Secondary Containment for Above Ground Storage Tanks

Eastern Gas Compression Roundtable - May 20, 2015

James M. Bright, P.E.

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EGCR 2015

Why is it important ?

Control leaks and spills

Protect water resources

Public safety

Minimize fire hazards

It’s the Law

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Secondary Containment

Defined:

Secondary containment describes the procedures,

methods, and equipment to prevent the discharge of oil

from non-transportation related onshore and offshore

facilities into navigable waters of the US or adjoining

shorelines.

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Secondary Containment

Spill Prevention, Control, and Countermeasure

Clean Water Act of 1972

Environmental Protection Agency (EPA)

40 CFR, Part 112

Oil Pollution Prevention Regulation

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The SPCC Rule

Mandates spill prevention and preparedness

Complements existing regulations

Operators must have an SPCC Plan

Requires spills be reported

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The SPCC Rule

Highlights

Written document detailing equipment, workforce, procedures, and steps

Reviewed and certified by a licensed P.E.

Copy of Plan to be on file at the facility

Site personal to be trained

Review and evaluated every five years

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SPCC Plan

Who must comply ? 112.3 - Owners / Operators of non-

transportation based facilities where: Above Ground Storage Tank

aggregate exceeds 1,320 gallons

Underground Storage Tank aggregate exceeds 42,000 gallons

A spill could reach navigable US waters or adjoining shorelines

NOTE: Oil means any petroleum, vegetable, or animal fat product or waste

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40 CFR, Part 112

112.3 - Requirement for Owner / Operator Prepare and implement a SPCC

Plan

112.7 (c ) - General provisions

Provide appropriate containment by means of active or passive facility controls

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40 CFR, Part 112

112.8 (c ) - Bulk storage containers

Sufficient freeboard for precipitation

Surface in diked areas is to be Sufficiently impervious

Containment for the entire contents of the largest container

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40 CFR, Part 112

Active vs Passive

Active - Specific action• Placing drain covers• Closing valves • Using spill kits

Passive - Permanent installation• Dikes, Curbs, and Barriers

with Liners

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Key Concepts

Sufficient Freeboard

EPA suggests using data for 25 year, 24 hour rain event OR 110% volume of largest container

Sufficiently Impervious Soil permeability criteria not

defined

Certifying PE to determine case by case with calculations retained on file

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Key Concepts

Space Available For a 500’ x 500’ area

1 vertical inch of dike = 156,000 gallons

Site Slope and Elevations Laid out by Licensed Surveyor

Find dike spill over location and elevation

Underlayment soil, crushed stone, concrete

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Design Considerations

Precipitation Water Sufficient Freeboard is not defined

by EPA

Minimum recommended volume:

• 110% of largest tank • 25 year, 24 hour rain event

The method is used must be documented with calculations in SPCC Plan

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Volume Calculation

Total tank capacity in gallons x 1.1

minimum safety factor = 10% can be as much as 50%

Length X Width of proposed area X Depth proposed

NOTE: For a group of tanks, use volume of the largest one

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Volume Calculation

Convert cubic feet to gallons Divide by 0.1337

Adjust dimensionsto obtain desired volume

trial and error

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Volume Calculation

Locate utilities

“One Call” system

Evaluate materials

Earthen Concrete Steel Liner

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Design Considerations

Is there sufficient soil on site to construct the dike ?

If not, where can it be found ?

Can the proper compaction be achieved on site? ( 90%-95% Proctor Test )

How imperious is the soil ?

Is a liner required ?

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Earthen Dikes

Can formwork be placed easily on site ?

Will their be a subsurface foundation?

Will soil subsidence cause failure of the barrier?

Barrier should be water sealed at the base

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Concrete Barrier

Typically vendor provided

Requires a liner

Hydrostatic force calculation

Anchoring required

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Steel Barrier

XR-5 Seaman Corporation

• Hydrocarbon resistant • UV resistant• www.seamancorp.com/geo.html

Cool Guard Cooley Group

• Multiple products • Variety of properties • http://

cooleygroup.com/cooley_product/coolguard

Berms

Snap-Up type

Foam type

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Liner material

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Design Considerations

Containment Area Design Tank Spacing / Grouping

NFPA 30 and 58

Accessible by Firefighters

Squirt

X = 2Cv [ SQRT (HY) ] X – horizontal distance (ft.) Cv – coefficient of velocity H – head (ft.) Y – distance above ground (ft.)

Storm water removal

drains and pumps

Flammable and Combustible Liquids

Containment Area Design Chapter 22.11

• Slope must exceed 1%

• 2’ min width for earthen dikes 3’ or higher

• Dike slope must = soil angle of repose

• 10’ min distance toe of dike to property line

Check tank location, grouping and spacing

• type of tank - Chapter 22.4

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NFPA 30

Liquefied Petroleum Gas Code

No secondary containment under tanks holding:

• Ethane• Propane

Check tank location, grouping, spacing

• min distance from liquids tanksChapter 6.3 and 6.4

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NFPA 58

Regular inspection schedule Set out in SPCC Plan Documentation

Check integrity of dikes and barriers Eroded soil Animal burrows Excessive vegetation Cracked / deteriorated concrete Corrosion on metal Mechanical damage

Check outside containment area Discolored / damp soil Dead vegetation

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Maintenance

Check inside the containment area Debris present Damaged liner

Check for signs of tank leakage Sheen on water surface

Function of drains and pumps Clogged drains Malfunctioning pumps Pumps properly sized

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Maintenance

January 9, 2014, Charleston, WV

A leaking AST spilled 7,500 to 10,000 gallons of MCHM into the Elk River upstream of the WV American Water treatment plant intake

300,000 citizens in 9 counties out of water

Outage lasted 4 to 10 days

Do Not Use advisory for up to one month

MCHM - considered non-hazardous

SPCC Rule and WV State regulations did not apply to Tank #396

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4 - methyl cyclohexane methanol

Case History Freedom Industries

Secondary Containment

cinder block wall no liner sand and gravel foundation

Tank #396 had been constructed prior to WW II

Private firm had inspected per API 653 in 2013

Tank #396 “not necessarily in compliance”

Tank damage could have been due to record low temperatures

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CSB Investigation

Federal State of Emergency Declared FEMA and National Guard deployed Bottled water distributed OSHA investigation

Proposed New Laws WV state legislature – SB 373

requires AST of critical concern to be registered with WV DEP and annually inspected by licensed PE

US Senate – Chemical Safety and Drinking Water Protection Act to mandate regular inspections of AST by state agencies• Introduced but not enacted

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Government Response

Secondary ContainmentAbove Ground Storage Tanks

SPCC Rule – CWA 1972

40 CFR Part 112 (EPA)

• SPCC Plan documented

• PE certified

Plan the design well

Check state and local codes

Facility maintenance is critical

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Conclusion

Questions ?

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Wrap Up

James M. Bright, P.E.

May 20, 2015

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Thank You !