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 berms
Oil 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,

and 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