The Environmental Protect Agency’s (EPA) Spill Prevention Control and Countermeasures (SPCC) Rule aims to prevent illegal discharges of oil into navigable U.S. waters and adjoining shorelines. The EPA acknowledges that primary containers can fail and requires companies that store high amounts of oil to have secondary containment.
The SPCC rule requires facility owners or operators with more than 1,320 gallons of aboveground oil storage capacity or 42,000 gallons of underground oil storage capacity to have a written plan that addresses how the facility will prevent oil spills to navigable waters and adjoining shorelines. Regulations also require facilities to be prepared for, and have the ability to respond to oil discharges, if the processes and/or devices put into place fail.
Violations of SPCC secondary containment requirements have historically resulted in companies being fined thousands of dollars.
The EPA does not specify particular methods or devices that must be used or applied to prevent discharges, which gives facility managers the flexibility to determine the best way for their facility to comply.
The methods listed in a facility’s plan should be in accordance with accepted “good engineering practices,” and sometimes must be certified by a Professional Engineer (PE).
Secondary Containment
Secondary containment for bulk containers is a required element of SPCC. The EPA’s SPCC Guidance for Regional Inspectors states that “secondary containment is required for all facilities with bulk storage containers, large or small, manned or unmanned, and for facilities with bulk storage containers that also have oil-filled equipment.”
According to the EPA, a bulk container is “any container (with a capacity of 55 gallons or more) storing oil at a facility. Bulk oil storage containers may include, but are not limited to tanks, containers, drums and mobile or portable totes.”
Oil-filled equipment — such as transformers, hydraulic systems, lubricating systems, gear boxes, machining coolant systems, heat transfer systems, circuit breakers and electrical switches — must also have secondary containment.
Active Versus Passive
According to the EPA, secondary containment can be active or passive as long as discharge cannot escape the device [40 CFR 112.7(c)].
Active secondary containment is when an employee personally contains a spill. Active secondary containment includes:
- Deploying drain covers before a spill happens
- Deploying drain covers after a spill has occurred, but before the spill reaches a drain
- Using a spill kit in the event of an oil discharge
- Having a spill response team in the event of an oil discharge
- Closing a gate valve prior to a discharge
Active secondary containment may not be appropriate or possible for all situations due to lack of resources and staff. Unlike active secondary containment, passive secondary containment does not require deployment or the action of an employee or employees to contain a spill.
Passive secondary containment includes:
- Placing containment pallets or decks under drums and other containers
- Surrounding machines and containers with berms
- Erecting retaining walls around machines and containers
- Placing drip trays under leaky machines and containers
General and Specific Containment
The EPA specifies two types of secondary containment requirements under the SPCC rule: general and specific.
The general secondary containment requirements are “intended to address the most likely oil discharge from bulk storage containers; mobile/portable containers; production tank battery treatment, and separation installations; a particular piece of oil-filled operational or process equipment; (non-rack) transfer activity; or piping in accordance with good engineering practice,” according to the EPA’s SPCC Guidance for Regional Inspectors.
There is no specified volume that needs to be contained under the general requirements because they address the “most likely oil discharge” and encompass containers, processes and oil-filled equipment.
According to the EPA’s SPCC Guidance for Regional Inspectors, the specific secondary containment requirements are “intended to address a major container failure… these specific provisions explicitly provide requirements for sizing, design and freeboard that need to be addressed in the SPCC Plan.”
Specific secondary containment requirements apply to the following:
- Bulk storage containers
- Loading/unloading racks
- Mobile or portable bulk storage containers
- Production facility bulk storage containers, including tank batteries, separation, and treating vessels/equipment
Unfortunately, the SPCC rule does not specifically define the term “freeboard,” nor does it describe how to calculate the volume for secondary containment. A PE can help determine if a containment system has sufficient volume. Two generally accepted methods for determining sufficient freeboard for a containment device include:
- Using historical data from the past 25 years to calculate the volume based on the worst 24-hour storm event in the area
- Ensuring that the sump is capable of holding 110% of the volume stored
Containment Considerations
Facility managers should consider the following points to determine what type or types of secondary containment are appropriate for their various areas and/or processes:
- What are the potential sources of failure that may cause a discharge?
- How quickly can oil be discharged?
- How will discharges be detected?
- How will personnel react to a discharge?
Whether containment is active or passive or general or specific, the goal is always the same: preventing oil from being discharged into navigable waters or adjoining shorelines. Having the ability to contain spills at or near their source helps minimize the potential for discharge.
14 Comments
Scott Olsonsays:
02/14/2017 at 10:28 amI have a 1000 gallon fuel tank on a work location. It is a double walled tank. Is the double wall not considered secondary containment? If so, what regulation explains this?
