WKS 4 DRAFT Secondary Containment Systems Consultation Draft For Website
WKS 4 DRAFT Secondary Containment Systems Consultation Draft For Website
WKS 4 DRAFT Secondary Containment Systems Consultation Draft For Website
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2 HSWA ........................................................................................................................................................... 8
2.5.1
2.5.2
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HSNO classification system .......................................................................................................................... 9
3.4 Maximum Capacity of Secondary Containment System - Class 3.1 substances ....................................... 14
4.7.5 Water........................................................................................................................................................... 21
4.13
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Substances that degrade with age ............................................................................................................. 23
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4.14 Storage inside buildings .............................................................................................................................. 23
4.14.5 Buildings holding substances that are required to be kept cool. ............................................................ 25
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4.14.6 Rooms where flammable liquids are in open containers or are being used .......................................... 25
7.3.1
7.3.2
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Works being undertaken ............................................................................................................................. 33
9 Interpretation ............................................................................................................................................... 36
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(a) in which pooling substances held in the workplace will be contained if they escape from the container
or containers in which they are being held; and
The purpose of these Guidelines is to provide a practical means of meeting the controls for secondary
containment systems. These Guidelines seek to address some of the range of secondary containment options a
PCBU is likely to consider when developing a new site or making significant changes to an existing site.
1.2 Scope
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Secondary containment is one aspect of wider emergency management provisions for hazardous substances.
These Guidelines provide options for meeting the requirements of secondary containment systems for sites
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having pooling hazardous substances in above-ground containers including bulk tanks, transportable containers,
process containers and packages.
These Guidelines provide guidance on compliance with the requirements for secondary containment in the Health
and Safety at Work (Hazardous Substances) Regulations 2017 (the Regulations).
PCBUs also need to be aware of the requirements of the Hazardous Substances and New Organisms (HSNO)
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Act 1996 relating to class 9 (ecotoxic substances). Of particular relevance are the controls on class 9 substances
prescribed in the Hazardous Substances (Hazardous Property Controls) Notice 2017.
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Compliance with these Guidelines does not remove the requirement to comply with other relevant provisions of
the Health and Safety at Work Act 2015 (HSWA) and regulations, or with other legislation such as the Resource
Management Act 1991 (RMA) and the Building Act 2004.
These Guidelines provide general guidance about requirements and are not a substitute for PCBUs obtaining
specialist advice about the requirements for their sites.
1.3 Exclusions
The following situations are not addressed in these Guidelines:
• Stationary containers with integral secondary containment.
• Below ground stationary containers.
• Small scale use of hazardous substances in research and development or teaching laboratories.
• Containment of explosives.
• Stationary containers covered by a safe work instrument.
The examples provided in these Guidelines are not intended to be used as technical specifications. The design,
Secondary containment systems apply to pooling substances, that is, a hazardous substance that is a liquid or is
likely to liquefy in a fire. By containing a spill and enabling its recovery, the secondary containment systems can
prevent a potential emergency from escalating to a point where the workers at the site, the public, or the
environment is at risk.
Fires at tank farms or earthquakes in the area of storage facilities are occurrences that might cause failure of
primary containers and therefore an appropriately designed, constructed and maintained secondary containment
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system is essential. On a smaller scale, spills can result from handling incidents in package stores, failure of
operational procedures or overfilling, for example, a valve left open or a package failure during handling.
Secondary containment systems are required for the duration of storage on site. This includes the lifetime of tanks
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and the period of storage for packages and drums. In the event of deterioration of the secondary containment
system, its integrity must be restored as soon as possible.
Secondary containment systems must be designed, constructed and maintained for their intended purpose.
1.5 Terminology
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These Guidelines use the term “must” to indicate a legal requirement to do something (for example it is required
by an Act or Regulations). The term “should” is used for a recommended practice or approach.
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Section 9 of these Guidelines (Interpretation) explains some of the terms used in these Guidelines.
HSWA sets out the principles, duties and rights in relation to workplace health and safety.
2.3 Regulations
The Health and Safety at Work (Hazardous Substances) Regulations 2017 (the Regulations) made under HSWA
specify generic controls for hazardous substances. Some regulations encompass all hazard classes and some
encompass specific hazard classes.
For instance:
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Part 10 of the Regulations relates to controls on Class 2, 3 and 4 substances
Part 11 of the Regulations relates to controls relating to adverse effects of unintended ignition of class 2 and 3.1
substances
Part 17 of the Regulations relates to controls on stationary container systems for all hazard classes, including
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• prescribe detailed or technical matters or standards that change relatively frequently and will often be
industry-specific
An example of a safe work instrument is the Reduced secondary containment for certain above ground stationary
The classification of hazardous substances must be listed in the Hazards Identification section of the safety data
sheet (SDS); usually Section 2. Section 15 of the SDS may also have other specific regulatory information.
Hazardous substances are classified in accordance with their inherent hazardous properties. The Hazardous
Substances (Classification) Notice 2017 sets out the following classes of hazardous properties:
• Class 1 – explosiveness
• Class 2 – flammability, gases
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• Class 3 – flammability, liquids
• Class 4 - flammability, solids
• Class 5 - capacity to oxidise
• Class 6 - toxicity
• Class 8 - corrosiveness
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• Class 9 - ecotoxicity
• (Class 7 is unallocated; radioactivity is subject to separate legislation).
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Each class is then split into numbered sub-classes to indicate the type of hazard, and a letter category to indicate
the degree of hazard. Each hazardous substance is given a series of hazard classes in accordance with the
properties of the substance, for example petrol has hazard classifications 3.1A, 6.1E, 6,3B, 6.7B, 9.1B.
Each hazardous substance is required to have safety data sheets available. The safety data sheets, available
from substance suppliers, are required to have the hazard classifications included on them.
Information on the HSNO classification system is available Environmental Protection Authority website.
Products brought into New Zealand from overseas will use the GHS system as the HSNO classification system is
unique to New Zealand. The SDS could show either the GHS or the HSNO classification for the substance.
