Secondary containment

[Corgas]

Do I need a secondary containment for a brine tank made of FRP? who requires it or recommends it? OSHA? EPA? API? NACE?

Any guidelines or links?

Thanks,

 

[MJCronin]

Post in the Storage Tank Forum....

 

[bimr]

No, you do not need secondary containment for a tank that is holding a product. Most regulations are generally focused on waste not chemical products. There are no regulations that require secondary containment for a brine tank.

Having said that, you should do a risk assessment and consider the consequences of a tank failure.

 

[zdas04]

bimr,
I'm not sure that would be right. I can think of a couple of times that a brine tank (or a chemical product) must be protected by an adequate secondary containment.

First, if a site has more than 1320 gallons of "oil" (defined as any liquid product that will leave a sheen on water or a sludge or emulsion in water) then the site comes under SPCC (a Federal Law administered by the EPA) and every bulk storage container within the site must have an adequate means to prevent a rupture from reaching protected waters--generally a secondary containment is the most cost effective way to provide adequate means.

Second, if the tank is in Texas then the Railroad Commission has some very specific rules that end up requiring every bulk storage tank to be bermed. Other states are copying the RRC rule so it is getting more common.

David

 

[MJCronin]

Corgas...

Is this tank inside of a building or outside ?

 

[Corgas]

MJCronin:

Tank is outside. There are two more tanks in the same area (H2SO4 & Methanol) and both have secondary containment.

 

[bimr]

As defined by 40 CFR Part 112, oil includes all grades of motor oil, hydraulic oil, lube oil, fuel oil, gasoline and diesel, automatic transmission fluid (ATF), waste oil, and transformer mineral oil. The definition of oil also includes non-petroleum oils such as animal or vegetable oils and synthetic oils.

“Petroleum” is defined as crude oil, or any fraction thereof, that is liquid at 60°F at normal atmospheric pressure. This includes petroleum-based substances comprised of a complex blend of hydrocarbons.

Common “petroleum” substances include: motor oil, hydraulic oil, gear oil, automatic transmission fluids (ATF), used oil, machine coolant, water-soluble coolant, gasoline, diesel, jet fuel, residual fuel oils, lubricants, petroleum solvents, and water/oil mixture.

"Petroleum" does not include antifreeze, liquid propane gas (LPG), acetone, and alcohol (i.e., ethanol, methanol, etc.).

Brine is not oil and is not covered by the SPCC regulatios.

Brine has NFPA hazard ratings of : Health 1 Flammability: 0 Reactivity: 0

Methanol has NFPA hazard ratings of : Health 1 Flammability: 3 Reactivity: 0

Sulfuric Acid has NFPA hazard ratings of : Health 3 Flammability: 0 Reactivity: 2

So, it makes sense to have containment for the methanol and sulfuric acid tanks. However, the brine tank does not need containment.

Having said that, you always should do a risk assessment and consider the consequences of a tank failure. If you are located inland and a tank ruptured, what would happen? If you are located in an industrial area, the consequences are minimal. If you were located next to a pristine environment and the ruptured tank will immediately drain to that area, then you have a different risk.

Talk to the manufacturers of salt for further information.

http://www.sciencofast.com/downloads/BrinemakerFG-Manual(rev4-06).pdf

http://www.mortonsalt.com/products/industrial/revlinks.html

 

[tickle]

Australian EPA requirements vary between states, but some guidelines require that all liquids storage should inclde a bund (secondary containment) with the exception of rain water.

The regulations further state that the owner/operator should take all reasonable and practicable measures to prevent / minimise environmental harm.

Of course what is reasonable / practicable is subjective.

 

[bimr]

Maybe you could provide further information on the "brine"?

My assumption was that you are talking about a dry bulk salt storage tank where you add water to make brine.

 

[JimCasey]

Thank you Bimr. I was about to point out that "brine" is not particularly precise and I see it most frequently as concentrated solution of NaCl, but have seen it as a solution of alcohol and water and even the salt/vinegar solution in which pickles are packaged.

 

[SJones]

Factory Mutual requires an FRP tank to be on a concrete pad and then indicates the need for bunding or dikes.

Steve Jones
Materials & Corrosion Engineer

http://www.linkedin.com/pub/8/83b/b04

 

[SJones]

Apologies - concrete pad for flammable liquids only.

Steve Jones
Materials & Corrosion Engineer

http://www.linkedin.com/pub/8/83b/b04

 

[dcasto]

In Kansas, the state made us use a plastic lined secondary containment around our 12,000 gallon brine tank and the brine pumps.