The Environmental Protection Agency (EPA) may require secondary oil containment methods for most oil storage tanks depending on volume. However, they do make exceptions for situations where it is truly impractical or downright impossible to implement more than just primary containment. This is designed to protect oil producers, transport companies, and end-users like mobile refuelers from unavoidable fines or overwhelming containment requirements. Understand the difference between practical and impractical oil containment and what you’ll still need to do even if secondary containment is not required. Even if the EPA allows you to circumvent their usual regulations due to impractical requirements, you’ll have other measures to take to prevent and address spills.
Mobile Transport
Mobile transport vessels, from tanker trucks to fuel-carrying ships, are generally exempt from the usual secondary containment methods required for onshore storage. This is only true when traveling between locations. When stopped for emptying or filling, these transport vessels must meet local and federal containment regulations. Mobile refuelers in particular are exempt from most containment measures due to the specific designs of these vehicles. These units are still governed by the rules of inspection and repair for when fixed secondary containment is deemed impractical by the EPA.
Onshore vs Offshore Production
Both onshore and offshore oil production facilities share similar requirements for secondary containment from the EPA. However, most offshore facilities are more likely than their onshore counterparts to qualify for the impractical exemption on standard secondary containment. While some oil platform designs lend themselves well to containment integrated into the raised surface, others simply make it impossible to truly contain the active production areas. Onshore oil storage and processing facilities are almost always subject to secondary containment because it’s rarely completely impractical to install liners and berms. Depending on the location of the facility and its level of protection with surrounding features like dikes and berms, different EPA regulations and codes apply.
Volume of Oil
Volume is generally not one of the features of an oil storage system that determines whether containment is practical or impractical. The EPA expects you to design and implement properly sized containment even for the largest volumes of oil. If you can’t afford the amount of liner or the size of berms needed to contain the oil you’re storing, you may need to break up the facility into smaller compounds that distribute the risk of leaks over a larger area. Building new containment areas from scratch is always easier than trying to tear down and partially rebuild an existing storage system that doesn’t meet today’s EPA and state agency standards.
Container Styles
For bulk storage facilities, the use of large and fixed tanks can make it hard to improve the containment efforts later. Most types of oil containment measures are optimized for installation during the creation of new oil storage facilities, not existing ones. In-ground ponds and pits are even more challenging to contain with complete liners that run under the entire structure. If you intend to seek an exemption to containment from the EPA based on container size or style alone, make sure to document how its design is preventing containment in particular. Make sure that the periodic integrity testing required, for containers exempt from containment, won’t cost more than starting over with brand new containers.
Prior Discharges
Don’t assume that you’re free to claim an impracticability exemption just because it’s expensive or difficult to implement containment. If you have had a discharge of over 1,000 gallons of oil in the last three years, or more than two releases of over 42 gallons in the same 12 months, you’re unlikely to qualify for alternative containment arrangements. The EPA may work with you to devise a specific containment arrangement if you’re struggling with the terms set by the standard regulations. The standards are even stricter for vessels crossing navigable waters, so don’t forget your recent history of spills and discharges when planning for containment.
Dikes and Containment Walls
Dikes and berms are solid walls made from concrete, asphalt, compacted earth, or similar materials to create physical barriers against liquid loss. These containment methods are sometimes integrated into offshore platforms and facilities, but they’re most commonly used for onshore facilities instead. According to EPA regulations for all containment systems, dikes and berms must be constructed of impermeable materials that won’t let the oil seep or leech out. Concrete isn’t naturally impervious to liquids because it’s full of tiny openings that create a capillary effect. Lining dikes, berms, and other containment walls with a flexible layer of impermeable geomembrane is the best way to meet all state and federal regulations that apply to your containment system.
Drainage Systems
Existing rainwater drainage culverts and pipes for oil storage facilities are often ideal for integrating as part of a larger containment system. However, it’s not appropriate to simply let the oil and water run out of these drains and into local soil and waterways. What’s safe for storm water isn’t appropriate for wastewater mixed with oil and other byproducts. Filtration equipment and drain blocking plugs or inflation devices are all required for keeping oil from escaping a drainage system.
EPA Requirements When Containment is Impractical
Having a specific oil transport or storage arrangement as impractical for the usual containment requirements doesn’t let you off the hook completely. Some of the EPA’s requirements for alternatives to the standard containment include:
- A written contingency plan to address the immediate measures taken to control and remediate any oil spills
- Commitments of the manpower, materials, and special equipment needed to deal with potential spills
- Periodic integrity testing for all vessels, valves, and piping involved in the storage or transport system.
Depending on what containers and methods you’re using for oil storage, you’re likely under one or more of the §112 regulations from the EPA that govern oil containment. Review the lengthy publications offered by the EPA regarding this code in particular to determine exactly what practical containment measures apply to you. Exploring alternative measures for oil containment may lead you right back to choosing a flexible liner material from us here at BTL Liners. We’re also happy to help with advice on geomembranes and containment liners if you’re stuck on the selection process.
