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Clarification regarding the application of standards for aboveground storage tanks

Above ground storage tank.

Photo of an above ground storage tank.

The 2015 edition of the National Fire Code of Canada (NFC) references CSA B139-09, Installation Code for Oil-Burning Equipment for the installation of piping systems serving oil-burning equipment, diesel-engine-driven emergency generators and fire pumps. Part 4 of Division B of the NFC, which applies to the storage, handling, use and processing of flammable and combustible liquids, and flammable gases at fuel-dispensing stations, does not apply to appliances and their ancillary equipment within the scope of the standard.

The scope of CSA B139-09 standard only applies to individual aboveground storage tanks (ASTs) of 2 500 L or less with a maximum aggregate capacity of 5 000 L. As such, any oil-burning equipment using ASTs over 2 500 L should comply with Part 4 of Division B of the NFC.

In 2015, the CSA Group updated the B139 series standards and expanded its scope to include any capacity for ASTs. Consequently, the new edition of the CSA B139 standard conflicts with Part 4 of the NFC as they now both apply to ASTs over 2 500 L. Code users may be confused when determining which of the Code or standard should be used when dealing with ASTs over 2 500 L. Additionally, the Code users may also be confused when determining which edition of the CSA B139 standard should be used, as the NFC clarifies the edition of referenced standards in Table 1.3.1.2. of Division B instead of within the code provision.

Since the NFC 2015 maintains its reference to the 2009 edition of the CSA B139 standard, a proposed change to the next edition of the code will clarify when to choose one over another. The purpose of the proposed change can be expressed using the following flowchart.

Image of a flowchart depicting which code or standard to apply regarding above-ground storage tanks. The flowchart states, if the above-ground storage tank is above 2 500 L apply Part 4 of Division B of the NFC. If the above-ground storage tank is below 2 500 L apply CSA B139-09 standard.

The proposed change to the NFC depicted in a flowchart.

The proposed change does not impose any additional cost to the Code users. It is a clarification of an existing requirement and should result in minimal impact for enforcement. In fact, this change could improve consistency for regulators and code users applying the NFC.

The public had a chance to comment on the proposed change during the public review that took place from November 7, 2018 to January 4, 2019. The Standing Committee on Hazardous Materials and Activities, who sponsored this change will review the comments received at the next meeting scheduled in spring 2019.

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