Clarification 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.
The term "dispensing" is used by the OSFM to distinguish a tank from a bulk storage tank. 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, gasohol, and gasoline/ethanol blends. (It should be noted that the applicable rules prohibit the retail sale/dispensing of fuel from an AST and that even when installed for non-retail use, dispensing ASTs are limited to 2,500 gallons capacity and any one facility is limited to the installation of only two such dispensing ASTs except for very limited circumstances that include airports, farms and mining facilities).
Other Related Information
A recent change to (430 ILCS 15/) Gasoline Storage Act increases the aggregate total gallons of fuel stored at one facility to 12,000 Gallons. (HB 4569) (Public Act 100-0637 Eff. 7.27.18)
430 ILCS 15/2 Section 4 a:
A facility used for (i) agricultural purposes, at an agricultural site; (ii) refueling construction equipment at a construction site; or (iii) parking, operating, or maintaining a commercial vehicle fleet, may store an aggregate total of 12,000 gallons of fuel for dispensing in aboveground storage tanks, as long as the facility complies with all other requirements of the rules of the Office of the State Fire Marshal.
Unlike USTs, there is no current requirement for the registration of existing ASTs. The OSFM does not maintain a database of all statewide ASTs.
Airport Dispensing Sites
Retail sale of fuel from an aboveground tank is allowed to be conducted at an airport facility, and only for dispensing into aircraft (not over-the-road vehicles). These tanks are allowed to have larger capacities (up to 10,000 gallons per tank) but also 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 - Fire Electric Generating Facilities
Aboveground fuel dispensing tanks at mining and coal-fire electric generating facilities are allowed to be of larger capacity (up to 12,000 gallons) with specific installation restrictions. The installation restrictions include increased separation distances to buildings and property lines, the storage of diesel fuel and not gasoline, and 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". (This is the same application that is applicable to smaller capacity dispensing sites. A special application does not apply to the mining or coal generation facilities).
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. Applications may be submitted either to the electronic or office address indicated at the top of the forms.
All storage tank applications must be accompanied by one copy of site plans showing the required information.
Unlike UST work, installation or relocation work on ASTs is not required to be conducted by a licensed contractor.
Applicants will receive 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 weeks.
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 correspondence also includes a phone number where installers or owners can contact the OSFM to inform the agency that the installation has been completed and 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.
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 Division of Fire Prevention. Field inspections of aboveground tanks are also conducted by this Division. If you have questions related to any of these subjects, including scheduling an inspection, or determining the results of a completed inspection, you should contact the Division of Fire Prevention's main office in Springfield at (217) 785-4714, or you may contact one of the Division's other regional offices: Chicago: (312) 814-2693 Marion: (618) 993-7085. Applications for AST installation are reviewed by the staff of the OSFM's Division of Technical Services. 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.