United States
                        Environmental Protection
                        Agency
                           Office of Solid Waste
                           and Emergency Response
                           (5104)
EPA 55Q-F-9?-QQ2b
May 199?
f/EPA
CATASTROPHIC  FAILURE OF
STORAGE  TANKS
                        The Environmental Protection Agency (EPA) is issuing this Alert as part of its ongoing effort to
                        protect human health and the environment by preventing chemical accidents. Under CERCLA,
                        section 104(e) and Clean Air Act CCAA),  EPA has authority to conduct chemical  accident
                        investigations. Additionally, in January 1995, the Administration asked the Occupational Safety
                        and Health Administration fOSHA) and EPA to jointly undertake investigations to determine
                        the root causefsl of chemical accidents and to issue public reports containing recommendations
                        to prevent similar accidents. EPA has created a chemical accident investigation team to work
                        jointly with OSHA in these efforts. Prior to the release of a full report, EPA intends to publish
                        Alerts as  promptly as possible to increase awareness of possible hazards.  Alerts may also be
                        issued when EPA becomes aware of a significant hazard.  It is important that facilities, SERCs,
                        LEPCs, emergency responders and others review this information and take appropriate steps
                        to minimize risk.
                        PROBLEM
                               Catastrophic    failures    of
                               aboveground,   atmospheric
                               storage tanks can occur when
                        flammable vapors in the tank explode
                        and break either the shell-to-bottom or
                        side seam.  These failures have caused
                        the tanks to rip open and, in some cases,
                        hurled the tanks through the air. A
                        properly designed and maintained
                        storage tank will break along the shell-
                        to-top seam. Then, the fire would more
                        likely be limited to the damaged tank
                        and the contents would not be spilled.
                        This alert describes the types of tanks
                        that may be prone to catastrophic failure
                        and maintenance practices that can help
                        prevent the accidents.
                             Several accidents have occurred
                             within the last few years in which
                             storage  tanks   have  failed
                        catastrophically when the flammable
                        vapors  inside an atmospheric  tank
                        exploded. The tank was either propelled
                        upward from its base (shell-to-bottom
                        seam failed) or split along the side seam.
                        As a result, workers were killed or
                        injured and the contents were released
                        into the  environment.
                                     Three specific incidents demonstrate the
                                     potential dangers posed to workers, the
                                     public, and the environment when these
                                     storage tanks fail catastrophically. In
                                     these incidents, the shell-to-bottom seam
                                     failed after an explosion and the tank
                                     was propelled upward.  All occurred in
                                     older, atmospheric steel storage tanks.
                                     Often workers were performing tank
                                     maintenance or other activities  that
                                     introduced an ignition source.  The
                                     vapors were ignited either inside the
                                     tank or outside and then flashed back
                                     into the tank.


                                     In a  1995  incident, during a welding
                                     operation on the outside of a tank, the
                                     combustible vapor inside two large, 30-ft
                                     diameter by 30-ft.  high, storage tanks
                                     exploded and  propelled the tanks
                                     upward — one landing more than 50 feet
                                     away. The flammable liquid inside was
                                     instantly released and ignited, resulting
                                     in a massive fire that caused five deaths
                                     and serious injuries.


                                     In a 1992 incident, while workers were
                                     welding the outside of a tank empty of
                                     liquid, the residual vapor in the storage
                                     tank exploded and propelled the tank
                                     upward and into an adjacent river. Three
                                     workers were killed and one was injured.


                                     In a  1994 incident, during a grinding
                                     operation on a tank holding petroleum-
Chemical Emergency Preparedness and Prevention Office
                                                    i Printed on recycled paper

