Everything Inquiring Minds Want to Know About Spill Containment

What do the terms spill containment, spill prevention, spill response, and secondary containment mean?

Spill Containment

Spill containment refers to a process in which spillage or leakage of a liquid or other hazardous material is kept within a barrier. Containment minimizes the risk of the hazardous materials being absorbed into the ground or reaching inland waterways, shoreline waters, or ocean water. It also minimizes the risk of human exposure to hazardous materials.

The best way to contain a spill depends on the type of chemical or oil involved, the size of the primary container, the type of machinery or storage facility where a spill or leak could originate from, and the equipment and vehicles involved. You must also consider where the equipment and vehicles are typically used.

For example, a mobile refueler that only transports fuel onsite at a non-transportation facility and qualifies for “general secondary containment” would use active containment measures. A rapid response team would quickly utilize a spill kit in the event of a fuel leak. A construction company that temporarily parks a mobile generator on different job sites needs a transportable generator spill containment berm for the most efficient spill containment. Plus, there are many types of spill containment barriers, including berms, booms, non-absorbent dikes, absorbent socks, and drainage sumps that may be used.

The spill containment process is part of a larger spill response plan.

Spill prevention is another important concept in spill containment and has two meanings in the big picture of the Environmental Protection Agency’s (EPA) Spill Prevention, Control, and Countermeasure (SPCC) rule. There are two elements of spill prevention.

Prevention Operating Procedures

The SPCC rule refers to preventing oil leaks or spills from occurring in the first place. The rule requires a Facility Response Plan (see the next section: Spill Response). In the plan, you will identify and analyze potential spill hazards and previous spills. Determining the most likely sources of oil spills and leaks is necessary for identifying the appropriate detection procedures and the response steps.

The operating procedures for spill prevention are best practices for hazardous materials storage and handling. You will address topics like how the oil is stored; loaded and unloaded and the equipment involved; and the location of each oil container.

Spill Control to Minimize Environmental Damage

The SPCC rule also requires spill control measures in the event oil does leak or spill. Spill control refers to preventing the oil or other petroleum-based products from directly reaching navigable waters or shorelines or via the ground.

This section identifies the spill prevention equipment needed at various locations most likely to experience a spill or leak. The specific equipment depends on the primary containment systems because they have different configurations and locations (i.e., stationary generator versus a mobile refueler, storage tank versus barrel) and different potential spill volumes.

You may need stocked spill kits, different types of berms, spill trays and a variety of berm accessories, like ground covers, rubber matting and spill berm hose bridges. The goal is having all the right spill control equipment in place or ready for rapid implementation to quickly minimize the amount of hazardous materials reaching soil or waterways.

Adhere to all laws and regulations for spill prevention and control: Though the SPCC drives the legal spill containment requirements for oil and petroleum product leaks and spills, you need a response plan that covers all hazardous materials, and not just oil, to meet federal laws and OSHA rules, Department of Transportation rules, state and local rules and so on – oil, vehicle fuel, animal fat, chemicals or any other material that causes harm to humans, people, plants or animals.

Spill Response

Spill response is a comprehensive plan for containing and cleaning up a spill or leak while protecting human health and the environment. The EPA requires a Facility Response Plan at every facility storing and using oil. Key elements of an SPCC plan include information like the identification of emergency notification personnel and the response actions for small, medium, and large spills. It also requires a detailed implementation plan for response, containment, and disposal of the spilled or leaked hazardous material.

OSHA also has spill control and containment requirements for hazardous materials, focusing on protecting the safety and health of employees. Employers are required to have a site safety and health program that includes a spill containment section.

Secondary Containment

The Resource Conservation and Recovery Act (RCRA) requires containment and secondary containment systems, codified in Title 40 Code of Federal Regulations (CFR) Part 264. The first general requirement is for portable bulk storage containers, like 55-gallon drums. The second general requirements are for large stationary containers. Adhering to the relevant laws, including properly sizing the containment system via a secondary spill containment calculation, is critical to avoid harming people and the environment and being heavily fined thousands of dollars. The EPA and OSHA are the oversight agencies.

Secondary containment is defined as “a barrier, structure, or device able to hold a legally specified volume of regulated hazardous materials that could spill or leak.” It is a backup solution to a primary container holding hazardous chemicals. Primary containers can and have failed. Effective secondary containment solutions include spill decks, sloped rooms, dikes, concrete walls, absorbents, and berms.

This is where it can get confusing. You need a spill containment program and system and a secondary spill containment program and system. The goal is to prevent or minimize spillage and leakage from the primary container reaching the ground or waterways, so the secondary spill containment unit confines the liquids.

