Ask the Expert, Special Topics in Environmental Management

Does the Requirement for Additional Capacity for Precipitation for Specific Secondary Containment Apply?

Q. Does the requirement for additional capacity for precipitation for specific secondary containment apply for “General” Secondary Containment cases such as pipelines?

A. The SPCC regulations require general secondary containment for piping in accordance with “good engineering practice.” There is no specified volume that needs to be contained under the general requirements because they address the most likely oil discharge, not the worst case discharge. Therefore, you are correct; there is nothing in the SPCC rule that requires a failure analysis for general secondary containment that needs to account for precipitation.

For your piping, even that piping in depressed pipeways, you are required to provide appropriate containment to prevent a discharge as describer in 40 CFR 112.1(b). The entire containment system must be capable of containing oil and must be constructed so that any discharge from the piping will not escape the containment system before cleanup occurs. You need only address the typical failure mode, and the most likely quantity of oil that would be discharged. Secondary containment may be either active or passive in design.

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