What Are Oilfield Secondary Containment Requirements?

October 3, 2018
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Oil and gas production is a highly regulated industry and rightly so. Oils spills such as the devastating Exxon Valdez oil spill in 1989 have been known to negatively impact drinking water, cause public health crises, and ravage natural resources and wildlife. How oil and gas is extracted, processed, transported, and stored is extremely important to the oil companies, the communities, the local and federal government, and the environment. The goal of oilfield storage and containment is to have zero probability of the crude materials reaching any navigable waters in the United States to prevent a natural disaster and contamination of potential drinking water. Thus, the EPA now requires secondary containment systems in these industries in the event of the failure of the primary containment systems.

The primary containment systems usually consist of bulk storage tanks or containers, pipelines or piping, or mobile or portable containers. The EPA requires a secondary containment system to be built or constructed around the primary system to accomplish the following goals:

  1. to protect the environment from hazardous spills
  2. to act as a fire wall between the hazardous fluid and its surroundings, and
  3. to ensure that those companies responsible for extracting the oil don’t lose valuable product because of a spill.

The secondary containment system allows for a safe, temporary place that the discharged oil can remain until the appropriate actions are taken to stop the source of the leak or discharge. It also allows time for the removal of the oil from all areas where it has collected to keep it from reaching any groundwater or adjoining shorelines and negatively impacting the environment and any surrounding wildlife, birds, or ecosystems.

The EPA does not stipulate what exactly a secondary containment system must be, but it does require that the secondary system be able to hold the entire volume of what is contained in the primary system (plus any rainfall if applicable). This means that your secondary containment system can be anything from a dike, berm, or concrete wall that surrounds your primary container to simple trays, spill pallets, absorbents, or even a sloped room that allows the oil or fuel to collect at one end until it can be cleaned up. (If you need assistance determining how large of a secondary containment system you require, the EPA has a worksheet on their website to help you calculate what your specific needs are.)

Retention ponds are also valid secondary containment systems. Building a retention pond allows you to choose the most appropriate materials for the substance you are trying to contain. Oil and fuel sometimes prove difficult to contain because most liner materials themselves are often made of oil by-products – an appropriate geomembrane liner is needed for such a situation. Companies such as Western Liner offer a liner that contains a specially formulated plasticizer called Elvaloy that is a better choice for long-term oil and fuel containment.

You must also have a Facility Response Plan (FRP) that addresses the steps needed in the event of a spill or leak from the primary AND secondary containment systems. Training your employees and personnel on what to do in the case of a leak is just as important as the materials you use to construct your containment systems. The EPA has provided extensive guidelines for developing an FRP on their website. Between a comprehensive FRP and reliable secondary containment systems, oil and other harmful substances can stay contained.

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