Chapter 4 Secondary Containment and Impracticability

1 Chapter 4 Secondary Containment and Impracticability Introduction The purpose of the SPCC rule is to prevent discharges of oil into navigable waters of the United States and adjoining shorelines. One of the primary ways the rule sets out to accomplish this goal is by requiring Secondary Containment . 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. The system provides temporary Containment of discharged oil until the appropriate actions are taken to abate the source of the discharge and remove oil from areas where it has accumulated to prevent it from reaching navigable waters or adjoining shorelines. The rule includes two categories of Secondary Containment requirements: A general provision addresses the potential for oil discharges from all regulated parts of a facility.

2 The Containment method, design, and capacity are determined by good engineering practice to contain the most likely discharge of oil until cleanup occurs. Specific provisions address the potential of oil discharges from areas of a facility where oil is stored or handled. The Containment design, sizing, and freeboard requirements are specified by the SPCC rule to address a major container failure. The general Secondary Containment requirements are intended to address, in accordance with good engineering practice, the most likely oil discharges from areas or containers such as mobile refuelers and other non-transportation-related tank trucks; oil-filled operational or process equipment; (non-rack) transfer areas; or piping. In determining the method, design, and capacity for general Secondary Containment , only the typical failure mode needs to be considered. The specific Secondary Containment requirements are intended to address a major container failure ( , the entire contents of the container and/or compartment) associated with a bulk storage container; single compartment of a tank car or tank truck at a loading/unloading rack; mobile/portable containers; and production tank batteries, treatment, and separation installations (including flow-through process vessels and produced water containers).

3 These specific provisions (see Table 4-1 in Section ) provide explicit requirements for sizing, design, and freeboard. The purpose of this Chapter is to clarify the relationships among the various general and specific Secondary Containment requirements of the SPCC rule, and to illustrate how these requirements apply. This Chapter also discusses the rule's Impracticability determination provision, which may be used when a facility owner/operator cannot install Secondary Containment by any reasonable method. The additional requirements that accompany an Impracticability determination, the documentation needed to support such a determination, SPCC GUIDANCE FOR REGIONAL INSPECTORS 4-1. December 16, 2013. Chapter 4: Secondary Containment and Impracticability Determination and the role of the EPA inspector in reviewing Secondary Containment requirements and Impracticability determinations are also discussed. The remainder of this Chapter is organized as follows.

4 Section provides an overview of the SPCC rule's general Secondary Containment provisions, including exceptions to the requirement to provide Secondary Containment . Section discusses the specific Secondary Containment requirements and the meaning of sufficient freeboard.. Section discusses issues related to Secondary Containment , such as active versus passive measures, the sufficiently impervious requirement, facility drainage, and man-made structures. Section describes the Impracticability determination provision. Section describes required measures when Secondary Containment is impracticable. Section discusses how the Impracticability determination may be used in certain circumstances. Section discusses alternative measures in the rule in lieu of Secondary Containment at oil production facilities. Overview of Secondary Containment Provisions The SPCC rule includes several Secondary Containment provisions intended to address the various activities or locations at a facility where oil is handled.

5 This section differentiates among these general and specific Secondary Containment provisions. Table 4-1 lists all the Secondary Containment provisions of the SPCC rule for different types of facilities. SPCC GUIDANCE FOR REGIONAL INSPECTORS 4-2. December 16, 2013. Chapter 4: Secondary Containment and Impracticability Determination Table 4-1: Secondary Containment provisions in 40 CFR part 112. Type of Facility Secondary Containment Rule Section(s). All Facilities General Containment (areas with potential for discharge, (c). such as piping including flowlines, bulk storage containers, oil-filled operating and manufacturing equipment, and oil equipment associated with transfer areas). Mobile refuelers and other non-transportation-related tank (c). trucks. Loading/unloading racks** (h)(1). Qualified Oil-Filled Operational Equipment (c) or alternate measures in (k). Onshore Storage Bulk storage containers (except mobile refuelers and other (c)(2) or (c)(2).)

