# Secondary Containment:

Regulations & BMPs

Beth Powell

Vice

- President and General Manager New Pig Energy bethp@newpigenergy.com

# Federal Secondary Containment

Safeguarding method in addition to the primary containment system



### Specific/Sized

– Indoor: Sump capacity should contain 10% of the volume of total containers or the total volume of the largest container, whichever is greater

– Outdoor: Plus sufficient freeboard to contain precipitation



### General

– Address typical failure mode and the most likely quantity

– Passive or Active

# Regulations

EPA



# Liquids PA DEP 

# and Best Practices

API

MSC STRONGER Advisory

Commissions

& Boards

# SPCC

Spill Prevention, Control, and Countermeasure (SPCC)

– 40 CFR 112

– Monitors plans to prevent oil spills at facilities

• Oil, oil

- like and oil/water mixtures

• 1320 gallons of above

- ground storage capacity

• Potential to reach “navigable waters”

• Defines oil pollution as a “sheen” on the water

– Clarifies “facility”; can be considered mobile or portable

– Sets compliance date of November 10, 2011 for facilities that came into operation after August 12, 2002

http:// www.epa.gov/osweroe1/docs/oil/spcc/spcc_101_prod.pdf

# SPCC 40CFR112.7(c)

The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system, such as a tank or pipe, will not escape the containment system before cleanup occurs

.

At a minimum, you must use one of the following prevention systems or its equivalent:

(1) For onshore facilities: ( i ) Dikes, berms, or retaining walls sufficiently impervious to contain oil; (ii) Curbing; (iii) Culverting , gutters, or other drainage systems; (iv) Weirs, booms, or other barriers; (v) Spill diversion ponds; (vi) Retention ponds; or (vii) Sorbent materials.

# SPCC Examples

Methods Description of Secondary Containment Examples

Dikes, berms, or retaining walls sufficiently impervious to contain oil Raised earth embankments or concrete containment walls used in areas with potential for large discharges, such as single or multiple aboveground storage tanks and certain piping.

Curbing Permanent concrete or asphalt apron surrounded by a curb. Can be used where only small spills are expected and also used to direct spills to drains or catchment areas.

Culverting, gutters, or other drainage
systems Types of permanent drainage systems designed to direct spills to remote containment or

treatment areas.

Weirs Dam

- like structures with a notch through which oil may flow to be collected.

Used in combination with skimmers to remove oil from the surface of water.

Booms Form a continuous barrier placed as a precautionary measure to contain/collect oil. Typically used for the containment, exclusion, or deflection of oil floating on water, and is usually used to address oil spills that have reached surface waters.

Barriers Spill mats, storm drain covers, and dams used to block or prevent the flow of oil.

Spill diversion and retention ponds Designed for long

- term or permanent containment of storm water capable to capture and hold oil or runoff and prevent it from entering surface water bodies.

Sorbent materials Materials include spill pads, pillows, socks, mats, clay, vermiculite, and diatomaceous earth. Used to isolate and contain small drips or leaks until the source of the leak is repaired.

Drip pans Used to isolate and contain small drips or leaks until the source of the leak is repaired. Drip pans are commonly used with product dispensing containers (usually drums), uncoupling of hoses during bulk transfer operations, and for pumps, valves, and fittings.

Sumps and collection systems A permanent pit or reservoir and the troughs/trenches connected to it that collect oil.

# SPCC § 112.10 Provisions

• If you are the owner or operator of an onshore oil drilling and workover facility, you must:

• (a) Meet the general requirements listed under § 112.7, and also meet the specific discharge prevention and containment procedures listed under this

section.

• (b) Position or locate mobile drilling or workover equipment so as to prevent a discharge as described in § 112.1(b).

• (c) Provide catchment basins or diversion structures to intercept and contain discharges of fuel, crude oil, or oily drilling fluids.

