Question: We have 55-gallon drums of oil staged throughout our machine shop. We are dispensing out of these drums. Some have manual pumps and some are being drawn directly from the drum. What are the requirements for this type of setup? We have zero floor drains. Is the containment supposed to hold the entire contents of a barrel or only a certain portion?
Answer: Secondary containment is required under different Environmental Protection Agency (EPA) regulations. One or all of the following might apply to your facility.
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RCRA requirements for secondary containment [40 CFR 264.175] only apply to containers holding hazardous waste, so the drums of virgin oil throughout your shop aren’t governed under this particular regulation. If you are storing hazardous wastes, the containment system needs to be capable of holding 100 percent of the largest container or 10 percent of the total volume of all containers stored in that area, whichever is greater. If the containment area is outdoors, you also need to allow extra capacity for “run-on” (rain or snowmelt).
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You mention that there are no floor drains. When it comes to having oil or any other hazardous material onsite, that’s a good thing! If there is no way for hazardous materials to leave your facility from a point source, such as a drain, and enter navigable waters, you would not typically be subject to EPA’s Stormwater Regulations [40 CFR 122].
It’s important to keep in mind, though, that states can have more stringent requirements than federal regulations, and there are some state and local municipalities that require every facility to have a stormwater pollution prevention plan (SWPPP) that outlines the best practices that are being employed to prevent spills from leaving the facility.
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Secondary containment would be an example of a best practice. Because it is intended to prevent a spill from leaving your facility, you’d want it to be large enough to handle your worst-case scenario, which is usually failure of the largest container.
Depending on the total volume of oil that is stored onsite (1,320 gallons aboveground or 42,000 gallons underground,) the EPA’s Spill Prevention Control and Countermeasures (SPCC) may apply [40 CFR 112]. If your facility has this volume of oil onsite, any container capable of holding 55 gallons or more of oil and any oil-filled equipment with 55 gallons or more of oil needs to have secondary containment.
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There are many ways to provide containment including everything from using spill kits to putting the drums on decks or pallets or using dikes to prevent spills from reaching a waterway. The key is to be prepared and have a plan that outlines the processes that you have onsite, your methods of providing secondary containment and how they will work together to prevent a release into water.
You may find that none of these regulations apply to your specific facility or situation and, therefore, secondary containment is not required. If that’s the case, it is still a good idea to consider whether or not secondary containment can provide other benefits. For example, it could be a good housekeeping process that keeps leaks and spills from creating slippery walkways. It could also be a waste minimization tool if any oil captured in the secondary containment system can be recovered for reuse or bulk recycling.