Do Double Walled Tanks Require Secondary Containment

Subpart i use and management of containers 40 cfr 264 175 which covers portable storage containers such as 55 gallon drums for hazardous waste and the second in subpart j tank systems 40 cfr 264 193 which covers large stationary containers.

Do double walled tanks require secondary containment.

Discusses the specific secondary containment requirements and the meaning of sufficient freeboard. The local consultant did not believe that the double walled frac tanks met the secondary containment requirements of 40 cfr part 112 7 and went as far as stating in the spcc plan that the installation was non compliant with these requirements. An owner or operator of a facility can self certify and their spcc plan if they qualify as a tier i or tier ii facility. Having double walled tanks or other devices that could prevent a release such as man made berms dikes and barriers does not exempt a facility from needing an spcc plan 40 cfr 112 1 d 1 i.

In most areas the use of a double wall tank with closed containment exempts you from the need to have containment that is over the capapcity of the primary storage tank. Ast with a double wall for secondary containment. Section 4 4 discusses issues related to secondary containment such as active versus passive measures the sufficiently impervious requirement facility drainage and man made structures. Typically secondary storage will be a dike system concrete vault or double wall steel storage tank.

In areas that get much rain that could mean 150 secondary containment capacity or more. Tanks that are constructed with double walls or with integral dikes or pans that fulfill the secondary containment function are recognized in the proposed seventh addition of ul standard 142 standard for steel aboveground tanks for flammable and combustible liquids. Shop built double walled or double hulled aboveground storage tanks asts may be used for secondary containment purposes as long as they are operated with certain protective measures.