The EPA’s SPCC Rule does not specify particular strategies for discharge prevention. Still, it does require secondary containment for any facility with “bulk storage containers, large or small, manned or unmanned, and for facilities with bulk storage containers that also have oil-filled equipment.” A bulk container is defined as a container with a capacity of 55 gallons or more storing oil. Following are some of the bulk containers and equipment that need secondary containment.

• Containers
• Tanks
• Drums
• Portable totes
• Mobile totes
• Hydraulic systems
• Lubricating systems
• Transformers
• Heat transfer systems
• Machining coolant systems
• Gearboxes
• Electrical switches
• Circuit breakers

The EPA also enforces the Clean Air Act requirements to prevent accidental releases of chemicals at stationary facilities. A facility must develop a Risk Management Plan that addresses three areas: hazard assessment of worst-case and alternative accidental releases, a prevention program, and an emergency response program. The EPA uses the OSHA definition of hazardous chemicals because these are the chemicals that pose a hazard to humans, plants, and animals.

There are specific rules pertaining to the required secondary containment size. In 40 CFR 264.175, paragraph B, you find the secondary containment base and capacity requirements. PacTec summarized the rules in its article How to Calculate the Capacity of Secondary Spill Containment Berms, including links to EPA worksheets and examples of a secondary containment calculator.

In 40 CFR. 264.193 are found the rules concerning secondary containment systems for tanks and tank systems to prevent the release of hazardous waste. The systems must prevent the hazardous liquid from reaching the soil, groundwater, or surface water. In subsection d, it says an external secondary containment for tanks must be able to contain 100 percent of the capacity of the largest tank in its boundary; be designed to prevent run-on or precipitation infiltration; be free of gaps or cracks, and be large enough to completely surround the tank and cover the earth likely to be contaminated by a waste spill or leak.

There are also rules for secondary containment vaults and double-walled tanks and requirements for the ancillary equipment used with secondary containment. Aboveground piping, welded joints, pumps, and valves must meet the same requirements as the secondary containment vessel for materials, leak detection, etc.

There are two most common types of spill containment materials for hazardous liquids: polyethylene and steel. These two materials do the best job of meeting the many EPA and SPCC regulations.

When should I use a polyethylene spill containment?

High-density polyethylene (HDPE) offers an excellent chemical-resistant spill containment option and can manage a wide range of chemicals. It is a high-quality thermoplastic that resists rough use. It is an excellent choice when:

• Storing corrosive or reactive chemicals because they will not rust or corrode
• Corrosion of steel is likely because of the environment
• Temperature extremes are not likely because they can crack or melt in very high heat or fire or during exceptionally frigid weather
• Dedicated grounding points or bonding are not required, so generally used with corrosive chemicals and non-flammable liquids
• Less expensive than steel

When should I use a steel spill containment?

• When needing containment less prone to cracking or softening in extreme temperatures
• When storing fuels, solvents, and other flammable liquids
• When dedicated grounding points or bonding are required
• When corrosive environments and high humidity are present

Following are some of the major industries where spill prevention and containment are required, along with a few examples of spill containment and secondary spill containment options.

Chemical Plants

Chemical plants are very prone to fluid and solid form spills and leaks of hazardous materials, since they manufacture or process large amounts of chemicals. These plants must take great care to follow EPA and OSHA regulations to minimize the chances of contamination of the environment with, and human exposure to, toxic, corrosive, flammable or chemically reactive chemical levels.

Chemical plants manufacture or chemicals in processing operations across industries. The EPA reports chemical manufacturing is used in industries that include pharmaceuticals, pesticides and fertilizers, resins and synthetic rubber, coatings and adhesives, basic chemicals and other chemical products. The plants rely on large energy generating equipment, large primary containment storage tanks and portable equipment like drums and transport vehicles, all of which are subject to chemical leaks and spills.

Chemical manufacturing includes industrial plants that use basic chemicals to produce products, like paint, pesticides, plastics, petroleum products and glues. Some plants manufacture, store and transport liquid and solid chemicals for sale to product manufacturers, while others utilize, store and transport chemicals for their own business operations. Spill containment and secondary spill containment solutions are required either way. A chemical plant will use a variety of secondary spill solutions, like spill containment kits, the BermPac® Hurdle-Bracket Spill Containment solution for long-term drum containment and the BermPac® Foam Sidewall Spill Berms for tanker trucks.

Oil and Gas, Including Refineries

Oil and gas drilling and refining operations are naturally susceptible to accidental and incidental spills, especially during crude oil transloading. These facilities have bulk storage containers, mobile storage containers, mobile refuelers, oil production tank batteries, transfer areas, and many other pieces of equipment.