6 Non-transportation-related tank trucks). Mobile or portable oil containers (except mobile refuelers (c)(11) or (c)(11). and other non-transportation-related tank trucks). Onshore Oil Bulk storage containers, including tank batteries, (c)(2). Production separation, and treating facility installations (except for flow-through process vessels and produced water containers). Flow-through process vessels (c)(2) or (c) and alternate measures in (c)(5). Flowlines and intra-facility gathering lines (c) or alternate measures in (d)(3). Produced water containers (c)(2) or (c) and alternate measures in (c)(6). Onshore Oil Drilling Mobile drilling or workover equipment (c). and Workover Offshore Oil Drilling, Oil drilling, production, or workover equipment (c). Production, and Workover ** Although this requirement applies to all facilities, loading/unloading racks are generally not present at typical oil production facilities or farms, as discussed in Section Figure 4-1 through Figure 4-4 illustrate the relationships between the Secondary Containment requirements at various types of facilities.

7 EPA inspectors should use the flowchart that corresponds to the type of facility he or she is inspecting (see the figure description for each flowchart). The second row of each flowchart identifies the types of containers, equipment, and activities or areas where oil is handled, with SPCC GUIDANCE FOR REGIONAL INSPECTORS 4-3. December 16, 2013. Chapter 4: Secondary Containment and Impracticability Determination reference to the appropriate Secondary Containment rule provision. The flowcharts note the use of Impracticability determinations and additional design considerations for other areas with the potential for discharge. Figure 4-1: Secondary Containment provisions in 40 CFR part 112 related to onshore storage facilities ( and or ). SPCC GUIDANCE FOR REGIONAL INSPECTORS 4-4. December 16, 2013. Chapter 4: Secondary Containment and Impracticability Determination Figure 4-2: Secondary Containment provisions in 40 CFR part 112 related to onshore oil production facilities ( and ).

8 Oil production facilities do not typically have loading/unloading racks as defined in , but when oil is transferred through a loading/unloading rack, sized Secondary Containment in accordance with (h)(1). applies. Oil transfers to trucks within oil production facilities normally occur at transfer areas that are subject to general Secondary Containment in accordance with (c). SPCC GUIDANCE FOR REGIONAL INSPECTORS 4-5. December 16, 2013. Chapter 4: Secondary Containment and Impracticability Determination Figure 4-3: Secondary Containment provisions in 40 CFR part 112 related to onshore oil drilling and workover facilities ( and ). SPCC GUIDANCE FOR REGIONAL INSPECTORS 4-6. December 16, 2013. Chapter 4: Secondary Containment and Impracticability Determination Figure 4-4: Secondary Containment provisions in 40 CFR part 112 related to offshore oil drilling, production, and workover facilities ( and ).79 P. General Secondary Containment Requirements At a regulated facility, all areas and equipment with the potential for a discharge are subject to the general Secondary Containment provision, (c).

9 These may include bulk storage containers;. mobile/portable containers; mobile refuelers and other non-transportation-related tank trucks; oil production tank batteries, treatment, and separation installations; pieces of oil-filled operational or manufacturing equipment; loading/unloading areas (also referred to as transfer areas); and piping; and may include other areas of a facility where oil is present. For the areas where specific (sized) Secondary Containment is also required (as described in Section ), this sized Secondary Containment fulfills the general Secondary Containment requirements. The general Secondary Containment provision requires that these areas be designed with appropriate Containment and/or diversionary structures to prevent a discharge in quantities that may be harmful ( , a discharge as described in (b)). Appropriate Containment must be designed to address the most likely quantity of oil that would be discharged from the primary Containment system ( , container, 79.)

10 Onshore components associated with offshore facilities may also be subject to or requirements (as applicable). SPCC GUIDANCE FOR REGIONAL INSPECTORS 4-7. December 16, 2013. Chapter 4: Secondary Containment and Impracticability Determination equipment), such that the discharge will not escape Secondary Containment before (c). cleanup occurs. In determining the most likely Provide appropriate Containment and/or diversionary structures quantity, the facility owner/operator should or equipment to prevent a discharge as described in (b). except as provided in paragraph (k) of this section for qualified oil- consider factors such as the typical failure filled operational equipment, and except as provided in mode ( , overfill, fracture in container wall, (d)(3) for flowlines and intra-facility gathering lines at an oil etc.), resulting oil flow rate, facility personnel production facility. The entire Containment system, including walls response time, and the duration of the and floor, must be capable of containing oil and must be discharge.