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                   Catastrophic Failure of Storage Tanks Caused by Vapor Explosion
                                                                         May 1997
based sludge, the tank was propelled upward,
injuring 17 workers and spilling its contents over
a containment berm into a nearby river.
T
ank design and inspection/maintenance
practices are factors directly related to
catastrophic tank failure.
Tank
Historically, accidents where the shell-to-bottom
seam fails are more common among older
storage tanks.  Steel storage tanks built before
1950 generally do not conform  to current
industry  standards for explosion and fire
venting. Atmospheric tanks used for storage of
flammable and combustible liquids should be
designed to fail along the shell-to-roof seam
when an explosion occurs in the  tank.  This
prevents the tank from propelling upward or
splitting along the side.  Several organizations
have developed standards and specifications for
storage tank design. Published standards relevant
to this design feature include API-650,"Welded
Steel Tanks for Oil Storage" issued  by the
American Petroleum Institute (API). Additional
codes and standards, published by API and
other organizations, address tank design,
construction, venting, and safe welding and are
listed at the end of this alert.
Poor inspection, maintenance,
Tanks that  are poorly maintained, rarely
inspected, or repaired without attention to
design, risk catastrophic failure in the event of a
vapor explosion. Either weakening of the shell-
to-bottom  seam  through  corrosion  or
strengthening the shell-to-roof seam relative to
the shell-to-bottom seam will increase the
vulnerability of the tank to failure along the
shell-to-bottom seam.  The practice of placing
gravel and spill absorbants around the base of
the tank, may increase the likelihood of bottom
corrosion.  Given years of this practice, the
bottom of some tanks, especially older ones, may
be below ground  level, thereby trapping
                                      moisture along the tank bottom.  This can
                                      weaken  the bottom and the shell-to-bottom
                                      seam.  Alternatively, changes to the roof seam
                                      such as modifications to or replacement of the
                                      roof, or attachments to the roof, could make the
                                      roof-to-shell seam stronger relative to the shell-
                                      to-bottom seam.
Other hazards that can contribute to a tank
explosion and possible consequences are:


Combustible
                                      Generation of combustible vapors is a hazard
                                      not only for the storage of pure flammable
                                      liquids but also for the storage of any sludge or
                                      mixture where a combustible component is
                                      present or can be produced by reaction. Sludge
                                      (slop tanks) and mixture (e.g., oil/water) tanks
                                      may be particularly vulnerable because they are
                                      sometimes   open  to  the  air; explosive
                                      atmospheres may form inside and outside the
                                      tank.  Facilities may not always recognize this
                                      hazard. In addition, even tanks appearing to be
                                      empty may pose a hazard if they still contain
                                      combustible vapors.


                                      In the cited cases, the potential for combustible
                                      vapors was not clearly recognized and materials
                                      were stored in tanks that were not equipped with
                                      flame arresters to prevent  external  fire from
                                      reaching the vapor space inside the tank or with
                                      vapor control devices to limit vapor emissions
                                      from the tank.
                                            Ignition
                                      When combustible vapors escape from their
                                      containment and mix with air in the presence of
                                      an ignition source, combustion may occur.  To
                                      minimize this hazard, all possible ignition
                                      sources must be isolated from potential
                                      combustible vapors, e.g., welding equipment or
                                      other maintenance equipment that can spark or
                                      arc, sources of static  electricity, lightning, "hot
                                      work" in adjacent areas,  and any electrical
                                      equipment in the vicinity of tanks that does not
                                      conform to National Fire Protection Association
                                      (NFPA)-70, "National Electric Code."

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                   Catastrophic Failure of Storage Tanks Caused by Vapor Explosion
                                  May 1997
Proximity to
environment
The  danger posed by these tanks is often
increased when the location of the tank does not
conform with  current minimum spacing
requirements.  Sections 2-3.2 to 2-3.3 of NFPA-30
discuss minimum spacing.   For mitigating
consequences to workers, the environment, and
other tanks, proper secondary containment
(diking) should be considered for containment.
     Facilities should evaluate their storage tanks
     for potential to catastrophically fail and
     identify  factors that could cause storage
tank explosion.  Some of the factors to look for
include, but are not limited to, the following:

4> Atmospheric storage tanks that do not meet
  API-650 or other applicable code(s) and
  contain flammable liquids or liquids that
  may produce combustible vapor.


4 Tanks with corrosion around the base and/or
  steel tanks whose base is in direct contact
  with ground and exposed to moisture.


4 Tanks or associated structures (e.g., pipes)
  with weakened or defective welds.
4 Tanks used to store mixtures containing
  water and flammables where the water
  phase is at the tank bottom and may con-
  tribute to internal bottom corrosion.
4 Tanks containing combustible vapor and
  not equipped with flame arrestors or vapor
  control devices to limit emissions.
4- Possible ignition sources near tanks
  containing combustible vapor.

