Simplifying Secondary Containment at SPCC-Regulated Facilities

Amanda Czepiel, J.D., SPCC Expert
aczepiel@blr.com

Well, SPCC regulations and the EPA’s guidance are very specific about what needs to be included, and you don’t want to be caught unprepared: an insufficient SPCC plan is one of the top SPCC violations, and fines are hefty.

Why does my facility need secondary containment?

Secondary containment systems are the most important ways to keep a failure of an oil container (known as primary containment) in control. Primary containment includes bulk storage containers, mobile or portable containers, pipes or flowlines, or other oil-filled operational equipment. Secondary containment systems provide temporary containment of spilled oil until a response action plan is activated to stop the discharge and prevent oil from moving to navigable waters and adjoining shorelines.

Use BLR’s oil storage inventory form to review all areas that require secondary containment.

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What are the secondary containment requirements?

The SPCC regulations contain general and specific provisions for secondary containment. General provisions address the potential for oil discharges from all regulated parts of a facility, including bulk storage containers; mobile/portable containers; production tank batteries, treatment, and separation installations; pieces of oil-filled operational or manufacturing equipment; loading/unloading areas; and piping. The general secondary containment requirements:

• Do not prescribe a size for a secondary containment structure but require that the containment system prevent the spilled oil from escaping the system before clean up
• Require appropriate containment and/or diversionary structures or equipment to prevent a discharge to navigable waters or adjoining shorelines
• Allow for the use of certain types of active containment measures that prevent a discharge to navigable waters or adjoining shorelines

The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system will not escape the containment system before cleanup occurs.

Specific provisions address the potential of oil discharges from specific parts of a facility where oil is stored or handled, and require specific containment design, sizing, and freeboard requirements be met in order to handle major container failure. While all parts of an SPCC-regulated facility with a potential for a discharge are, at a minimum, subject to the general secondary containment requirements, areas where certain types of containers, activities, or equipment are located are subject to these additional, more stringent containment requirements, including specifications for minimum capacity.

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The SPCC rule specifies a required minimum size for secondary containment for the following areas:

• Bulk storage containers;
• Loading/unloading racks;
• Mobile or portable bulk storage containers; and
• Production facility bulk storage containers, including tank batteries, separation, and treating vessels/equipment.

In general, provisions for sized secondary containment require that the chosen containment method be sized to contain the largest single oil compartment or container plus “sufficient freeboard” to contain precipitation.

See tomorrow’s Advisor for more information on selecting secondary containment systems, and some essential tools to help calculate secondary containment capacity.