What People Get Confused About Secondary Containment

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

The entire containment system, including the walls and floor, should be capable of consisting of oil and must be built so that any discharge from a primary containment system, such as a tank or pipe, will not leave the containment system before clean-up occurs (40 CFR 112.7( c)).

Exceptions apply to certified oil-filled functional devices and flowlines and intrafacility event lines at oil production facilities.

Here's more on simplifying secondary containment requirements.

Owners and operators of facilities based on SPCC requirements should provide secondary containment for their bulk storage container setups (other than mobile refuelers and other non-transportation-related tank trucks) that are capable of holding the contents of the biggest single container plus adequate freeboard to contain rainfall (40 CFR 112.8( c)( 2 )). What does EPA consider sufficient freeboard?

A 25-year, 24-hour storm event requirement is a proper requirement of enough freeboard for a lot of centers. Nevertheless, EPA did not promulgate this requirement because of the trouble and cost for some facilities to get this storm occasion information.

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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 plan is a more effective 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 actually already happened. However, if secondary containment is not practicable, the owner or operator need to supply a contingency strategy and take other actions as needed.

Must owners or operators of facilities subject to SPCC requirements supply secondary containment, as required by Section 112.8( c)( 2 ), for oil-filled devices, such as transformers?

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

Thus, the secondary containment requirements of 40 CFR 112.8( c)( 2) are not suitable to oilfilled electrical equipment, 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 associates with the capacity of the biggest single compartment or container. Permanently manifolded tanks are tanks that are developed, set up, or operated so that the several containers operate as a single storage unit. Containers that are permanently manifolded together might count as the "largest single compartment."

See tomorrow's Advisor for more secondary containment FAQs.
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