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Is your secondary containment all it’s cracked up to be?

Published: 14 May 2021 - Victoria White

From annual checks on the roadworthiness of our cars to weekly fire alarm tests at work, inspections are a common feature of daily life.

At the root of them all is the mitigation of risk: these assessments provide peace of mind that our assets - whether the four-wheeled or fire-prevention variety - are fit for purpose or if any remedial effort is needed to keep them in good working order.

The same diligent approach is not necessarily applied to spill containment assets, however, as the Darcy Group explains. Across the UK, there are potentially hundreds of industrial and manufacturing sites where secondary containment measures, such as bunds, sit unchecked despite the crucial function they play in managing spill risk. There is no equivalent to an MOT or dental check-up that confirms these important assets are truly fit for their intended purpose.

As set out in the Control of Pollution (Oil Storage) Regulations 2001, secondary containment in the form of a bund must hold 110% of the capacity of the container and be impermeable to oil and water, with those constructed from masonry and concrete “likely to need a rendering or coating on the internal surfaces of the base and walls”.

According to guidance from CIRIA (Containment Systems for the Prevention of Pollution), very few new containment systems are currently being built, which means there is growing reliance on an ageing population of bunds to be compliant with these requirements. While this should place even greater emphasis on the need for a structured maintenance and repair schedule (and, indeed, this is a requisite of the Environmental Permitting Regulations (EPR) and Control of Major Accident Hazards (COMAH) Regulations), there is no specific guidance on what an appropriate inspection regime looks like.

CIRIA’s guidance suggests: daily or weekly inspections carried out by operations staff; a more formal inspection conducted by the works engineer every six to 12 months; and a detailed inspection completed by a competent person every five years. But without an explicitly imposed schedule, for some, this task can fall between the cracks.

The implications if bunds are not regularly and appropriately inspected are obvious: damage and deterioration can go unnoticed, and the asset’s pollution-prevention capabilities are diminished. In a worst-case scenario, the bund will not perform as required in the event of a leak, leading to an escape of polluting materials into the surrounding site and, potentially, into the wider environment. This, of course, raises the commercial risk of fines and reputational damage.

A bund inspection report provides a robust framework for managing this issue. The process involves documenting the dimensions of the bund and undertaking a series of assessments to evaluate properties such as porosity, while also providing an evaluation of structural integrity through the use of Schmidt hammer testing.

Any potential causes for concern are flagged in a detailed defect schedule alongside more overarching conclusions and recommendations, providing site owners with a prompt for when necessary remedial work should be carried out. This means that any weaknesses, such as corrosion or structural damage, can be remedied before they reach a point where the cost to repair would become prohibitively expensive or the bund’s containment capabilities would become impaired, compromising regulatory compliance.

So, while there might be nothing as prescriptive as an annual MOT for secondary containment facilities, it is important to know the condition of the assets under your control. Inspection reports, combined with a regular maintenance schedule, represent a cost-effective, proactive way of keeping them in check.

When combined with the use of bund water control units and wider audit activities, they form part of a sustained, best-practice approach to monitoring and managing vital secondary containment assets across a site. This not only ensures regulatory compliance, it ensures spill containment facilities are truly fit for their purpose of protecting the environment.

Source: Industrial Compliance


 
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