1 reply to this topic

[enviro michael 101]

Hey everybody,

I'm new to the whole forum board posting thing. I've been racking my brain all day so far looking at stuff on the internet but I'm finding myself data rich and information poor.

My problem is I've been told I have to have a secondary containment around my slug catcher. My plant is manned 24 hours. I've been told it doesnt have to hold the entire amount of the the catcher (simply because it is part of the plant and it has and unlimited amount to its capacity) but it does have to hold the amount of fluid that would be spilled during a normal spill on this equipment. In other words I have to be able to contain fluids from something like a leaking flange for a 24 hour period. The thing is since I have so many flanges on it I was told I can put a berm or a concrete curb all the way around the slug catcher. Pouring a curb is no big deal, but logic to me says why even pour a curb if it is going to soak into the roadbase! I was told by a consultant that I don't have to line it just put the berm or curb. I bet I looked at 20 different pictures of slug catchers and equipement on the internet yesterday and not one of them had a secondary containment. Are most of the pictures not showing that the facilities are protected by a ring leeve or retention pond?

I want to find a well educated answer for my guys. I'm already seen as the pain because I'm classified as a young tree hugger, but I really need to show these guys the right way so I can earn their respect.


Any help would be appreciated.

Thanks

[Art Montemayor]

Michael:

Yours is not only a valid and practical concern, it is a very important concern from the view point that we don’t know the fluids being caught and deposited in the slug catcher. Slug catchers are normally located outside normal operational limits – out in the yard somewhere, or just inside the processing plant’s property limits. This is because slug catchers normally service incoming pipelines originating in other units or other plant sites. The receiving plant normally does not have control on the quality and consistency of the fluids being initially received and, as such, usually receives a fluid that can arrive as a 2-phase mixture or as a “slug” – something that accumulated within the pipeline and is introduced into the reception plant instantaneously and needs to be captured, inventoried, controlled, and analyzed. All kinds of “cats and dogs” can come through a slug catcher.

I concur with your concern and fully agree that a small dike or curb is definitely not within the definition of “secondary containment”. First – and foremost – is that in order to be defined as “containment”, the installation has to be essentially impermeable. By this, I mean that I would not accept just a normal concrete slab with a curb. I would insist on a scope of work that includes the need to fully contain the fluids captured there for an indefinite period of time and the ability to fully pump the liquid fluids out to a safe and controlled tank or process area. The area would not only be made of concrete, but designed for total, impermeable containment – allowing for the eventuality of rain showers depositing more liquids within it during the containment period. It should have a built-in sump with an appropriate, remote-operated and controlled sump transfer pump with a stand-by spare. If the second, stand-by spare pump is not justifiable, then an emergency, feasible pump-out scheme should be prepared and kept a the ready in order to pump out the secondary containment. The area should be available for day or night operation – which calls for safe area lighting.

Note that I am assuming that your fluids are either toxic, hazardous, or potentially contaminating. Outside of pure water, I don’t know of any liquid fluids that I would allow to be drained or soaked into processing plant ground – if if were MY plant. Therefore, I certainly would not take the suggestion of your “consultant” that all you need is a curb or berm to contain fluids.

Until you furnish SPECIFIC data and information – such as specific fluid IDs, quantities, location, size of slug catcher, quantities of flanges, etc., etc. I don’t think we can make more comments.

I deleted your prior, duplicate posting on this same Forum. Please do not make duplicate postings of the same topic.