Amanda Czepiel, J.D., SPCC Expert
aczepiel@blr.com
How do I select the appropriate secondary containment?
Because EPA does not dictate specific types of secondary containment to be used in specific situations, owners and operators of SPCC-regulated facilities should use professional judgment to determine reasonable secondary containment requirements that fit each individual circumstance. Multiple factors should be considered to determine what needs secondary containment (i.e. what areas present a potential for discharge).
First, to assess spill risks, the area and its surroundings should be evaluated and possible discharge scenarios considered. Ask the following questions:
- 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?
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Location, type, and quantity of stored materials should be taken into account along with the topography (slope and gradient) and the proximity to water or other environmentally sensitive areas to determine whether a spill could reach a navigable water.
How do I determine secondary containment capacity?
The SPCC rule does not specifically define the term “freeboard,” nor does it describe how to calculate the 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 percent of the volume stored
In addition to these accepted methods, the following worksheets will provide some great guidance on what secondary containment will be sufficient in four specific scenarios:
- Single vertical cylindrical tank inside a rectangular or square dike or berm
- Multiple horizontal cylindrical tanks inside a rectangular or square dike or berm
- Rectangular or square remote impoundment structure
- Constructing new secondary containment
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What if secondary containment isn’t practicable?
In some cases, an owner or operator may determine that secondary containment just isn’t practicable. If this determination is made, the owner or operator must clearly explain the reason for the determination in the SPCC plan. For bulk storage containers, periodic integrity testing must be conducted of the containers and any associated valves and piping. Also, an impracticability determination requires the preparation of an oil spill contingency plan and a written commitment of manpower, equipment, and materials to expeditiously control and remove any quantity of oil discharged that may be harmful.
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