• (d) Install a blowout prevention (BOP) assembly and well control system before drilling below any casing string or during workover operations. The BOP assembly and well control system must be capable of controlling any

well

- head pressure that may be encountered while that BOP assembly and well control system are on the well.

# RCRA

Resource Conservation & Recovery Act (RCRA)

– 40 CFR 260

- 265 (generator standards)

– Restricts hazardous waste collection and storage

– Defines “characteristic” and “listed” hazardous wastes

• Ignitability

• Corrosivity

• Reactivity

• Toxicity

– Exempts flowback fluids at federal level

-- state laws may apply

– May not exempt fracturing fluids at federal level

# NPDES

National Pollutant Discharge Elimination System (NPDES)

– 40 CFR 122

– Limits water pollution through permits

– Defines oil pollution as a “sheen” on the water

– Regulates stormwater discharges from construction sites (1 acre plus), industrial facilities and municipalities

– Considers sediment to be the most common pollutant

– Requires E&P sites to have sediment controls

– Delegates permitting to states; all Marcellus/Utica Shale states have received delegation

# API Recommend Practice

Environmental Protection for Onshore Oil and Gas Production Operations and Leases (51R)

– Containment should be constructed so spilled fuels or chemicals do not reach the ground

– Control the spread to the smallest possible area

• Drip pans under equipment and storage containers

• Retaining walls or dikes around tanks and other spill prone equipment

• Secondary catchment basins

• Permanent booms in the adjoining water basin

• Temporary booms deployed after the spill occurs

• Cleanup materials sufficient to handle small spills stocked on site

# API Guidance Document

Practices for Mitigating Surface Impacts Associated
with Hydraulic Fracturing (HF3)

– Spill prevention, response and cleanup procedures as part of SOP

manual for storing oil, chemicals or other fluids

– Installation of containment, BMPs, barriers and response equipment

• Sloping well location away from surface water

• Retaining walls or dikes around tanks

• Secondary catchment basins

• Absorbent between sites and surface waters

• Temporary containment and liners during drilling and completions

# Surface Spills vs. Fracking

Secretary of Energy Advisory Board

Incidents causing problems have been unrelated to fracking itself but have
arisen from surface spills, poor cementing jobs in wellbores and other
operational failures



### Energy Institute

— University of Texas at Austin

Surface spills of fracturing fluids appear to pose greater risks to groundwater sources than from hydraulic fracturing itself



### Governor’s Marcellus Shale Advisory Commission

The primary concerns regarding hydraulic fracturing relate to surface spills
of fluids, well control and lost containment of production and flowback water

on the surface

# PA DEP Oil & Gas Spill Policy

• Recommends reporting a spill or release of more than five gallons of a regulated substance to the surface of the ground

• Recommends notifying if the spill/release exceeds 42 gallons in competent secondary containment

• Remove the spilled material from the secondary containment within

24 hours

• When spilled onto the ground, the material is usually either residual

waste or hazardous waste

# PA Act 13 of 2012

Unconventional well sites must be designed and constructed to prevent spills to the ground surface or off the well site. Containment practices must be in place during both drilling and hydraulic fracturing operations and must be sufficiently impervious and able to contain spilled materials, and be compatible with the waste material or waste

stored within the containment. Containment plans must be submitted to the department and describe any equipment that is to be kept onsite to prevent a spill from leaving the well pad.

Containment systems shall be used wherever drilling mud, hydraulic oil, diesel fuel, drilling mud additives, hydraulic fracturing additives, and/or hydraulic fracturing flowback are stored. Containment areas must be sufficient to hold the volume of the largest container stored in the area plus ten percent. ( § 3218.2 of the Act)

# Master Containment Plans

Shall Include:

1) General well site construction plans with expected containment systems placement

2) Overall containment practice

3) Detailed installation, utilization, integration and maintenance plan

4) Manufacturer's specifications on materials used, installation directions, maintenance requirements, chemical compatibility, warranted uses and reuse/disposal considerations

5) List of all equipment that may be onsite that could be used to prevent/contain a spill

6) Name, address and contact information of the companies contracted by the operator that may assist with spill response, containment and

remediation

http://www.portal.state.pa.us/portal/server.pt/community/act_13/20789/act_13_faq/1127392

# System vs. Practice

A system is a type of containment method

.