     Storage tanks should  comply  with all
     regulations, industry codes and standards,
     including inspection and maintenance
requirements to keep tanks in proper condition.
Facilities with storage tanks that can contain
flammable  vapors  should review  their
equipment and operations.  Areas to review
should  include, but not be limited to, the
foil owing:


 1)           Of



API and other organizations have standards and
codes that address recommended practices for
tank design and construction.  It is imperative
to evaluate  whether the liquids or certain
components  of liquid mixtures may  generate
combustible  vapors. Design measures include
fire protection, flame arresters, emergency
venting (such as part of theAPl-650), prevention
of flash  back (for tanks containing flammable
liquids), and proper berming or diking.


2)

of


API-653 has tank inspection guidelines and
procedures for periodic inspections and testing,
especially for older tanks. These procedures call
for written documentation of inspections by API
Certified Tank Inspectors. Measures to review
include procedures for pressure testing, welding
inspections, and checks for corrosion or metal
fatigue.  API-650 specifies welding procedures
and  welding qualifications as well as joint
inspection (e.g., radiograph and magnetic
particle examination).  Programs  for tank
inspection  and  maintenance  should  be
developed in accordance with these standards.


3) Hot-work
                                            Both the Occupational Safety and  Health
                                            Administration's (OSHA) regulations concerning

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                    Catastrophic Failure of Storage Tanks Caused by Vapor Explosion
                                   May 1997
hot work and NFPA's standards on welding
should be reviewed for compliance.  Hazard
reduction measures include proper hot-work
procedures such as obtaining a hot work permit,
having a fire watch  and fire extinguishing
equipment present,  and proper testing of
atmosphere for explosivity; covering and sealing
all drains, vents, manways, and  open flanges;
sealing all sewers (to prevent gas or vapor
migration); and training workers and providing
them with appropriate protective equipment.


4)
Both OSHA regulations and NFPA standards
should be reviewed for compliance.  Hazard
reduction measures may include: having all
electrical   equipment   in  a  hazardous
environment conform with the requirements of
the  National  Electric  Code  (NFPA-70),
grounding tanks to dissipate static charge, using
only  "non-spark  producing" tools  and
equipment  in flammable atmospheres, and
taking care to not create sufficient heat or sparks
to cause ignition of flammable vapors.

      The above information is  for general
      guidance  only.    References  with
      information  about  the  hazards  of
catastrophic failures and methods of minimizing
them are listed below.  Regulations potentially
applicable to storage tanks and codes and
standards that may be relevant are included.


For more information consult the following:



Section 112(r) of the Clean Air Act focuses on
prevention of chemical accidents.  It imposes on
facilities with regulated substances or other extremely
hazardous substances a general duty to prevent and
mitigate accidental releases.  Accident prevention
activities include identifying hazards and operating
a safe facility.
EPA's Risk Management Program (RMP) Rule [40
CFR 68] is intended to prevent and mitigate
accidental releases of listed toxic and flammable
substances. Requirements under the RMP rule
include development of a hazard assessment, a
prevention program, and an emergency response
program.


EPA has tank inspection regulations under the Spill
Prevention Countermeasure and Control Plan and
Oil Pollution Control Act of 1990 [40 CFR119],


The Occupational Safety and Health
Administration (OSHA) has the Process Safety
Management Standard [29 CFR 1910.119], which
includes regulations on tank inspection, fire
prevention, and conduct during hot-work;
regulations concerning the storage of flammable
and combustible liquids [29 CFR 1910.106];
regulations concerning fire protection and
prevention during welding, brazing, and cutting
[29 CFR 1910.252] and regulations covering the
duties and responsibilities of afire watch 129 CFR
Part 126].


Occupational Safety and Health Administration
Phone: (202) 219-8151 - Public Information
Web site: http://www.osha.gov


Codes
The American Petroleum Institute (API) has tank
standards and guidelines on safe welding.


American Petroleum Institute
1220 L St NW
Washington DC 20005
Phone: (202) 682-8000
Web site: http://www.api.org


Relevant API standards include:
API Standard 620 — Design and Construction
of Large, Welded, Low-Pressure Storage Tanks,
ninth  edition,  February  1996  (includes
Addendum 1, December 1996).


[API Standard 650 comes from] Welded Steel Tanks
for Oil  Storage,  ninth edition,  May 1993
(includes Addendum 1, December 1994;
Addendum 2, December 1995; and Addendum
3, December 1996).

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                    Catastrophic Failure of Storage Tanks Caused by Vapor Explosion
                                   May 1997
API Recommended Practice (RP) 651 —
Cathodic Protection of Aboveground Petroleum
Storage Tanks, first edition, April 1991.


