Special Topics in Environmental Management

SPCC Q&As: Part 2

Does the calculation of total oil storage volume include all oil contained in drums and totes and all oil contained in storage tanks and all contained in process tanks? In other words, are we adding it all up?

Yes. I would say “yes,” again, with a caveat that if you have it in containers less than 55 gal, you don’t have to count that.


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When is a nonpermanent, nonengineered secondary containment allowed?

Nonpermanent, nonengineered secondary containment is allowed to provide secondary containment for transfer facilities. If you need containment for your oil-filled equipment, you propose active measure as well. However, you still must have engineered secondary containment for permanent storage tanks.

We can probably do the short answer on this one, unless, of course, there isn’t a short answer. As a PE working for a company, am I still allowed to certify our plans? I guess the question is, can it be self-certified? I mean, he’s a PE already.

The answer is “yes.” In-house PEs can certify their own plans under the SPCC rule. I guess it’s only in the caveat that if the state PE regulations were to apply this circumstance and said something different, that would apply.


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Can you briefly speak about self-contained tanks and double-walled tanks that are over 10,000 gal?

If you have a tank that’s engineered as double walled, that counts as being secondary containment. People who design and build those know the SPCC rule, and typically they’re designed so that they meet their containment requirements. If the containment is totally covered so that no rain can get in it, you don’t need the extra volume for precipitation.

Are transformers considered oil containers?

Transformers are considered oil containers under the SPCC rule. They are not bulk storage containers, but they are oil containers.

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