Examples:

• Well pad lining system

• Manifolded pallet

- style secondary containment system

A practice is the specific way in which a containment system is used

.

Examples:

• A liner (system) used just under the drilling rig as localized

containment (practice)

• A liner (system) installed to cover the entire well site for complete

containment (practice)

# Containment System Examples

• Diking (Diking Fields)

• Curbing or berming

• Double

- walled tanks

• Open

- top tanks and containers

• Manifold containment tanking systems

• Portable collapsible containment systems

• Liquid transfer containment kits

• Modular spill decks

• Pipe sleeves

• Surface liners

• Spill kits, booms, and absorbent pads, mats, pillows and socks

# Local Containment Practice

Deployed only at the site of the reservoir (tanks), such as diesel fuel tanks, chemical tanks, roll offs, drilling rigs and trucking transfer

stations.

These systems may also include using a spill deck under all chemical storage tanks of a certain size or deploying a collapsible portable containment system around all diesel fuel tanks.

These could also consist of any impermeable container made of a

material that is compatible with the waste stored or used within the containment. Any containment material that meets the coefficient of permeability of no greater than 1 x 10

- 10 cm/sec and has supporting

documentation of the permeability, chemical compatibility and other applicable QA/QC standards, is acceptable for use for containment.

# Complete Containment Practice

Complete containment is deployed under the entire well pad operation.

Choose a liner that is

– Durable

-- Able to support the weight of heavy equipment, such as drilling rigs and trucks.

– Impervious

-- Constructed from a synthetic material with a coefficient of permeability of no greater than 1 x 10

- 10 cm/sec and with sufficient strength and thickness to maintain the integrity of the

liner.

– Chemically Compatible

- - Designed, constructed and maintained so that the physical and chemical characteristics of the liner are not adversely affected by the waste and the liner is resistant to physical, chemical and other failure during transportation, handling,

installation and use.

# Complete Containment FAQs

When employing this type of system, the plan must:

• Identify the type and thickness of the material.

• Identify the installation procedures to be used.

• Ensure that adjoining sections of liners be sealed together to prevent leakage in accordance with the manufacturer's directions.

• Ensure that liner systems must be designed to allow spilled material or
waste to be collected and removed efficiently

.

• Ensure that the site must be designed to handle large spills and to also manage runoff that occurs on the well site. Supporting calculations may be required by the Department.

• Ensure that the collection system must be designed to handle both
contaminated and uncontaminated runoff on the well site.

• Ensure that all complete well site containment plans include berming of the entire pad that meets the permeability standard.

http://www.portal.state.pa.us/portal/server.pt/community/act_13/20789/act_13_faq/1127392

# Master Containment Plans

• Inspection and Maintenance Plan

– To ensure the timely and quality repair of damage that is caused to any containment systems including, but not limited to: tears, punctures or any condition that compromises the maximum permeability requirements of the liner system.

• Appendix to be attached to PPC

– General drawing showing locations of all containment systems, including GPS coordinates

– Brief description of each system , along with cross reference to Master Containment Plan

– Names and contact information of all companies contracted to assist with spill response, containment and remediation

# Well Site Containments

Pad

– Large square footage, typically centered off the wellheads

– 6 to 8 inch high berms



### Tank

– 110% of the largest tank

– 18 to 36 inch high berms



### Equipment

– Placed under equipment that is leak prone

– 6 to 8 inch high berms



### Chemical Storage

– Placed under liquid and dry chemicals

– 6 to 8 inch high bermsOil and hydraulic oils

in pumps 

# Completions Site

# Pad Containment Best Management Practices

# Surface Liners

Work surfaces should be as clean and dry as possible to prevent slips and falls.