A correlation table for HSNO and GHS classifications is available at the Environmental Protection Authority
website.
The thresholds for secondary containment systems for above-ground containers are specified in the Regulations
and also the Hazardous Substances (Hazardous Property Controls) Notice 2017 (for class 9 pooling substances).
Each site must be assessed for secondary containment requirements. Appendix 15 and Appendix 16 of these
Guidelines provide template registers for assessing secondary containment system requirements based on the
substances held at the site.
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The PCBU with management or control of a place where hazardous substances are present is responsible for
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ensuring that the specified controls are in place and are being followed. The Regulations set out detailed
secondary containment requirements for the different classes of pooling substances.
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Typical containers that require secondary containment systems are stationary tanks, process containers and
packages, such as drums and small packs. The secondary containment system around a tank is typically a
compound with bund walls.
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(Hazardous Property Controls) Notice 2017 may be different. PCBUs need to be familiar with the requirements
that apply to them. Storage above these quantities requires a secondary containment system, irrespective of the
type of storage, for example, stationary tanks, drums or packages.
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When applying Appendix 1, each of the hazard classes assigned to the substances must be individually
considered. For example, diesel fuel has hazard classifications 3.1D, 6.1E, 6,3B, 6.7B, 9.1B. It is hazard
classification 9.1B that triggers a requirement for secondary containment with a threshold quantity for secondary
containment of 1000 litres (see special cases in Section 5.1 below for farm tanks and Section 5.4 below for short-
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duration storage).
Some substances have had specific variations made to the secondary containment thresholds, for example petrol
has hazard classifications 3.1A, 6.1E, 6,3B, 6.7B, 9.1B. The threshold quantity under the Regulations for class
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3.1A substances is 100 litres. However, regulation 10.30(6) varies the secondary containment threshold quantity
for petrol to 1000 litres (see special cases in Section 5.1 below for farm tanks and Section 5.4 below for short-
duration storage).
The Hazardous Substances Calculator can be used to find out whether the quantity of hazardous substances in a
workplace requires secondary containment.
The Regulations also prescribe a requirement for preparing response plans. These emergency response plans
should provide for recovering hazardous substances from the secondary containment system, and where
necessary, for treating the hazardous substance to enable disposal of it.
Workrooms containing flammable liquids require secondary containment at 100% of the total pooling potential.
This is irrespective of the hazard class or quantity of substances held in the workroom, that is, there is no
minimum threshold quantity.
≤ 60 litres At least 50% TPP 2,500 litres or 25% TPP 10.31 (class 3 or 4)
whichever is the greater
12.14 (class 5.1.1)
> 60 and up to At least 100% TPP 5,000 litres or 50% TPP 10.32 (class 3 or 4)
450 litres whichever is the greater
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Workrooms require secondary containment at 100% of the TPP.
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As defined in Regulation 3(1) of the Health and Safety at Work (Hazardous Substances) Regulations 2017
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Type 1, Type 2 and Type 3 workrooms as defined in Regulation 11.1.
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Table 2 Minimum secondary containment capacity for classes 6, 8 and 9 substances that do not have class 1 to 5
hazard classifications.
provided).
c. For horizontal tanks - the total enclosed volume.
2. The volume of isolatable piping connecting stationary containers or process containers is not considered
when determining the secondary containment system capacity requirement.
3. Where stationary containers are interconnected and a spillage will entail the release of the contents of
both or all of the containers, for example by a pipeline that is open, they are considered as one container.
4. In situations that rely on achieving a water bottom in the compound, for example, some clay-lined
compounds that require moisture for the clay to form a seal, the volume of water that is necessary to
achieve this is in addition to the 110% containment capacity that is required.
5. If 2 or more categories of containers of different capacities (as described in Regulations 10.31, 10.32, and
10.33) are held at 1 place, the PCBU must ensure that the secondary containment system has a capacity
of at least the sum of each container category [Regulations 10.30(3), 12.13(3), 12.38(3), 13.30(3)].
6. If a stationary container system comprises above-ground stationary containers, 1 or more of which have a
capacity of at least 250 litres, the capacity of the secondary containment system for the stationary
container system must be at least 110% of the capacity of the largest container [Regulation 17.100(1)]. A
If the aggregate quantity of flammable liquid which is to be held within a secondary containment system is greater
than 25,000,000 litres and the storage is in more than one stationary container, the stationary containers must be
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divided into groups. This quantity may be increased up to 40,000,000 litres upon application to WorkSafe. Each
group must be separated from all other stationary containers within the secondary containment system by an
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intermediate secondary containment system.
The capacity of the intermediate secondary containment system must be at least 50% of the capacity of the
largest stationary container within that group. The walls that form the subdivision of the secondary containment
system must be at least 250mm below the top of the lowest wall of the secondary containment system in which it
is located.
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The intermediate secondary containment system will limit the impact of a minor spill from a single container.
These spills are contained around the container that failed, thereby reducing the impact from allowing the spill to
spread over a wider containment area. If the spill cannot be stopped and the quantity in the container is greater
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than the capacity of the intermediate secondary containment system, then the spillage will cascade into the
secondary containment system.
Secondary containment systems for storage of class 3.1 substances in above-ground stationary tank - Regulation
17.102
include (non-exclusive):
• continuous pour from floor to wall, or
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• Connections between a compound wall and the floor of the compound must be adequately sealed. This could
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• inserted leak stop barriers, or
• a continuous earthen layer. Refer to Appendix 4 for examples.
• Incompatible substances must be prevented from adversely affecting each other. Incompatible substances
stored in stationary tanks must have separate secondary containment systems. This does not prevent dilute
substances whose only action is to neutralise each other with minimal rise in temperature from being located
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A failure that results in jetting could lead to the contained substance being projected over the secondary
containment system wall. Therefore, for sensitive sites, potential jetting should be considered and addressed.
Refer to Appendix 12 for a methodology. In this context, sensitive sites are those which will result in
consequences, such as environmental damage or human harm, if the contained substance escapes outside the
secondary containment system.