Spill containment and secondary spill containment solutions can take many forms, depending on the situation. For example, a tanker truck can use Industrial Spill Trays, available in multiple sizes, to contain chemicals and equipment oil leaks and spills. Hinge Bracket BermPac® Spill Containment Berms help companies meet SPCC regulations for applications like frac tanks, light towable equipment, pumps and generators, and decontamination wash stations. You can park bulk storage containers on large stationary foam berms.

Municipality and Utility Substations

Municipal and utility substations utilizing oil-filled equipment and large storage tanks have containment needs in electrical power, nuclear power, natural gas, oil and gas, water and waste treatment plants, and rail. They maintain bulk storage and utilize drums and oil-filled equipment, and tanks. The secondary containment solutions meet transformer and generator spills and leaks, incidental spills from vehicles, equipment drips, spills during railroad car transfers, and more. Wire Bracket Spill Containment BermPacs® work for drum storage, tanker trunks, and industrial equipment.

Railroad Companies

Class One Rail Companies, the largest industrial companies, and other railcar and railroad companies authorized to transport hazardous materials to different locations are required to have secondary spill containment systems. Transloading is the transfer of liquids from railcars to trucks, and transload facilities can quickly install portable spill containment solutions to meet SPCC regulations. PacTec’s railcar liners and tarps also enable safe transportation of contaminated waste.

Electrical Power Companies

Electrical power plants use large generators, transformers, fuel tanks, chemical tanks, tanker trucks, rails cars, and other equipment and systems that require oil and vehicle fuel. Electrical power companies can use most of PacTec’s portable and stationary spill containment berms at their facilities and job sites.

Military and Government Operations

Military and government operations have a high likelihood of leaks and spills from normal operations, including:

• Military vehicles, including fuel tankers and mobile refuelers
• Fuel storage and transportation
• Military Aviation Ground Equipment (AGE) storage and use
• Hazardous waste storage and transport
• Pipeline delivery
• Mess hall cooking and vegetable oil

Military and government operations also often use earthen or porous berms, so the use of berm liners, in addition to the other barriers and berm options for storage tanks, equipment, and vehicles, is critical.

Construction Companies

Construction companies using standing equipment like generators, compressors, bulk tanks, drums, and large and small equipment and vehicles can utilize pop-up spill containment berms. These are ideal for capturing the oil and grease while washing off equipment and serve as a decon wash pad.

Farms

EPA SPCC regulations for agriculture apply to “farms that sell $1,000 or more of agricultural products; stores, transfers, uses, or consumes oil or oil products; and has a reasonable expectation of a discharge of oil into U.S. waters or shorelines.” Farms usually have above-ground containers like tanks, industrial-grade drums, generators, and farming equipment storing hazardous chemicals, including fuel, pesticides, and fertilizers. Pop-up Spill Containment Berms work for generators and farming equipment, while Hurdle-bracket Spill Containment berms work well for long-term drum containment, tote containment, and roll-off containers.

Following are some common questions to guide your decision-making and spill containment evaluation process:

Is the system chemically compatible with the type of hazardous materials stored or used in my equipment?

The chemical spill containment system you choose needs to be compatible with the type of hazardous material that could leak or spill. Previously, we discussed the two primary types of materials used in containment systems. First, evaluate the characteristics of the possible leaked material, i.e., type, how it interacts with different materials upon contact, corrosiveness, and disposability. Choose the system with the best chemical resistance, makes disposal simple, and uses materials that best resist cracks and gaps.

What containment volume and weight are needed?

The federal regulations require spill containment systems to have the capacity to contain 10 percent of the volume of the containers holding the hazardous materials or the volume of the largest container. The secondary containment calculator guides the capacity calculation. The weight is calculated while the containment system is in stationary mode, called static weight capacity.

How and when will I need to move the containment systems?

Some businesses install their spill containment system and do not need to move it. Perhaps a piece of equipment is permanently located, or a semi-trailer is parked for storage use.

Many companies need portable spill containment options because they frequently move their equipment or containers. Portable containment systems are transported without the containers on them. The larger ones are moved via forklift or pallet jacks, but portable solutions are small enough to fold up and store in a truck.

What legal requirements do I need to follow?

The EPA website lists regional EPA offices and the phone numbers of divisions responsible for secondary containment compliance. Regional offices can direct you to the state EPA agencies that can explain state codes. You can also ask if the EPA knows the AHJ (authority having jurisdiction) for environmental harm in your area.

Take Advantage of PacTec’s Expertise in Spill Containment Solutions

Are spill containment and secondary spill containment complex topics? Yes, they are because of the variety of hazardous materials involved, the variety of job site needs, and government regulations. It is precisely why PacTec has developed many spill containment solutions to simplify the decision-making process. PacTec sales representatives are specialists within U.S. regions and are always ready to help you determine the best spill containment option for your business.