DOT tankers without their motive power may be PSM covered processes

A few years ago we were asked to participate in an engineering review/facility siting for a proposed facility.  The business was in a $ crunch so one way they decided to save some $ was to utilize DOT-306 tankers as “temporary storage tanks”, thus reducing the number of above-ground storage tanks AND a reduction in the size of secondary containment.  As we got into this review, we noticed they had a “Concrete Pad w/ Containment” against the fence line in the “back 40”.  This pad was where they planned to stage their “dropped” flammable liquid tankers.  Once we explained the drawbacks to this plan and all of the baseline regulatory requirements for their plan – they were not happy campers.  Here is why this is not a great idea – it can be done, but these are the impacts:

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