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In circumstances where maintenance about the tank or water cooling of the tank is required, sufficient clearance
needs to be available between the tank and the inside of the secondary containment system perimeter.
The potential consequences should a secondary containment system containing hazardous substances fail should
be considered in the bund design phase.
The secondary containment system must be designed and constructed to withstand all foreseeable events. This
includes seismic activity. The secondary containment system should be designed to withstand a seismic event,
that is, it should be able to withstand the seismic event in the unloaded state and be able to retain the contents of
the damaged containers subsequent to the seismic event. In the event that liquefaction can result in land
movement, this should also be designed for.
Design criteria for the secondary containment system in the unladen state should exceed the stationary tank
design criteria, so that it can provide effective containment if the stationary tank fails due to seismic activity. The
secondary containment system in the laden state should be able to withstand aftershocks so the secondary
containment system in the laden state should be designed to the same criteria as the stationary tank.
New secondary containment systems for stationary tanks should have a statement from a competent person to:
Hydraulic forces arising from the catastrophic failure of a tank can lead to wave action. This can result in
significant hydraulic force and also a significant wave height. While some spillage over top of a secondary
containment system may be inevitable, the design of the walls and adjacent tertiary containment should provide
for mitigation and control of these effects so far as is reasonably practicable.
The secondary containment should be designed to the most up-to-date structural design and construction
standards and codes to ensure it is fit for purpose over its design life.
Relevant standards of design and construction include (but are not restricted to):
• NZS 3101 Concrete structures standard
• NZS 3106 Design of concrete structures for the storage of liquids
• NZS 4203 Code of practice for general structural design and design loadings for buildings.
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The publications CIRIA C598, CIRIA R163 and CIRIA C736 provide further information on compounds.
The standard API 650 in Appendix I – Underground Leak Detection and Subgrade Protection provides acceptable
construction methods for the detection of leaks through the bottoms of above-ground stationary tanks and
Appendix 11 of these Guidelines provides an example.
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Where site restrictions make it impossible to construct an adequate secondary containment system directly
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around a stationary tank, the secondary containment system may be connected by piping or ducting to an
impounding basin. The impounding basin needs to be constructed with the same degree of integrity as the initial
secondary containment. Refer to Appendix 7 of these Guidelines for an example.
Secondary containment systems for flammable substances should be designed to minimise the surface area of
the spill/fire size so far as is reasonably practicable.
A fire in a secondary containment system containing flammable substances is a foreseeable event and the
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secondary containment system needs to be designed on this basis. The secondary containment system is to be
designed to retain its structural integrity and withstand such a fire. Furthermore, the secondary containment
system design needs to ensure that a fire occurrence in the secondary containment system, the transfer route or
impounding basin does not endanger neighbouring facilities, particularly, protected places.
Flammable substances can create hazardous areas. Such areas can be present in compounds for flammable
substances. These areas must be delineated and controls put in place. Refer to AS/NZS 60079.10 for the
classification of hazardous areas [Regulation 10.6].
Where there are secondary containment systems for flammable and oxidising substances or organic peroxides,
energy sources or incompatible substances capable of igniting the substances or causing them to thermally
decompose must be excluded or where it is necessary for such items to be in the secondary containment system
they must be suitably rated for the hazardous areas.
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It is important that there are no materials in the compound which are incompatible with the substance being
stored. As an example, when substances such as peroxides are being stored, the compound must be free of
organic material such as wind-blown leaves and debris
4.5 Compatibility
4.5.1 Compatibility of substances
Hazardous substances that react with other substances must have separate secondary containment systems so
that the substances do not come into contact with each other. Incompatible materials must also be prevented from
coming into contact with the hazardous substance. This includes any spillage route within the secondary
containment system. The site inventory must identify the incompatible substances on the site.
When substances are classified as incompatible, they must not be stored in the same compound, and segregation
distances must be applied. Furthermore, water-reactive substances must be protected from water. This extends to
reaction with fire-fighting mediums.
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Schedule 9, Table 1 of the Regulations specifies substances that are incompatible with class 2, 3 and 4
substances; Schedule 10, Table 3 has a table of separation distances for substances that are incompatible with
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substances with 5.1.1A; 5.1.1B; 5.1.1C and 5.1.2A hazard classifications; and Schedule 15 specifies substances
that are incompatible with class 6.1A, 6.1B, 6.1C, 8.2A, 8.2B, and 8.2C substances.
AS/NZS 3833:2007 Figure 6.1 has a useful segregation matrix for storage areas.
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A PCBU who installs, constructs, or commissions a secondary containment system has a duty to ensure, so far as
is reasonably practicable, that the system is without risks to the health and safety of workers or others [HSWA
s.43].
This means that the material which the secondary containment system is constructed from must not be adversely
affected by the substance stored inside it. It may be necessary to coat the secondary containment system to
achieve this, for example, coating it with fibreglass to achieve corrosion resistance for a class 8 substance.
Some hazardous substances are stored at elevated temperatures. In these scenarios consideration must be given
to the materials of construction of the secondary containment system to ensure it retains it characteristics at these
elevated temperatures.
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For larger storage areas and buildings/warehouses, sufficient safe exit routes need to be provided to ensure that a
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loss of containment does not prevent egress from the secondary containment system.
4.7 Drainage
4.7.1 Slope away from container.
The floor of a compound around a stationary tank should be sloped away from the storage container. This does
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not imply that it is sloped away from the container in all directions, for example, other sections of the compound
floor may slope towards the tank in question and this may then flow to a lower section of the compound. Tank
bases should be constructed at an elevation above the compound floor.
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PCBUs need to ensure that water does not accumulate in a compound. The compounds are to be periodically
drained to minimise this accumulation and the compound needs to include a method for draining this water when
needed, for example, a normally closed valve at the lowest point.
Secondary containment systems storing a highly toxic substance, that is with 6.1A, 6.1B or 6.1C hazard
classifications, must not have drains to open areas unless the PCBU is certain that the discharged water is not
contaminated with the hazardous substance. Drains to sump systems must be compatible with the chemical being
stored.
