Texas uses both numbers. The fire-protection section applies above 4,000 gallons aggregate water capacity. The written fire safety analysis rule covers new installations, existing installations at 10,000 gallons or more, and ASME containers on roofs. Those are different tests. Ask the authority having jurisdiction which applies to your site.
By Bill Stomp · Last updated:
Why are there two numbers?
The RRC amendment table, NFPA 58 §§6.29.1–6.29.3.3, sets out both tests. The section covers industrial plants, bulk plants and dispensing systems above 4,000 gallons aggregate water capacity. That means the tanks’ capacity. Use the nameplate, not today’s fuel gauge.
The RRC regulations page lists the adopted 2017 edition of NFPA 58. Read it with the Texas changes. A newer national edition may use other section numbers.
What should the site review cover?
Bring the tank list and each nameplate. Add the site history and any past analysis. Ask which rule fits. Keep that answer in the site file. These are steps I suggest to help with review.
Send the analysis to local emergency responders. Also send it to the authority having jurisdiction when asked. Check current state and local rules. The RRC PDF is a guide. The Texas Administrative Code is the official rule record.
Questions and answers
Does being below 10,000 gallons settle the question?
No. Is the site new? Are ASME tanks on a roof? Ask which other rules apply. One number does not settle the question.
Can our DOT security plan take the place of this analysis?
They cover different subjects. Ask the reviewer which files the site needs. Keep the fire safety analysis and DOT plan clearly labeled.
Next step
Bring your site’s tank list to the person who reviews its fire protection. For help with the document’s scope, see our fire safety analysis page.
Related: EPA’s separate plant fuel exclusion. Return to the manuals and records questions.
General information, not legal advice. Check what applies with the responsible regulator and a qualified safety or legal reviewer. This page does not replace training or the procedures for your equipment.