Oil Tank Farms: What We Should Know

Oil tank farms, when regulated and well-maintained, serve a purpose, but are subject to national and state regulations to keep them up to date and safe. 

An oil tank farm is defined as a site with numerous tanks for storing bulk oil, petroleum, and petrochemicals. They house above or underground tanks, and are often situated near oil refineries, transportation hubs, or near the end of pipelines.

Some of the risks of oil tank farms include fires and explosions from flammable materials, soil and groundwater contamination from leaks, pollution from emissions, and hazards for workers, which can be triggered by natural events (like lightning strikes), structural failures and equipment malfunctions, and human error. These risks are, in part, mitigated by national and local regulations.

“U.S. Environmental Protection Agency identified examples of spills from farm bulk storage containers, and ample evidence that discharges of oil—even in the relatively small quantities stored on farms—cause significant harm to the environment,” EPA wrote in a report developed in consultation with the U.S. Department of Agriculture, Natural Resources Conservation Service in June 2015.

For those who work with storage tanks, most have restricted means of entry and are “not intended for continuous human occupancy,” according to the U.S. Department of Labor, Occupational Safety and Health Administration. Most storage tanks are considered “Permit-Required Confined Spaces,” which are recognized by OSHA and the industry as “presenting specific hazards that require special safety procedures in order to prevent accidents and injuries during entry.”

“Hazards encountered in petroleum and petrochemical storage tanks include fire or explosion, asphyxiation, toxicity, entrapment, falls, and physical and chemical hazards, including steam, heat, noise, cold and electrical shock,” according to OSHA. “These hazards can be a result of the presence of hazardous gases, vapors, fumes, cleaning chemicals, dusts, improper or insufficient lockout-tagout, or excessive heat or cold. Additionally, the creation of an oxygen-deficient or oxygen-rich atmosphere may cause serious injury or death.”

Facilities that have above-ground storage tanks (AST) for oils of any kind may be subject to the U.S. EPA’s Spill Prevention, Control and Countermeasure regulations. Bulk storage containers are defined by the EPA as “any container used to store oil … for purposes including, but not limited to, the storage of oil prior to use, while being used, or prior to further distribution in commerce.”

“Regularly scheduled inspections, evaluations, and testing of bulk oil storage containers by qualified personnel are critical parts of discharge prevention,” read information from EPA. “A container integrity inspection and/or testing program may involve one or more of the following: an external visual inspection of containers, foundations, and supports; non-destructive testing (examination) to evaluate integrity of certain containers; and additional evaluations, as needed, to assess the containers’ fitness for continued service. The type of inspection program and its scope will depend on site specific condition and the application of good engineering practices and this can be accomplished by following applicable industry standards.”

The Spill Prevention, Control and Countermeasure Plan Program includes conducting integrity testing and routinely inspecting above-ground bulk storage containers with a capacity of 55 gallons or more, including “large (field-constructed or field-erected) and small (shop-built) bulk storage containers, containers located on, partially in (partially buried, bunkered or vaulted tanks), and off the ground wherever located, and double-walled containers.”

Some storage containers need to meet additional state or local regulatory requirements, designed to “safeguard human health and the environment from potential threats posed by ASTs,” according to the EPA.

In Connecticut, any state or federally regulated underground storage tank (UST) installed on or after August 5 of this year must be “double-walled and use continuous interstitial monitoring of the inner and outer walls with a technology such as inert gas, liquid, or a vacuum (e.g. brine system),” according to the Connecticut Department of Energy & Environmental Protection.

“Double-walled USTs installed before Oct. 1, 2003, have two years (May 7, 2027) to upgrade release detection to continuously monitor the interstitial space between the walls (dry space) or use continuous interstitial monitoring of the inner and outer walls with a technology such as inert gas, liquid, or a vacuum (e.g. brine system),” the regulations continued.

A report by Purdue said that the risk potential of on-site fuel storage can be reduced by following safety, security, environmental and regulatory guidelines, including selecting the best location for above-ground storage tanks, incorporating good engineering practices, and observing industry standards.

Aboveground storage units that are not well managed can cause spills and other consequences, including soil and water contamination, spills and releases, cleanup costs, and evacuation of neighborhoods if there is a sizable release, according to Purdue.

When well maintained, oil tank farms can provide benefits such as storing large volumes of liquid efficiently, which helps ensure a steady supply for demands, as well as reducing costs through bulk purchasing. They also provide a controlled and secure environment for hazardous materials, and are designed to protect the environment through safety measures.

An oil tank farm on School Hill Road in Goshen was discussed during the August 12 and 19 meetings of the Goshen Board of Selectmen, becoming the focus of public comment on August 19.

Michael and Sarah Leonard, who live on the road beside the tank farm, have sent correspondence citing the potential hazards and wetlands concerns.

The .83-acre site on School Hill Road is listed as Rtl Oil for Land Use, under Land Class Code C. It is zoned RA5, according to Goshen records. Outbuilding and extra features on the property include five elevated tanks, ranging from 5,000 to 210,000 gallons.

Sarah wrote in a letter that was included with the Board of Selectmen meeting on Sept. 9 that, after speaking with Land Use Official Spencer Musselman on Sept. 8, a Wetlands permit will now be required for any future work on the School Hill Road project.

“The application had been approved by our building inspector for upgrades to the tank property … but Spencer told [the owners] over a month ago, sometime in mid- to late-July, that it was going to have to go before Inland Wetlands before the application could proceed,” Selectman Scott Olson said during the Board of Selectmen meeting on Sept. 9.