Tip: Cover polyethylene liners in felt

to increase the coefficient of friction.

Tip: Limit wrinkled, loose layers of material to reduce tripping hazards.

OSHA 29 CFR 1910.22

SPCC 40 CFR 112.7

NPDES 40 CFR 122.26

RCRA 40 CFR 264.175

# Composite Liners

Composite liners are slip resistant and 5X more puncture resistant.

Tip: Withstands rigging up and down.

Tip: Able to last through multiple operations.

Tip: Holes are readily detectable and easily repairable.

Tip: Recyclable to reduce landfill

burden.

OSHA 29 CFR 1910.22

SPCC 40 CFR 112.7

NPDES 40 CFR 122.26

RCRA 40 CFR 264.175 New Pig Patents Pending

# Pad Sub

- base

Avoid mud.

Tip: Cement dirt should be capped

with at least 2 inches of stone.

Tip: Stone should be 2 inches or less in diameter (2A

- Modified, Crusher Run, #57).

Tip : Stone should rolled and firm (no rolling or pumping ).

# Seam Welding

Automated wedge welders should be used for all liners to join large panels together.

Tip: Set to correct temperature and speed depending on liner and

site conditions.

Tip: Liner should be spotted during welding.

OSHA 29 CFR 1910.22

SPCC 40 CFR 112.7

NPDES 40 CFR 122.26

RCRA 40 CFR 264.175

# Leak Testing

Split welder seams can be tested by pressure.

Solid wedge welder seams can be tested by air lance and vacuum.

Tip: Vacuum tester can be moved 30 inches every 10 seconds

OSHA 29 CFR 1910.22

SPCC 40 CFR 112.7

NPDES 40 CFR 122.26

RCRA 40 CFR 264.175

# Patching

Plastic Liner: 1) Dry surface 2) Heat tack patch 3) Grind edge 4) Extrusion weld

Composite Liner: 1) Dry surface 2) Surround with sealant 3) Heat tack patch 4) Surround with sealant

OSHA 29 CFR 1910.22

SPCC 40 CFR 112.7

NPDES 40 CFR 122.26

RCRA 40 CFR 264.175

# Attachment to Cellar

Prevents leak in cellar from backing up under the liner.

Tip: Attach with ice guard.

Tip: Attach with metal ring.

Tip: Spray coat with polyurea

.

Tip: Build liner tube, cement in place,

a nd weld surface liner to it.

# Low

- Wall Berming

Most common materials are railroad ties, corrugated pipe or foam.

Tip: Tie corrugated pipe corners together to prevent kick out.

Tip: Edges of liner should at least reach the top of the berm to maintain sump capacity.

OSHA 29 CFR 1910.22

SPCC 40 CFR 112.7

NPDES 40 CFR 122.26

RCRA 40 CFR 264.175

# Maintaining the Berm

Control access to either ramps

or foam berms.

Tip: Don’t park on the berm.

Tip: Don’t cut away the berm.

Tip: Plastic barricades seem to have the most success in limiting traffic.

OSHA 29 CFR 1910.22

SPCC 40 CFR 112.7

NPDES 40 CFR 122.26

RCRA 40 CFR 264.175

# Grounding Rods

Ideally grounding rods should be outside of the pad containment.

Tip: Use a boot with standing pipe. Pipe should be as tall as the berm.

OSHA 29 CFR 1910.22

SPCC 40 CFR 112.7

NPDES 40 CFR 122.26

RCRA 40 CFR 264.175

# Hole Prone Areas

Pipe Racks

– Use plastic mats

OR

– Keep liner tight to catwalk



### Backyard

– Use rig mats for trackhoe path to drill cutting bins



### Outriggers

– Use outrigger pads when positioning heavy equipment

# Tank Containment

# Frac Tank Containment

110% of largest tank. Berm walls are typically metal, concrete or plastic barricades.

