Secondary Containment Structures Requirements

Steel Secondary Containment Structure In addition to developing the SPCC plan, it must contain information about containment and diversion structures at the site, other spill prevention measures routinely practiced, and steps to be taken by farm personnel in the event of a spill or major release.

To satisfy the "preventative" intent of the regulations, and the SPCC plan, a secondary containment structure will normally be required -- unless the owner-operator can "clearly demonstrate such impracticability" of secondary containment, and agrees to various requirements like periodic integrity and leak testing of tanks and piping. With new installations, substituting "double-walled" tanks for secondary containment may be allowed, but this method also requires overfill alarms and automatic shut-off devices, and it should not be used without prior EPA approval.

Concrete Structures Secondary containment structures must have sufficient holding capacity for the contents of the tank (or largest tank for multiple-tank facilities) plus a 10% freeboard. And, they must be impervious to the petroleum products stored for up to 72 hours. Earthen dikes (clay preferred), concrete or other materials may be used.

[Note -- Some state rules may be more severe in their requirements than the federal rules -- check to be sure.]

Some farm fuel suppliers can provide tanks which are an integral part of a steel secondary containment structure - Figure 1. Concrete structures - Figure 2 - can be built using the engineering practices for secondary containment set forth in MWPS-37 (Designing Facilities for Pesticide and Fertilizer Containment), which are quite adequate for fuel containment.

Covered Structure Consider covering the structure (with a canopy, tarp, etc.) - Figure 3 - to keep out rain, since accumulated minor spillage, over time, may result in a film or sheen on collected rainwater, making it legally unsuitable for discharge to the soil or drains.

Some farm fuel storage facilities may not come under the state and/or federal rules discussed here. Even so, many farmers are voluntarily choosing to implement practices to prevent or contain fuel spills or major releases because, frankly, it makes good sense to protect farm property, farm family members and employees, and drinking water supplies!

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