In a couple of earlier blogs I have mentioned the reference to reporting fuels in the Top Screen. The information in those blogs came from the CSAT Top-Screen User Manual (pages 34 and 36). Well yesterday looking at the DHS CSAT FAQ page I found some updated answers that were entered/updated this week. The questions are numbers 1370 through 1372.
First off, facilities do not have to declare fuels unless they have at least one Release Flammable COI in quantities above the STQ for that chemical. That means that a facility that has only Jet Fuel, Kerosene or Diesel in fuel tanks and no other flammable COI above the STQ, does not have to answer the fuel questions on the Top Screen.
The question is less clear with respect to gasoline. Gasoline is a blend of oil distillates with various additives. If any of the components of the gasoline mixture are listed on the Release Flammable COI (for example various butenes) and are present at more than 1% the gasoline may have to be reported;
· If the gasoline is an NFPA 4 rated blend andmore than 10,000 pounds have been on site in the last 60 days, it has to be reported in the fuel question. The listed COI components in the gasoline do not have to be reported separately on the Top Screen.
· If the gasoline is not NFPA 4 rated and it is stored in an above ground tank, the amount of gasoline would have to be reported in the fuel question if any of the listed Flammable COI components are present at more than 10,000 pounds (eg: 10% Concentration x 100,000 Pounds of Gasoline = 10,000 lbs of COI). Again, the listed COI components in the gasoline do not have to be reported separately on the Top Screen.
· If the gasoline is not NFPA 4 rated and it is stored in a below ground tank, neither the gasoline nor the Flammable COI component needs to be reported in the Top Screen.
Other than refineries, most facilities are not going to be able to test for the presence of any of the Flammable COI in their gasoline. They are going to have to rely on the Certificates of Analysis (CoA) provided by the refinery or distributor. Anyone with 10,000 pound bulk storage of gasoline needs to insure that they require their supplier to include on the CoA the Flammable COI concentrations and the NFPA rating of each shipment of gasoline that they receive. Lacking proof to the contrary they are going to have to assume that they have an NFPA 4 rated mixture that contains more than 1% of one or more Flammable COI.
There is an interesting environmental component to this requirement. Ethanol is not a Flammable COI. The larger the concentration of ethanol in a fuel blend, the less likely that the blend will have 1% of any of the COI. If the equipment burning the fuel will allow for it, the facility could reduce their Top Screen reporting (and perhaps lower their risk rating) by requiring an ethanol-gasoline blend that would not require Top Screen reports.
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