Impervious Under Tank Secondary Containment

(Do I need it in Florida?)

There seems to be some confusion in the state of Florida regarding under tank secondary containment.  In 1998, the Florida Department of Environmental Protection (FDEP) approved the latest update to the storage tank rule, 62-761 F.A.C. This regulation called for “impervious” containment throughout the entire secondary containment area by the end of 1999.  FDEP, however, allows an option for tank owners. The above ground storage tank (AST) could be internally lined and retrofitted with an FDEP approved continuous leak detection system.  The catch is, this system was only acceptable until the end of 2009.  By the end of 2009, all ASTs in Florida must have a double bottom or impervious secondary containment system under the tank

In addition to the under tank impervious liner, FDEP has approved Alternate Procedures (AP) for a number of companies.  The AP had to show that the company was providing equal or superior environmental protection to imperviously lined secondary containment.  As with the under tank impervious liner, there is a catch to this approval. FDEP can rescind the AP approval at any time.

FDEP is currently working on updating the 1998 regulation. One of the serious considerations that they are weighing is the approval of the APs.  FDEP is reviewing data that they believe shows that the APs are not providing the necessary environmental protection, especially when it comes to overfills.  Rescinding the existing APs is currently a real possibility in Florida.

What should the tank owner do? When should they begin doing it? These are good questions requiring long term planning and budgeting.

Believe it or not, 2010 is just around the corner.  If you are a tank owner that has the approved internal tank lining and FDEP approved leak detection system, you should be planning to upgrade your tanks.  You should also be keeping a close ear out to Tallahassee FDEP. 

The good news is that there are a number of methods to install impervious secondary bottoms on existing storage tanks.  As with all business decisions, there are a number of factors to consider when choosing the right method.  The best method for an individual tank must take into consideration the size of the tank, the existing foundation, the existing secondary  containment, the original tank construction and even the availability and disposal of hydro-test water. In fact, a tank owner may have a facility with a number of ASTs, each with different preferred double bottom methods. It is important that the tank owner / operator review all the options to find the best method for each tank.

The tank owner / operator should start now to begin the upgrade process.  You need to research all the available options and methods, weigh the pros and cons of each option, including their costs. When the desired method is chosen, the necessary funds must be budgeted.  Double bottoming a tank will cost many thousands of dollars and require the tank to be out of service for a number of weeks to months. An important consideration in the budget process is timing.  If you delay the required upgrade until just before the deadline, the demand for material and qualified contractors will be high.  Remember the relationship between supply and demand.  Low demand and high supply results in low price.  High demand and low supply results in high prices.  Start now to get the best bang for your capital investment dollar.

Tank Engineering And Management Consultants, Inc. is uniquely positioned to perform the evaluation and recommend the best alternatives.  We are not locked into any specific method, except what is best for our customers.  We can engineer and evaluate:

►   Double Steel Bottoms

►   Lift & Line

·         Air Bag Lifting

·         Crane Lifting

·         Hydraulic Jack Lifting

·         HDPE

·         XR-5

►   Internal Double Floor Applications

►   Cathodic Protection Considerations

►   Ring Walls

►   Concrete Slabs

In addition, TEAM can provide solutions that can be upgraded to meet the possible changes in FDEP regulations.

DON’T WAIT TILL THE LAST MINUTE!