A Hidden Cost of Using a “Frac Tank” to Store Waste Might Be An Unanticipated Citation
Blog post by Charles Liou, Senior Associate Consultant II
Frac Tanks have gained in popularity for storage due to their ready availability and generous storage capacity. These convenient fixed-axle storage tanks that were originally designed to handle the remoteness and rugged terrain of oil gas industry have caught the attention of those seeking reliable temporary storage. But they need to be used with caution!
We have seen numerous instances where the use of these tanks for temporary storage purposes has resulted in regulatory agency citations. Even though these seem to be ideal storage vessel, lined with sturdy materials and often equipped with relief systems, as well as, level gauges and alarms that should make them useful for waste storage – use caution. The problem is that these pseudo-transportable stationary devices are considered “tanks” rather than “containers”. Furthermore, despite being transportable when empty, the trailers become nearly impossible to maneuver once in use, making them not as “temporary” as agencies would accept. They may be fine for storage of non-hazardous materials, but they are considered permanent “tanks” when filled with waste.
What does this mean? The Department of Toxic Substance Control (DTSC) has mandated that Frac Tanks would have to follow every element specified under California Code of Regulations Title 22 Division 4.5 Chapter 14/15 Article 10 Tank Systems when storing hazardous waste. This means that not only do they have to be structurally intact, but also certified by an independent Professional Engineer (PE), structurally anchored to meet earthquake standards, with sufficient secondary containment, and well-maintained inspection records. They cannot be moved and need to have the certification and documentation annually.
When considering utilizing one of these tanks it is important to ensure you take the proper steps to avoid a regulatory penalty. If you need further information, or to have your tanks assessed for certification, please contact us at 562-495-5777.