Karensays:
02/16/2017 at 8:48 amHi Scott, check out this memorandum from the EPA discussing this topic: https://www.epa.gov/sites/production/files/2014-04/documents/h_2002_memo_horinko.pdf
-Karen
Jeffsays:
02/24/2017 at 7:38 amDo these regulations apply to other chemicals such as caustic soaps and chlorine based sanitizing chemicals? I know this article deals with oil.
Karensays:
03/03/2017 at 5:43 pmHi Jeff,
The SPCC rules only apply to oil and oil products. But that doesn’t necessarily mean that you’re out of the water. Caustic soaps and chlorine-based sanitizing chemicals may be considered hazardous and may be covered under other EPA and OSHA regulations, depending upon the specific hazards of each of the chemicals as well as the quantities that you have stored at your facility.
Providing secondary containment for these chemicals would be considered a best management practice (BMP) to help meet the spill prevention planning requirements of regulations such as:
Even if none of these regulations apply to your facility, many facilities provide secondary containment for all chemicals stored onsite as a general BMP to promote safety and housekeeping efforts. It is much easier to clean up a spill that has been contained, and a spill that has been contained is less likely to create a slip and fall hazard.
Hope this info helps!
Best,
Karen
DJsays:
10/18/2017 at 12:01 pmI have (10) 275 gallon totes of oil stored above ground, how tall of a containment wall do I need around the perimeter?
Karensays:
01/02/2018 at 3:14 pmHi DJ,
Totes come in different shapes. The most common are round and square. They can also be arranged in an endless number of ways. To keep things simple for this example, I’ve chosen to use 4’ square totes, spaced with 3’ of aisle space around each tote.
Step 1: Calculate 10% of the total volume of all containers that will be stored in the area and compare it with the total volume of a single container to determine which is larger. In this scenario, the answer is 275 gallons either way.
Largest container: 275 gallons
10% of total volume: 10 containers x 275 gallons per container x 10% = 275 gallons
Step 2: Determine if any additional containment capacity is needed to contain “run on” (rain and/or snowmelt). If the containment area will be outdoors and uncovered, EPA requires that additional sump capacity be added to allow for rain or snowmelt in addition to the volume of liquid that could spill. This volume is most commonly determined by one of the two methods:
At the federal level, neither of these two methods is mandated, but some states require one of these methods
Step 3: Determine the minimum square footage for the containment area
For this example, I’m using ten totes that are each 4’ square, arranged in two rows of five totes, allowing a 3’ aisle/walkway around each tote for inspections and access. In this configuration, the minimum length would be 38’ and the minimum width would be 17’, for a total of 646 square feet of space.
From this figure, the volume displaced by each tote needs to be subtracted.
Now, remember that we used a cubic foot for this calculation. That means that the wall/berm around the perimeter would be 1’ high. If you choose to put a 6” berm around the perimeter, you’d cut your volume in half (1817.64 gallons) and if you chose a 4” berm, your containment volume would be 1210.55 gallons.
Any of these volumes is well above what would be required for the ten totes, given the square footage listed in this example.
You do have a lot of options when creating a containment area, and it may help to explore different options to see which works best. For example, if the totes are stackable, you could reduce the square footage requirements and still reach your containment needs without having to put in a high berm around the perimeter. Using our previous example, if you stacked five of the totes on top of the other five and kept 3’ of aisle space between each one, you’d only need a 38 x 10 perimeter. This would be 380 square feet of space, and even with a 4” berm you’d still have 748 gallons of containment, which is also well above what is needed. The bottom line is that for 275 gallons of containment, the wall won’t need to be especially tall.
Please let us know if you have any other containment questions!
Best,
Karen
Ahmed uzairsays:
11/10/2017 at 1:19 pmHi
Kindly update as its mention the margin for chemical drums are 10% of its volume. If the tank is of 2000 liters or above then what would be the height of the containment with the provision of 10% increased area of its total volume.
Brittanysays:
11/13/2017 at 10:16 amThere are a few regulations that may apply to this situation. The EPA requires secondary containment for drums and other containers, including tanks, that are storing hazardous waste. The secondary containment system must be capable of containing either 100% of the largest container in the system or 10% of the total volume of all containers stored in the system, whichever volume is greater.
If the only container in your secondary containment area is the 2,000 liter tank, the containment system would need to be able to contain all 2,000 liters, not just 10% of that.
If the tank contains an oil product, and your facility stores 5,000 liters or more in aboveground containers and/or tanks, SPCC rules would apply. This regulation also requires secondary containment. Because secondary containment systems and devices are designed to prevent spills from leaving the containment area, you should have a secondary containment system that is capable of containing your worst case scenario spill.
If a leak or spill from the tank could enter a waterbody, Stormwater rules would apply. Providing a secondary containment system that is capable of holding the entire contents from a spilled tank would be a best management practice that would prevent a release from entering a waterbody.