The piping should be subjected to an integrity test at the time of construction. Any seals where piping is joined, for
example to sumps etc., must also be compatible with the substances involved.
PCBUs need to consider drainage systems through the site. This may mean providing separate drainage from the
site for:
• areas continuously contaminated
• areas able to be accidentally contaminated
• storm water.
The division of areas of the site and the drainage systems on this basis, can optimise the focus on areas which
may be contaminated with the hazardous substance, thereby avoiding having to treat large volumes of rainwater
that have become contaminated.
Drainage from secondary containment systems, whether by gravity or pumping, needs to be controlled. The
quality of the material being drained should be monitored and only released to public drain systems when it is
compliant with the requirements of the territorial authority, otherwise the drained material requires collection for
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treatment and disposal or re-use. Manual control may be necessary, especially for water-miscible substances,
such as alcohols, aldehydes and ketones.
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Care should be taken with concentrated acids as they may result in an exothermic reaction when coming into
contact with water.
The drainage system, if accessible to unauthorised persons, needs to be kept locked. This requirement can be
met by locking the outlet valve in the closed position. Where gravity draining is used, the status of the valve
position should be clearly obvious. It is good practice to place a sign at each drain position stating that the valve/s
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Site operation procedures should define disposal routes for contaminated content. Drainage water from the
secondary containment system of sites storing hydrocarbons should be passed through an interceptor or
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Where it is practicable, PCBUs of sites that utilise compounds as a means of secondary containment should
consider rain proofing the compound. This will minimise the requirements for draining it.
4.7.5 Water
If it is not possible to establish whether the water in a compound is contaminated by looking at it, the water should
be tested prior to being discharged. If the water is polluted it should be disposed of in a manner that does not
affect the environment.
For concrete compounds this may mean the application of a suitable surface coating resistant to the hazardous
substance. Consideration should be given to treating the concrete with penetrating synthetic resin or a similar
suitable system that is compatible to the final surface coating, before that surface coating is applied.
Where toxic or biologically corrosive substances are to be contained, people must be prevented from being
directly exposed to them.
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The interior of a secondary containment system that is occupied by tanks is to be limited to the tanks and the
necessary related equipment, such as piping, valves, dewatering tanks equipment etc. Substances in packages
are not to be located in secondary containment systems for stationary tanks. Similarly, the secondary containment
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system is not to be used for the storage of gas cylinders full or empty.
These requirements may be met by having a barrier that is sufficiently thick to:
• prevent the passage of the flammable liquids from passing through the membrane until such time as the
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substance is removed from the secondary containment system or an alternative action is initiated to inhibit the
passage of the substance, for example implementing a water bottom, and
• restrict the seepage rate while under full hydrostatic head. The water seepage rate at full head is to be no
greater than 1 mm/hour, (See Section 7.1.2 for information on periodic compound tests), and
• avoid localised seepage. In particular, localised seepage into an earthen compound wall must be avoided as
this may fluidise the wall mass and result in sudden rupture.
The water seepage rate may be calculated from the Darcy Equation. See Appendix 6 for details on the Darcy
Equation and permeability rates of hydrocarbons through compound floors of high clay index layers
When constructed of low permeability materials (for example, clay) the top of the compound wall should be at
least 300mm wide and if the wall height is greater than 750mm, the top width should be more than 600mm. Where
earth is placed to form the compound wall, it should not have a slope greater than 1m in 1m.
Sites in use prior to 1 July 2006 are able to have approved compliance plans which may accept seepage rates
different from those above. However, where major works are undertaken on the compound, or new tanks are
added into the secondary containment system, these compliance plans are typically invalidated. In these
Some hazardous substances, for example, cut back bitumen have a viscosity that is sufficiently high that a
specifically engineered geotextile membrane is not required.
• the penetration does not threaten the structural integrity of the compound or its impermeability.
• where pipe work is required to penetrate the compound wall, it is sealed and supported.
• where flammable substances are stored, the seals are fire resistant. The seals may need to be protected
by a covering such as a metal plate.
• earth rods, pipe sleepers and other support footings are sealed through the compound floor. Setting into a
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poured bentonite clay mix may suffice for clay compounds.
For certain arrangements of bund penetrations there is a higher possibility of crevice corrosion between the pipe
and the sleeve packing. Pipe protective coatings and materials should be carefully selected and regular
inspections should be carried out to ensure that protective coatings and seal arrangements remain in good
condition and corrosion of the pipe is not taking place.
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This means that the ability to conduct ongoing maintenance and integrity checks should also be considered in the
design phase.
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Particular care must be taken if it is intended to store or use flammable liquids inside buildings; the building must
Where flammable storage inside a building is required to be vented, this needs to be vented outside the building.
Storage of packages holding class 3.1 substance in a store in a building - Regulations 11.13, 11.31
Storage of containers of more than 60 litres of class 3.1A, 3.1B, or 3.1C substances - Regulations 11.14, 11.34
Storage of class 3.1B and 3.1C substances in retail shops - Regulation 11.33
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This store has a surrounding nib wall with entrance ramps and contoured floor. The centre drain slopes to an
internal sump where it can be pumped out. The store is attached to a retail shop and has electronic keyed
entrance.
Incompatible substances must be segregated in accordance with the provisions of Section 4.5 of these
Guidelines. One form of secondary containment is for incompatible material to be stored on separate racks with
“grate-over channel” drains all around the rack. The total volume of the drain is to meet the secondary
containment capacity requirement for the maximum amount of stored liquid and substances that liquefy in a fire,
for each storage rack. Each drain system must be kept segregated from each other for this type of control.
Another form of secondary containment is to install berms around the segregated storage areas.
When designing the layout of a secondary containment system within a building, consideration should be given as
to how a fire is to be combatted. For example, if using water fog nozzles to push the fire towards a corner is the
intended method, an aerosol display stand that would be engulfed should not be located in this area. A competent
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person should be consulted prior to the design and establishment of hazardous storage areas within buildings.