API RP 652 —  Lining  of Aboveground
Petroleum Storage Tank Bottoms, first edition,
April 1991.


API Standard 653 — Tank Inspection, Repair,
Alteration, and Reconstruction, second edition,
December 1995  (includes  Addendum  1,
December 1996).


API Standard 2000 —Venting Atmospheric and
Low-Pressure Storage Tanks: Nonrefrigerated
and Refrigerated, fourth  edition,  September
1992.


API RP 2003 — Protection Against Ignitions
Arising Out of Static, Lightning, and  Stray
Current, fifth edition, December 1991.
American Society of Mechanical Engineers
1828 L St NW, Suite 906
Washington DC 20036
Phone: 1 (800) 843-2863 or (202) 785-3756
Publications and membership 1 (800) 843-2763
Codes and standards (212) 705-8500
Accreditation and certification programs (212)
705-8581
Web site: http://www.asme.org
The American Society of Nondestructive Testing
(ASNT) certifies welding and non-destructive
examination (NDE) and non-destructive testing
(NDT) inspectors,


American Society of Nondestructive Testing
P.O. Box 28518
1711 Arlingate Lane
Columbus, OH 43228
Phone: 1 (800) 222-2768 or (614) 274-6003
Web site: http://www.asnt.org
API PUBL 2210 — Flame Arrestors for Vents of
Tanks  Storing Petroleum Products, second
edition, 1982.


API RP 2350 —Overfill Protection for Petroleum
Storage Tanks, first edition, March 1987.
The American National Standards Institute (ANSI)
has the B-31,3 Refinery Piping Code and other
standards and codes.
The American Welding Society (AWS) certifies
ivelding inspectors with the, designation AWS QC-1
(Quality Control)  Welding Inspector and has
guidelines on safe ivelding.


American Welding Society
550 NW Lejeune Rd
Miami, FL 33126
Phone: 1 (800) 443-9353 or (305) 443-9353
Web site: http://www.amweld.org
American  National  Standards  Institute
655 15th St NW
Washington DC 20005
Phone: (202) 639-4090 or
11 West 42nd St
New York, NY 10036
Phone: (212) 642-4900
Web site: http://www.ansi.org
The America?!- Society of Mechanical Engineers
(ASME) has the Pressure Vessel Code and other codes
relevant to tanks and storage ivssels.
The National Fire Protection Association (NFPA) has
lightning and flammable/combustible liquid codes.


National Fire Protection Association
1 Batterymarch Park
P.O. Box 9101
Quincy, MA 02269-9101
Phone: (617) 770-3000
Customer Sendee: 1 (800) 344-3555
Web site: http://www.nfpa.org

Relevant NFPA codes include:
NFPA 30 — Flammable and Combustible Liquid
Code, 1996 edition.
NFPA 51 — Design and Installation of Oxygen-
Fuel Gas  Systems for Welding, Cutting, and
Allied Processes, 1992.

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                     Catastrophic Failure of Storage Tanks Caused by Vapor Explosion
                                     May 1997
NFPA 51B — Fire Prevention in Use of Cutting
and Welding Processes, 1994.
NFPA 70 — National Electric Code. 1996.
NFPA 77 — Static Electricity. 1993.
NFPA 780 — Lightning Protection Code. 1995.
 Underwriters Laboratories Inc. (UL) has standards
for product safety,

 Underwriters Laboratories Inc.
 333 Pfingsten Rd
 Northbrook, IL 60062
 Phone: (847) 272-8800
 Web site: http://www.ul.com

 Relevant UL standards include:
 UL-142 — Standard for  Steel Aboveground
 Tanks for Flammable and Combustible Liquids,
 1993.
FOR MORE INFORMATION,,.
CONTACT THE EMERGENCY PLANNING AND
COMMUNITY RIGHT-TO-KNOW HOTLINE

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TDD (800) 553-7672

MONDAY-FRIDAY, 9 AM TO 6 PM, EASTERN TIME
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                                           NOTICE

 The statements in this document are intended solely as guidance. This document does not substitute for EPA's or other
 agency regulations,  nor is it a regulation itself.  Site-specific application of the guidance may vary depending on process
 activities, and may  not apply to a given situation.  EPA may revoke, modify, or suspend this guidance in the future, as
 appropriate.

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