Secondary containment for each container under SPCC

Pursuant to 40 CFR §112.7(c), facilities subject to SPCC must provide containment or diversionary structures or equipment to prevent discharges as described in §112.1(b). Additionally, facilities must construct all bulk storage container installations (except mobile refuelers) to provide a secondary means of containment for the entire capacity of the largest single container and sufficient freeboard to contain precipitation (§112.8(c)(2)). Must a facility that has numerous 55-gallon drums provide separate containment systems for each drum to meet the general secondary containment requirements in §112.7(c) or the specific secondary containment requirements in §112.8(c)(2)?

No, it is not necessary to provide separate containment systems for each individual container or piece of equipment. The SPCC Plan preparer may choose to design facility drainage to provide a common collection area for multiple containers, piping, or oil-filled equipment located at the facility. In the specific secondary containment requirements in §112.8(c)(2), the term bulk storage container installation refers to an assemblage of bulk storage containers, many of which are separated by the types of product that they store. Owners or operators must ensure each bulk storage container meets the requirements in §112.8(c)(2), either individually or as part of a bulk storage container installation.

Additional information about the SPCC secondary containment requirements is available in Chapter 4 of the SPCC Guidance for Regional Inspectors.