The US National Fire Protection Association Flammable and Combustible Liquids Code (NFPA 30) provides an
extensive guideline for fire-fighting considerations when storing flammable substances inside buildings. It includes
drainage through traps to remote secondary containment, containment sills or ramps, as well as guidelines for
heights of racks and stacked storage.
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Consideration should be given to the management of fire-fighting water. A compound should have the capacity to
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contain 20 minutes of fire-fighting water/foam at the design rate of application in addition to containing a spill from
the largest container. This calculated volume of water must be available onsite or available from a minimum of 2
fire hydrants within 135m of the site.
Hazardous substances that are required to be kept cool need to be located where that requirement is met.
4.14.6 Rooms where flammable liquids are in open containers or are being used
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Rooms where flammable liquids are being used or are held in one or more containers, one or more of which is
open must be held in a Type 1, Type 2 and Type 3 workroom or a paint-mixing room that complies with AS/NZS
4114.1:2003.
The secondary containment system capacity for workrooms must be at least 100% of the total pooling potential.
This is applicable irrespective of the quantity contained, that is, there is no minimum threshold quantity.
The legislation that applies in this Section is: Workroom requirements - Regulations 11.1, 11.16, 11.36
Where practicable, the drainage from indoor secondary containment systems of substances with flammable or
toxic vapours should be piped via traps to holding vessel/s or sump/s in a safe location. The sump may form part
of the volume calculation of the required secondary containment capacity. Incompatible substances must not
share the same secondary containment system [Regulation 17.24].
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In this context a competent person means a person who is skilled and experienced in this activity, such as a fire
engineer, or the Fire Engineering Unit of the Fire and Emergency New Zealand.
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4.15 Outdoor storage for packages
Outdoor storage buildings for packages of liquid hazardous substances, for example, drums, must meet the
requirements for secondary containment where the threshold for secondary containment has been exceeded
(refer Appendix 1). If they are flammable, the buildings must also be installed in compliance with the location
requirements of Part 11 of the Regulations.
Consideration should be given to covering outdoor package stores, for example by roofing over, to minimise
rainfall into the secondary containment system. This has the benefits of
• minimising contamination of rain water from localised spills, thereby reducing the cost and effort to maintain
the secondary containment system and the drainage from it, and
• preventing the pooling of rain water and thus maintaining the capacity of the secondary containment system.
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Some transportable bulk containers have an integrated secondary containment system, for example, a double
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skin containment system, which may be utilised while the container is being held and discharged. The design and
construction of the integral containment system is required to support the total load of the transportable bulk
container and is not to be subject to weakening from being contacted by the hazardous substance that is
contained.
Catastrophic multiple container failures or the use of water for fire protection purposes may result in overwhelming
the secondary containment system. Where this is a possibility, consideration should be given to providing tertiary
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containment to prevent harm to the public or the environment. This can be provided by raised earthen mounds,
depressions, or hard paved areas with nib walls. Portable deployment systems may also be used such as
inflatable pools and tubes, or sand bags to create compounds on hard paved areas.
The arrangements of a tertiary containment system must not frustrate access for emergency services to the site.
Appendix 14 provides examples of tertiary containment systems.
Where a site or building has an impermeable mound or ramp built around it for tertiary containment, care should
be taken to ensure this does not become a hazard for use of other buildings or equipment.
Where tertiary containment is provided to capture fire-fighting water run-off, for example, storm basins, the
potential may exist for fire pumps to take water from this containment area thereby reducing the overall volume of
liquid to contain.
Diluting the fire-fighting water run-off does not remove contamination and the makeup of the contamination may
not be able to be treated by standard waste water bio-treatment or interceptors.
PCBUs should consider the amount of contaminated fire-fighting water that will be generated in accordance with
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the emergency response procedures to the fire, how much containment is required and what can be used as
containment.
In addition to these, consideration should be given to the management of fire-fighting water. The compound
should have the capacity to contain 20 minutes of fire-fighting water/foam at the design rate of application in
addition to containing a spill from the largest container. This calculated volume of water must be available onsite
or available from a minimum of 2 fire hydrants within 135m of the site.
4.20 Housekeeping
Secondary containment systems should be maintained in a tidy state. Compounds should be regularly cleared of
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rubbish and other extraneous material. No combustible or incompatible material, such as vegetation, litter or
rubbish, should be allowed to accumulate in the bund.
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Spillages of material within the compound should be cleaned up immediately.
After rainfall, the compound should be emptied as soon as possible to maintain full capacity.
Secondary containment systems for tanks must not be used for the storage of packages, gas cylinders (full or
empty) or other hazardous substances.
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There must be instituted or capable of being instituted in respect of a secondary containment system, controls
that—
• if flammable liquids, oxidising substances or organic peroxides must be contained, exclude any energy
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• in areas with light, free draining soils, for example pumice or sandy soils, the ground may need to be lined
with an additional barrier that will prevent soakage into the soil.
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The legislation that applies in this Section is:
Secondary containment systems on farms - Regulation 17.99(6)(b),
17.99(6)(d)
Generally, if substances are held in tanks, 1 or more of which have a capacity of at least 250 litres, the capacity of
the secondary containment system must be at least 110% of the capacity of the largest container [Regulation
17.100]
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However, the requirements for tanks installed before July 2006 have been modified by the Health and Safety at
Work (Hazardous Substances—Management of Pre-2006 Stationary Container Systems up to 60,000 L) Safe
Work Instrument 2017.
See clauses 10, 13, 16, 20, and 23 of the safe work instrument for modifications of the secondary containment
requirements for different types of above-ground stationary tanks in stationary container systems installed prior to
July 2006.
In order to comply with this requirement all tanks should be maintained so that valves, hoses and dispensers do
not leak, and in areas with light, free draining soils, for example, pumice or sandy soils, the ground may need to
be lined with an additional barrier that will prevent soakage into the soil.
