AST Banner.jpgClarification of the Terms "Bulk Storage" vs "Dispensing" Tanks

Bulk Storage Tanks

The term "bulk" is often incorrectly interpreted to mean a "large capacity" storage tank typically found at bulk plants or terminals. However, with the rules and operating procedures of the OSFM, the term "bulk" is not connected to the capacity of the tank, but rather to simply distinguish the purpose of the tank storage from a "dispensing tank". Bulk storage tanks include tanks used for the storage of flammable or combustible liquids that are not dispensed directly into the fuel tanks of vehicles. Typical contents of bulk storage tanks include: fresh and waste motor oils, transmission and hydraulic fluids, petroleum products stored for off-loading into bulk storage trucks, chemical products (if flammable or combustible) and emergency generator fuel tanks. (Note: even though products such as fresh motor oils or transmission fluid are intended for use in vehicles, they are not dispensed into the fuel tanks of the vehicles and therefore the OSFM classifies such tanks as bulk storage tanks and not as "dispensing" tanks. Likewise, if flammable or combustible products are off-loaded from an aboveground tank into the cargo tank of a bulk storage truck, such a tank would be considered a bulk storage tank and not a dispensing tank. The tank would only be designated as a dispensing tank if the contents of the tank are dispensed directly into the fuel tank of vehicle - in other words, the vehicle's motor runs off the product being dispensed into the fuel tank).

An application to, and subsequent field inspection by, the OSFM is required for the installation or relocation of bulk ASTs greater than 110 gallons capacity.

Dispensing Tanks

The term "dispensing" is used by the OSFM to distinguish a tank from a bulk storage tank.  "Dispensing", means the activity of transferring a flammable or combustible liquid from an aboveground storage tank to a vehicle, mobile equipment, engine or motor for use as fuel by them; "dispensing" also includes such transference into a receptacle, such as a gas can.  

Dispensing storage tanks contain products that are dispensed directly into the fuel tank of a vehicle. Typical contents of dispensing storage tanks include: gasoline, diesel fuel, biodiesel, gasohol, and gasoline/ethanol blends. The rules prohibit the retail sale/dispensing of fuel by the public from dispensing AST.  Part 180 provides regulations for the permitted dispensing scenarios along with the maximum amount permitted to be stored. The most common dispensing activity is found in what OSFM calls “fleet services” or storage at commercial, industrial, governmental or manufacturing establishments for fueling vehicles used in connection with their business. The maximum total aggregate volume permitted for this fleet activity is 12,000 gallons. 

Registration of Aboveground Storage Tanks

Unlike USTs, there is is no requirement for the registration of ASTs. The OSFM does not maintain a database of ASTs installed in Illinois.

Airport Dispensing Sites

Retail sale of aircraft fuel from an aboveground tank is allowed to be conducted at an airport facility. Dispensing is only for aircraft and not into over-the-road vehicles. These installations are permitted to have two tanks with capacities up to 10,000 gallons per tank. Airport Dispensing installations must comply with more stringent installation rules. These installations at airports must be approved by both the Illinois Department of Transportation's Division of Aeronautics as well as the Office of the State Fire Marshal.

The proper application to be completed and submitted to the OSFM for airport sites is the "Aboveground Airport Dispensing Storage Tank Application".

Mining and Coal-Fired Electric Generating Facilities

Mining and coal-fired electric generating facilities are allowed to have two tanks up to 12,000 gallons each. Additionally there are specific installation restrictions for these larger tanks. The installation restrictions include increased separation distances to buildings and property lines, limiting storage to off-road  diesel fuel, and an agreement to the installation by the local fire department. The proper application to be completed and submitted to the OSFM is the "Application for Above Ground Storage Tank Installation for Motor Vehicle Fuel \ Dispensing Purposes". It should be noted that additional ASTs for on-road vehicles are also permitted to be installed. See the information "Dispensing Tanks."

Information Applicable to Both Bulk and Dispensing ASTs

There is no fee required for the OSFM's review or field inspection of aboveground storage tanks. All applications for aboveground liquid (bulk or dispensing) storage tank installation or relocation must be completed, and submitted to OSFM Technical Services Division. 

All storage tank applications must be accompanied by one copy of site plans showing the required information.

AST installation and relocation work is not required to be conducted by a licensed contractor.

Applicants will return correspondence from the OSFM after a review of the applications and plans has occurred. If all necessary information is included in the submittal, average turnaround time for submitted AST applications is 10 business days.

The return correspondence includes instructions that the tanks may not be filled with product until an on-site inspection is conducted by an assigned inspector of the OSFM. The OSFM application review letters also copied to the local fire authority. The correspondence also includes a phone number and an email where installers or owners can contact the OSFM to request the assignment of an inspector to conduct the on-site inspection. The OSFM application review letters will continue to be copied to the local fire authority.

Bulk ASTs used to Fuel Fire Pumps

Contact Information

Requests for blank applications or copies of applicable rules, as well as general rule interpretations of the Part 160 and 180 rules are handled by the OSFM's Technical Services Division. This division also reviews the AST installation applications. Field inspections of aboveground tanks are conducted by OSFMs Fire Prevention Division. If you have questions related to scheduling an inspection or determining the results of a completed inspection, you should contact the Division of Fire Prevention's offices in Springfield at (217) 785-4714 or in Chicago at (312) 814-2693.  If you have questions related to the status of a submitted application or the contents of an application review letter, you should contact the Division of Technical Services by email.