Facilities with aboveground storage tanks (ASTs) holding potential pollutants of any kind—oils, lubricants, greases, fuels, kerosenes, etc.—are likely to be subject to the Spill Prevention, Control, and Countermeasure (SPCC) regulation (40 CFR Part 112) required by the United States Environmental Protection Agency (EPA).
Some ASTs in the U.S. may also need to meet additional state or local regulatory requirements, while ASTs outside of the U.S. may be subject to similar regulations as well.
Regardless, implementing secondary containment protocols for aboveground storage tanks should be a best practice for any facility, no matter where it’s located.
Think of it as a security blanket for your operation. For a relatively small investment, you’ll sleep better at night. It’s like having a spill pan under your washing machine or water heater. When either device springs a leak, you’ll be very happy you had this backup device in place.
The EPA SPCC rules apply to businesses and farms that might not seem at first glance to be in need of such regulations. However, even relatively small ASTs fall under the rules’ guidelines, which are intended to safeguard the environment from oil and chemical spills. To put this into perspective, consider a typical residential home’s heating oil tank, which averages about 275 gallons, but can sometimes have capacities as large as 1,000 gallons. A single tank just slightly larger than that would fall under SPCC regulations. In fact, if your tank holds 1,320 gallons or more, it is subject to SPCC guidance.
Now, you might be thinking something like this: “That’s a pretty big tank. I don’t have anywhere near that storage capacity in my facility.” The problem is that the rule is additive. In other words, you might have a couple of 275-gallon heating oil tanks; a 500-gallon diesel fuel tank; a few scattered 55-gallon drums of mineral spirits, lubricating oil, kerosene, even vegetable oils. After adding up all these gallons, as the SPCC regulation requires, you’re probably well beyond the 1,320-gallon baseline. In other words, you’re subject to the EPA’s SPCC rules — like it or not.
A key element of adhering to the SPCC requirements (and avoiding hefty fines or other penalties) is implementing proper secondary containment methods. The EPA’s document providing SPCC guidance for regional inspectors states that a “secondary containment system provides an essential line of defense in the event of a failure of the primary containment, such as a bulk storage container, a mobile or portable container, piping, or oil-filled equipment.”
Even relatively small operations (family farms, for instance) need a written plan to be in compliance. You’ll need to account for any bulk storage container 55 gallons or larger. That’s right — every 55-gallon drum on your site needs to be included in the plan. But with the types of primary containers so diverse, how can you deal with all the various possibilities for backup protection? Let’s consider a few of the alternatives.
The most simple method of containment might be a drum around the drum. This solution is easily applied by dropping the metal drum into the plastic container. But what if you have more than one drum? Spill pallets provide stable platforms for up to four drums and meet all EPA requirements.
For larger tanks designed to hold oil and fuel above ground, the need for secondary containment is critical. Most of these tanks hold between 250 and 750 gallons of oftentimes flammable liquids. To capture any spills, a special containment sump is usually required, which can safely hold the contents of the tank and then some. These sumps are usually available with a drain to make spill recovery much easier.
Larger Container Installations
Sometimes called Intermediate Bulk Containers (IBCs), these vessels or tanks can hold hundreds or even thousands of gallons. If they spring a leak, the environmental impact could be significant, which makes containment crucial. IBC spill pallets offer protection from this exposure, securely holding large volumes in place until the spill can be mitigated and controlled.
Oil tankers, gasoline or diesel tankers, waste-oil tractor-trailers, food-grade oil transport vehicles, you name it. When they’re parked on-site, they need to comply with SPCC rules. One proven method to contain these container trucks is a modular containment berm, which is designed to prevent spills from vehicles of all shapes and sizes. There are also secondary containment solutions designed for the railroad industry.
Your specific secondary containment requirements are likely to be as diverse as the containers you’re using. And your SPCC plan needs to include them all. Be sure to consider the many options available to protect your organization—and the environment —from the high cost of spills.