The legislation that applies in this Section is:
Regulation 10.30(6)(c) and Regulation 17.99(6)(c)
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height is greater than 750mm, the top width is not less than 600mm. Where earth is placed to form the bund it
• where earth is placed to form a compound or bund, the earth is to be selected and appropriately compacted
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to form a layer that is impermeable to the substance being stored. It is not suitable to use loose or sandy loam
in this circumstance.
• the interior of any compound is occupied only by the stationary tank or tanks, and such settling and
measuring tanks, piping, valves and other necessary appliances. These additional facilities are not to be
included in the volume calculations of the secondary containment system.
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• no person may allow water to accumulate in the compound. Compounds are to be periodically drained to
minimise the accumulation of water, for example, by means of an oil stop valve, by means of pumping or by
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means of a pipe carried through the wall of the compound at the lowest practicable point. For compounds that
are manually drained, the pipe needs to be fitted with either a screw-in bung or a lockable valve which is to be
kept in the closed position at all times except when draining off accumulated water.
• Where such compounds are in use or planned to be in use for more than 6 months, they are required to
comply with the maximum allowable seepage rate specified in Section 4.12.
Risks must be evaluated at all phases of a project. Refer to Appendix 18 for further details.
A PCBU with management or control of a workplace where a secondary containment system is installed must
manage the risk associated with the system.
They must also prepare an emergency response plan that describes and applies to all reasonably foreseeable
emergencies that may arise from a breach or failure of the system.
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The construction of permanent new /upgraded secondary containment systems for above-ground storage should
be verified by post-construction integrity testing. For compounds, the preferred method is a hydro test at full head.
In this context;
• hydro test means testing with water, and
• full head means 100% of the capacity of the largest stationary tank within the compound,
Where:
• this is not practicable, for example, within a building or a tank in a chamber, or
• there are new/upgraded secondary containment systems for above-ground storage which are not
permanent,
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these may be assessed by a competent person as an alternative option to this requirement.
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In the context of this Section, a permanent facility is one that is intended to be in place for a period greater than 6
months.
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Because large primary containers require a full hydro test for foundation compression stability and tank integrity
prior to service, the testing of the new compound can often be combined with the primary container hydro test.
head.
The testing needs to be done after initial soaking into the membrane has occurred and the system has stabilised.
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Accordingly, a duration of 24 to 48 hours subsequent to filling and initial ground wetting is a typical test period.
Compound walls that become damp on the external face or toe of the compound during the test must be
investigated and the significance of the dampness determined. Where the cause of the dampness may result in
structural failure, it must be remedied.
If there is a failure, the compound must be repaired and a hydrostatic test repeated. It is not necessary to repeat
the test for the complete compound if the repaired section can be isolated.
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In this context, a competent person is a person who is skilled and experienced in assessing the natural
characteristics of the secondary containment system for example, a Chartered Professional Engineer.
Secondary Containment Systems Consultation draft valid until 22 January 2021 32
liquid seepage loss to provide actual seepage rates.
A water level data logger is a useful instrument for monitoring the levels.
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The results of the tests should be recorded and signed by a competent person . A suitable form is included in
Appendix 17 of these Guidelines. The full results of the loss rate should be made available to the HSWA
compliance certifier.
In some circumstances it may be impractical to undertake a periodic hydro test. In these circumstances an
alternative test that is at least equivalent should be undertaken. A risk based inspection (RBI) program may assist.
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For large sites with multiple large compounds that have consistent design and construction, it is acceptable to
conduct the periodic flood tests in representative compounds with verification checks and inspections in the other
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compounds. In this context, large compounds are those with a capacity in excess of 1,000,000 litres.
A compliance certifier may be located from the WorkSafe register of compliance certifiers:
https://compliancecertifiers.worksafe.govt.nz/
Any works involving penetration of the permeability barrier must ensure the containment integrity is maintained
according to the performance criteria.
Where these are minor works and localised, for example, localised pipe or earthing rod penetrations, the works
must use recognised detailing practices. The detail of the works are to be documented and this documentation
can be augmented by localised testing.
Where these works are moderate or significant, for example, rebuild of a section of the secondary containment
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A Chartered Professional Engineer or equivalent with experience in this activity.
Secondary Containment Systems Consultation draft valid until 22 January 2021 33
system, re-founding of a tank or reconfiguring the compound, the integrity of the containment needs to be
demonstrated upon completion of the works, for example, by undertaking a compound flood test. A test in
accordance with Section 7.1.2 of these Guidelines will normally suffice but in circumstances where this will not test
the works that have been undertaken, a test in accordance with Section 7.1.1 of these Guidelines may need to be
considered. A consideration in determining whether a full head test is required is the impact on both the tanks in
the compound and the long term under floor corrosion of tanks in the compound.
Secondary containment systems are a passive barrier but their condition still needs to be monitored to ensure
their integrity. All operators should implement a periodic condition monitoring / inspection regime for their
secondary containment systems. This can include visual inspections, checking bund penetrations for crevice
corrosion etc.
Signs of failure of the bund integrity include wildlife burrowing in an earthen bund, cracking in a bund wall, sealant
degradation etc.
Where this is undertaken as part of an inspection and test plan, the plan and frequency of future inspections
should be adjusted accordingly when issues are noted.
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BS EN 61511
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Functional safety. Safety instrumented systems for the process industry sector
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Chemical Storage Tank Systems – Good Practice
https://www.ciria.org//ProductExcerpts/C598.aspx
CIRIA C598
Industrial Incidents
CIRIA R164
Buncefield Safety and Environmental standards for fuel storage site final report by the
Recommendations Process Safety Leadership Group (PSLG):
https://www.hse.gov.uk/comah/buncefield/fuel-storage-sites.pdf
Compound means an impermeable wall surrounding above-ground (or partially depressed) bulk
wall storage tanks, or containers and which forms the initial boundary of a secondary
containment system
Compound in relation to the storage of a hazardous substance, means a basin, pit, excavation,
hollow, or enclosure that is resistant to fire and—
(i) is constructed of concrete, brick, clay, earth, or similar incombustible material; and
(ii) is of such a nature and construction that it will effectively retain a hazardous
substance that is a liquid if the hazardous substance leaks or flows out of its
container
Regulation 3
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means prevention of a sites hazardous substance endangering the environment, or
public outside of a site’s boundary
Containment
Container means
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(b) includes—
(i) a receptacle that forms an integral part of a vehicle (other than part of a
vehicle’s fuel system, electrical system, control system, or emergency
system); and
Regulation 3
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(b) from which they can, subject to unavoidable wastage, be recovered.