Tip: Subtract out tank displacement when calculating capacity.

Tip: Keep separate from pad
containment. Berm should terminate, meaning no hats.

Tip: Higher sidewalls increase sump capacity for smaller areas

.

# Fuel Tank Containment

Fuel tanks should be double wall construction so that secondary

containment travels with the tank.

Tip: Tertiary containment

Tip: Quaternary containment

OSHA 29 CFR 1910.22

SPCC 40 CFR 112.7

NPDES 40 CFR 122.26

RCRA 40 CFR 264.175

# Brine Tank Containment

Brine tanks are permanent

structures and should have permanent secondary containment

.

Tip : Install a ladder to prevent falls.

Tip: Load

- line containment can prevent spills during transfer.

OSHA 29 CFR 1910.22

SPCC 40 CFR 112.7

NPDES 40 CFR 122.26

RCRA 40 CFR 264.175 Infrared photograph of storage tank with a two foot oil layer on top of water

# Equipment Containment

# Equipment Containment

Typically used under generators, light posts, and sewer treaters.

Tip: Can be reused from site to site.

OSHA 29 CFR 1910.22

SPCC 40 CFR 112.7

NPDES 40 CFR 122.26

RCRA 40 CFR 264.175

# Collapsible Storage

Lightweight and reusable spot containment can be used for tanks, separators and vehicles.

Tip: Float

- up walls reduce impalement and tripping concerns.

Tip: Drive

- through options eliminate need to drop and raise

walls.

SPCC 40 CFR 112.7

NPDES 40 CFR 122.26

RCRA 40 CFR 264.175

# Fluid Dispensing

Fluid dispensing is a high

- risk

area for spills.

Tip: Place quick

- throw berms or

basins under hose connections

and valves.

OSHA 29 CFR 1910.106

SPCC 40 CFR 112.7

NPDES 40 CFR 122.26

# Chemical Storage Containment

# Chemical Storage

Both liquid and dry chemicals

should be on containment.

Tip: Maintain a driveway between pad containment and chemical storage containment to reduce high

- traffic area.

Tip: Compartmentalize flammables and incompatible

materials.

OSHA 29 CFR 1910.106

SPCC 40 CFR 112.7

NPDES 40 CFR 122.26

# Active Containment

# Universal Spill Removal

Surround spill with booms to prevent spreading.

Tip: Choose socks filled with
earthen materials to create stronger containment dikes.

Tip: Absorbent mats cover large surface areas to soak up spills.

NPDES 40 CFR 122.26
25 Pa. Code §§ 78.55 25 Pa. Code §§ 91.34

# Oil/Diesel Spill Removal

Oil

- only absorbents will not pick up water, which reduces disposal costs.

Tip: Place booms at an angle in water basins as a preventative

measure.

Tip: Select UV

- resistant

absorbents if installed in the field

for more than 3 months.

SPCC 40 CFR 112.7

NPDES 40 CFR 122.26

25 Pa. Code §§ 78.55

25 Pa. Code §§ 91.34

# Response Trailers

Equipment available for cleanup of a given spill must be listed.

Tip: Use GPS coordinates to mark
locations of the off

- site trailers.

Tip: Keep first responder boom supplies on site to surround perimeter.

OSHA 29 CFR 1910.120
SPCC 40 CFR 112.7
25 Pa. Code §§ 78.55 25 Pa. Code §§ 91.34

# Truck Kits

Address the typical failure mode and the most likely quantity.

Tip: 5

- to 8

- gallon kits fit inside cabs.

Tip: Consider pop

- up pools for fuel tank damage and shovels for spills to soil.

OSHA 29 CFR 1910.120

SPCC 40 CFR 112.7

25 Pa. Code §§ 78.55

25 Pa. Code §§ 91.34