Mechanical Engineers (49 CFR 195.3(c)(5-7)); The standards set by both API and ASME
are subject to change and ongoing legislative review. However, I believe the sections
cited above more directly address your question regarding construction and safety.
I hope this is helpful… Please let me know if I can provide any additional information
and/or answer any questions you and your team may have.
Have a good afternoon.
-Helen
Helen M. Callahan
Corporate Counsel