Regulation 3
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Regulations means the Health and Safety at Work (Hazardous Substances) Regulations 2017
Tertiary means a system that will prevent leak to the environment in the event of overflowing
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Total pooling in relation to a workplace or a place within a workplace, means the aggregate
potential quantity of all pooling substances present at the workplace or place
Regulation 3
(i) the floor, walls, and ceiling have a minimum fire-resistance rating of
60/60/60 minutes:
(ii) every door opens towards the outside of the building or room, is self-
closing, and has a fire-resistance rating of at least -/60/60 minutes:
(iii) every window in the building or room complies with NZS 4232.2:1988;
and
(d) that has a secondary containment system with a capacity of at least 100% of the
total pooling potential.
Regulation 11.1
(i) the floor, walls, and ceiling have a minimum fire-resistance rating of
120/120/120 minutes:
(ii) every door opens towards the outside of the building or room, is self-
closing, and has a fire-resistance rating of at least -/120/60 minutes:
(iii) every window in the building or room complies with NZS 4232.2:1988;
and
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(c) that is not occupied either in whole or in part as a dwelling; and
(d) that has a secondary containment system with a capacity of at least 100% of the
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total pooling potential
Regulation 11.1
(i) the floor, walls, and ceiling have a minimum fire-resistance rating of
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240/240/240 minutes:
(ii) every door opens towards the outside of the building or room, is self-
closing, and has a fire-resistance rating of at least -/240/60 minutes:
(iii) every window in the building or room complies with NZS 4232.2:1988;
and
(d) that has a secondary containment system with a capacity of at least 100% of the
total pooling potential
Regulation 11.1
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3.1A 100
3.1B 1000
4.1.2A, 4.1.2B 50
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4.1.3A, 4.1.3B, 4.1.3C 100
4.2A 100
4.3A 100
4.3B 1,000
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4.3C 10,000
5.1.1A 50
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5.1.1B 500
5.1.1C 5,000
5.2A, 5.2B 10
5.2C, 5.2D 25
8.2A 100
8.2B 1,000
9.1A 100
9.1D 10,000
Some substances have variations associated with secondary containment systems as prescribed in:
• Regulation 10.30(6)(b) for E10, E85, petrol, aviation gasoline, racing gasoline, kerosene or diesel fuel stored
on a farm, and
• Regulation 10.30(6)(c) for E10, E85 for petrol, aviation gasoline, racing gasoline, kerosene or diesel fuel
stored for temporary use, and
• Regulation 10.30(6)(c) for E10, E85, petrol, aviation gasoline, or racing gasoline, setting the threshold
quantity as 1000 litres, and
• Regulation 13.31(2) for substances which do not have a class 1 to 5 hazard classification, and
• Regulations 17.102 and 17.103 for the storage of large quantities of flammable substances in bulk. This
specifies maximum quantities within a secondary containment system, trigger for intermediate secondary
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containment and provisions for approval to modify aggregate quantities.
The controls that apply to a specific hazardous substance or multiple substances held at a place can be found by
using the online Hazardous Substances Calculator.
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Notes to diagram:
1. Tank side valves that are below flammable product level are to be fire safe.
2. When concrete is used it is to be reinforced to prevent cracking and to withstand loads expected during
normal service.
Refer to Appendix 3 for examples of compounds constructed from concrete blocks and cast concrete.
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The Darcy Equation can be used to estimate the required thickness of clay barrier to ensure the loss rate does not
exceed 1 mm/hr:
Seepage, V = k x i
Where
• k = coefficient of permeability
• i = hydraulic gradient = z/l
• l = barrier thickness
• z = hydrostatic head = p x h l
• p = liquid density and h = height shown below
EXAMPLE
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Assume barrier (‘clay’) permeability coefficient of 0.0001 mm/sec (1 x E-7m/s) Calculate seepage for compounded
water (density = 1 kg/litre)
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Required barrier thickness to achieve seepage criteria increases in proportion to the hydrostatic head
requirement.
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This was a simple “material at hand” existing brown rock compound floor test to gain knowledge of the suitability
of the locally sourced material. The test tank was steel plate from a tank floor replacement. It was simply made
into a rough cylinder on site then welded.
The cylinder’s trench was marked out then excavated into the compacted high clay index brown rock floor.
Bentonite was mixed in a concrete mixer and the trench filled, the cylinder lowered in and left to set. Three sites
across the compound floor were tested. The transpiration tank was a 200 litres drum.
This type of test does not test the other areas such as pipe sleepers, earth rods, access step foundations or the
heel of the wall to floor connection.
The LAH is a second alarm (derived from the ATG where fitted). This alarm Response Time 2
is the first stage overfilling protection, and should be set to warn when the
normal fill level has been exceeded. It MUST NOT be used to control filling.
Factors influencing the alarm set point are: providing a prompt warning
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of overfilling and maximising the time available for corrective action
while minimising spurious alarms such as those due to transient level
fluctuations or thermal expansion
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NORMAL FILL LEVEL (NORMAL CAPACITY)
Response Time
Defined as the maximum level to which the tank will be intentionally filled
under routine process control.
For further information refer to API RP 2350 Overfill Protection for Storage Tanks in Petroleum
Facilities.
Where multiple tanks are blended into a single tank the blend management system should be
capable of proving that the sum of the flows is equal to the volumetric rise in level of the
receiving tank. Where this is in error, an alarm should be provided and as a minimum step,
manual intervention is required to ratify the reason for the alarm condition.