Scottsays:
08/03/2018 at 4:43 pmWe will be bringing 33 each 55gal bbl of hydraulic oil to our facility in New Mexico. We do not normally stock more than 1 55gal bbl of oil but we are doing oil changes for all of our hydraulic units. What kind of secondary containment is required in New Mexico while we have this product on site?
Karensays:
08/06/2018 at 2:26 pmHi Scott,
I’m happy to try to help. This situation is subject to EPA’s Stormwater and SPCC regulations if there is a potential for an oil spill from your facility to reach navigable waters and cause a sheen on the water’s surface or adjoining shorelines. Those rules require you to identify potential spill hazards and to establish plans, procedures and best practices to prevent releases. The regulations do not demand specific BMPs, but secondary containment devices are a well-recognized BMP for keeping spills in check.
The SPCC rule applies to facilities that use or can store over 1,320 gallons of oil above ground or 42,000 gallons underground. When you calculate whether the rule applies to your site, you must include containers and oil-filled equipment that can hold at least 55 gallons of oil. In your case, the 33 drums of oil equal 1,815 gallons on top of the capacity for oil in your hydraulic units.
The SPCC rule describes two types of secondary containment: general and specific. (Read more in our article here: https://www.newpig.com/expertadvice/shedding-light-on-spccs-secondary-containment-requirements/). All bulk containers (those able to hold at least 55 gallons of oil) must have specific containment that is capable of “addressing a major container failure.”
General secondary containment rules require facilities to address the most likely discharges and to have a plan to handle those. For example, if a site identifies that bulk unloading of fuel into a storage tank could create the potential to spill 50 gallons, the facility might choose to provide secondary containment in this area and/or have spill kits readily available to clean up the spill before it can reach a drain or waterway.
Like the Stormwater rule, the SPCC rule does not specify the use of particular types of containment systems or devices. That is up to you based on your situation. If you will be making oil changes periodically, it might make sense to dedicate a storage area for the drums with an impervious floor and containment walls, or to purchase secondary containment pallets or decks. If this maintenance is infrequent, temporary secondary containment solutions, such as collapsible pools, might be a better fit. Just be sure to include in your plans both a description of your secondary containment system and your rationale for choosing it.
Thank you for asking this question. Feel free to follow up if you need more information.
Logansays:
11/12/2018 at 5:22 pmI know federal epa requires you to have secondary containment for 10% of the volume of containers or the volume of the largest container, whichever is greater. However some states are more stringent and require 110%. Do you know where I could find which states require the 110%?
Brittanysays:
11/15/2018 at 12:31 pmHi Logan,
Some states are more stringent and do require secondary containment systems that are capable of holding 110% of the total volume. Because this requirement can stem from a number of different requirements, there really isn’t a concise list of states requiring 110% containment.
In addition to the RCRA requirements, two of the regulations and standards that could necessitate 110% containment are:
Hope this info helps! If you have any other questions please let us know.
Thanks,
Brittany
Rodney Kirbysays:
01/11/2019 at 5:27 pmDoes the EPA allow for new oil to be stored outside of secondary containment if the oil is in its original container and unopened? Such as a pallet of 5-gallon oil jugs.
Additionally, could you please reference EPA documentation in regard to the question.
Isabella Andersensays:
03/04/2019 at 2:08 pmHi Rodney, when you’re looking at the need for secondary containment, several different rules can come into play. Fortunately, in this case, we can eliminate a few:
Because this is new oil, RCRA rules would not apply because the oil is not a waste [40 CFR].
The Management of Used Oil Rule [40 CFR 279] doesn’t apply because this is new oil, not used.
Because the oil is in 5-gallon containers, SPCC does not apply to these containers because they hold less than 55 gallons [40 CFR 112.1(d)(5)].
The rule that may apply, however, is EPA’s Stormwater Regulation. Oil is a pollutant – it doesn’t matter what size the container is or whether the oil is new or used. So, if a spill from one of these 5-gallon jugs has the potential to reach and pollute a navigable waterway from a point source at your facility, (storm drain, outflow pipe, ditch etc.) EPA’s Stormwater Rules apply [40 CFR 126].
If this rule applies to your facility, your facility’s Stormwater Pollution Prevention Plan (SWPPP) needs to list the best management practices (BMPs) that are in place to prevent pollution. Providing secondary containment is one of the solutions or BMPs that may be used to prevent spilled oil from reaching a navigable waterway. It’s also one of the most commonly used best management practices, along with good housekeeping practices and having effective spill prevention and response plans.
Outside of regulatory requirements, a practical reason for providing secondary containment for new oil containers is housekeeping. Even if the oil can’t reach a drain or otherwise cause pollution, it will create a slippery mess. If that mess is contained in a spill deck or berm, it still needs to be cleaned up, but the spill is in a defined area – not creating a slip hazard in aisle or sneaking off toward sensitive areas.
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