June 08, 2020





What are the specific requirements for secondary containment of oil containers at SPCC-regulated facilities?

The whole containment system, including the walls and flooring, must can consisting of oil and must be constructed so that any discharge from a main containment system, such as a tank or pipeline, will not leave the containment system prior to cleanup takes place (40 CFR 112.7( c)).

Exceptions use to certified oil-filled operational devices and flowlines and intrafacility event lines at oil production centers.

Here's more on streamlining secondary containment requirements.

Owners and operators of facilities subject to SPCC requirements should provide secondary containment for their bulk storage container installations (other than mobile refuelers and other non-transportation-related tank trucks) that can holding the contents of the largest single container plus adequate freeboard to consist of rainfall (40 CFR 112.8( c)( 2 )). What does EPA think about adequate freeboard?

A 25-year, 24-hour storm occasion standard is an appropriate standard of adequate freeboard for most centers. Nevertheless, EPA did not promote this standard due to the fact that of the difficulty and cost for some centers to acquire this storm event data.

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Does EPA have a main choice contingency plan or secondary containment for SPCC Planning purposes?

EPA does not think that a contingency strategy is a more suitable option to secondary containment. EPA's position is that secondary containment is preferable due to the fact that it might prevent a discharge that may be hazardous. A contingency plan is a plan for action when the discharge has currently occurred. Nevertheless, if secondary containment is not practicable, the owner or operator should offer a contingency plan and take other actions as needed.

Must owners or operators of centers based on SPCC requirements offer secondary containment, as needed by Section 112.8( c)( 2 ), for oil-filled equipment, such as transformers?

Owners or operators must provide secondary containment for all bulk storage container installations, except mobile refuelers and other non-transportation-related tank trucks. Oil-filled electrical equipment is particularly excluded from the definition of "bulk storage container."

Hence, the secondary containment requirements of 40 CFR 112.8( c)( 2) are not applicable to oilfilled electrical devices, such as transformers.

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What are the secondary containment requirements for single-compartment and manifolded tanks?

The SPCC requirement for secondary containment requirements connects to the capability of the biggest single compartment or container. Permanently manifolded tanks are tanks that are developed, set up, or operated so that the multiple containers operate as a single storage system. Containers that are permanently manifolded together might count as the "largest single compartment."
See tomorrow's Advisor for more secondary containment FAQs.

See tomorrow's Advisor for more secondary containment FAQs.