Special Topics in Environmental Management

Sorting Out Secondary Containment for SPCC Containers

An owner or operator required to implement an SPCC plan must provide appropriate containment and/or diversionary structures or equipment to prevent discharges, except as provided in 40 CFR 112.7(k) for qualified oil-filled operational equipment and in 40 CFR 112.9(d)(3) for flow lines and intrafacility gathering lines at oil production facilities. 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, such as a tank, will not escape the containment system before cleanup occurs. In determining the method, design, and capacity for secondary containment, an owner or operator must address only the typical failure mode and the most likely quantity of oil that would be discharged. Secondary containment may be either active or passive.

At a minimum, one of the following prevention systems or its equivalent must be used for onshore facilities:

  • Dikes, berms, or retaining walls sufficiently impervious to contain oil
  • Curbing or drip pans
  • Sumps and collection systems
  • Culverting, gutters, or other drainage systems
  • Weirs, booms, or other barriers
  • Spill diversion ponds
  • Retention ponds
  • Sorbent materials

Offshore facilities must use curbing or drip pans, or sumps and collection systems.

Depending on the type of facility, secondary containment calculations may require additional volume provisions for incoming precipitation and catastrophic releases from storage vessels.


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Secondary Containment Calculators

Some examples and blank worksheets used to calculate secondary containment capacity:

These blank worksheets address four specific scenarios and may not be valid for every facility. Although the SPCC rule does not require facility operators to show the calculations of sized secondary containment in SPCC plans, operators should maintain documentation of secondary containment calculations to demonstrate compliance to an EPA inspector.


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For a really detailed description on how to use these calculators, see these Advisor articles written by our SPCC expert.

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