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Fire retarding rope is to be placed on both sides of an internal compound wall and may be placed on the
internal side only of an external wall.
Water barrier, rope and polysulphide sealant can be omitted in compound wall footings. The water barrier is
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A stainless steel flat barrier 4 mm thick is to be placed over the joint to protect the caulking. The bolt holes are to
be slotted vertically for expansion, and also horizontally if bolted on both sides of the concrete joint.
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With this detail, expansion and contraction of the piping for all foreseeable situations needs to be adequately
catered for to prevent damage to the wall.
Where the pipe cannot be anchored to the wall a different approach is required.
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Note: Wherever possible, penetrations through compound walls and floors should be avoided.
Part 4 – ‘Engineering against loss of secondary and tertiary containment’ of the Buncefield Recommendations
includes additional guidance on pipe penetrations. Additional examples include an additional concrete bund wall
penetration design, a design for a sheet pile bund wall penetration and a design for a sealed sleeve upgrade
option.
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The continuation of the compound floor sealing under the foundation pad is an important detail. Over time, the
loads upon the tank foundation tend to cause settlement of the original base resulting in a cone down effect. This
may result in tension cracks in a compacted compound floor.
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The tank drain runs full circumference at the base of the tank pad foundation and has lateral/s that lead to the
compound drain sump trap. The compound drain valve is always outside of the compound and is sized for the fire-
fighting water case.
The telltale drains to the outside of the foundation skirt and enables detection of a leak into the foundation.
Crest Locus
Tan θ = 0.5
0
θ = 26.5
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For a small diameter sharp edged hole in a tank shell: Cv = velocity coefficient.
2 2
I = 4Cv (z-h)(H-z)
Imin = H-h
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Tertiary containment can be provided by raised mounds or canals, concave paved areas with isolatable storm
drains, ramp down car parks etc. around a site, or storage areas within a site.
The mounds may be planted for landscaping enhancement but care should be taken when choosing the plant
species. Shallow rooting species such as grasses are preferable to deeper rooting species. The deeper rooting
species such as trees potentially allow for root penetrations through the tertiary containment wall, thus
compromising the integrity of the containment system.
Channeling within a tertiary containment system is required to direct overspills away from sensitive areas within,
for example, office blocks, adjacent public places or highways, or ignition sources if flammable spills.
The tertiary containment system leak integrity should be designed having regard to the location of the site within
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the surrounding environment, for example, presence of underground streams, aquifers, potable water catchment
areas etc.
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• Tertiary containment will be utilised when there is an event that causes loss of containment, for example,
compound joint failure or firewater overflowing from a compound during a prolonged tank fire, and is intended
to ensure that loss of hazardous substances does not result from such an event.
• Tertiary containment plans must be prepared as part of an effective emergency response plan, having regard
to the ground and location characteristics of the site.
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• Tertiary containment measures minimise the consequences of a major incident that causes the failure of or
exceeds the storage capacity of the secondary containment system.
Tertiary containment enables time to mobilise additional measures to be deployed if an incident escalates.
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In this example, the entire site is hard paved with a perimeter concrete nib wall. There are individual ramped
storage areas within the site where localised spills are trapped. The site’s surfaces outside of the storage areas
are contoured to this catchment and sump area. The float switch of the pump has lockouts driven from analyzers
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for contamination.
The system should be designed and operated to ensure that only clean rainwater is discharged into the
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environment. Contaminated material (including rainwater) that is collected should be disposed of correctly. The
more toxic or rain susceptible areas can be roofed over to minimise the possibility of contamination.
With such a system the design of the total available catchment volume and pumping capacity over time should
take into account the 50 year rainfall case. (Subject to Resource Consent conditions).
Where hydrocarbons are involved, it may be necessary to provide a separator. This could be an under/over weir
system to enable at least simple primary oil separation with dedicated pumps for recovery, plate interceptors,
absorbers etc.
When designing a hazardous site in a vacant area, thought should be given to the possible need for increasing the
protection systems when the surrounding area becomes developed.
This photo is of an agricultural supplier store with external hard paved area that has been contoured into several
catchment areas with hi-lighted drain sumps. The combined sumps lead to an isolation valve prior to exiting the
site. The store room has significant secondary containment system capacity.
Hi=lighted Sump
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From inside the store looking out showing the compound ramp and contoured paving.
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The description should be sufficient to ensure that each tank can be unequivocally identified.
The register may be combined with other HSWA criteria such as hazardous areas required for class 2.1.1, 2.1.2 and 3.1 flammable substances. Secondary
containment capacity of large systems may require a surveyors report to establish the capacity.
Secondary Secondary
containment Containment
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Location or Description Total Pooling Hazardous Protected Public Place
Capacity Capacity
Tank Number Potential Area Metres Place Metres.
Required Provided
litres
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Litres Litres Metres.
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In this column, a loss is expressed as a negative amount and a gain is expressed as a positive amount
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Duty of PCBU who manufactures secondary containment systems HSWA s.40
Duty of PCBU who imports secondary containment systems HSWA s.41
Duty of PCBU who supplies secondary containment systems HSWA s.42
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Duty of PCBU who installs, secondary containment systems HSWA s.43
Technical evaluation
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The UK Process Safety Leadership Group’s final Buncefield Report “Safety and environmental
standards for fuel storage sites” is a leading example of accepted practice for the storage of
flammable liquids. The report covers the processes required to ensure that the impacts on people
and the environment from the primary and secondary containment is understood, and that the
design eliminates the risk as far as is reasonably practicable. It is the expectation of WorkSafe that
the PCBU will implement these standards or a control which will achieve an outcome which is
similar or better.
Factors that should be taken into account when designing containment systems include the
following:
• proximity to, and environmental sensitivity of, surface waters
• proximity to, and environmental sensitivity of, groundwater
• nature and volume of products stored
• resistance of containment materials to the product stored
• service loading on containment media
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• fail safe provisions, proof test coverage and frequency; and
• consideration of the common causes of failure.
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Refer also to Appendix 8 ‘Overfill Protection’ of these Guidelines.
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