Category: Regulatory Updates

The U.S. Environmental Protection Agency released updated guidance documents in early 2026 affecting secondary containment requirements under 40 CFR Part 112 (SPCC Rule). This article summarizes the key changes and what they mean for facility operators across the country.

Key Changes to the SPCC Rule

The EPA’s January 2026 guidance memorandum clarifies several previously ambiguous areas of the Spill Prevention, Control, and Countermeasure (SPCC) rule. The most significant changes include:

1. Aggregate Storage Capacity Calculations

The new guidance clarifies how facilities must calculate their aboveground oil storage capacity when determining SPCC applicability. Previously, many facilities excluded certain container types from their calculations. The 2026 guidance closes this gap by requiring inclusion of all containers with a capacity of 55 gallons or more, including mobile equipment tanks and bulk transfer vehicles when stationed at fixed locations for more than 30 days.

2. Inspection Frequency for Portable Containment Systems

Foam berm systems and other portable containment devices must now be formally documented in the facility’s SPCC plan, with inspection records maintained for at least five years. Annual professional engineer certification is required for facilities with portable systems exceeding 10,000 gallons total containment capacity.

3. Material Compatibility Requirements

New guidance specifies minimum material compatibility standards for containment liners. Polyurea coatings must demonstrate 2,000+ hours of chemical resistance testing for petroleum hydrocarbons. PVC liner systems must meet updated permeability standards. All containment materials must now include documented manufacturer certifications.

Compliance Deadlines

Facilities with existing SPCC plans have until December 31, 2026 to amend their plans to reflect the new guidance. New facilities or those undergoing significant modifications must incorporate the 2026 standards immediately.

OCA Member Resources

The OCA has prepared a compliance checklist and plan amendment template available in the Member Resources section. Our regulatory compliance team is also available for individualized consultations. Contact us at compliance@oilcontainment.org.

If you operate a facility that stores oil aboveground in containers of 55 gallons or more, and your total storage capacity exceeds 1,320 gallons, you are very likely required to have a Spill Prevention, Control, and Countermeasure (SPCC) plan under EPA regulations. This guide walks small facility operators through the basics.

What Is an SPCC Plan?

An SPCC plan is a written document that describes how your facility will prevent oil spills from reaching navigable waters or adjoining shorelines, and what you will do if a spill occurs. It is required under the Clean Water Act (33 U.S.C. § 1321) and is detailed in 40 CFR Part 112.

Do You Need One?

You need an SPCC plan if ALL of the following apply:

1. Your facility is non-transportation-related (not a vessel, pipeline, or vehicle)
2. You store oil in aboveground containers totaling more than 1,320 gallons, OR you have a single underground storage tank larger than 42,000 gallons
3. Your facility could reasonably be expected to discharge oil into or upon navigable waters or adjoining shorelines

Tier System: What Type of Plan Do You Need?

Qualified Facility (Tier I)

Facilities with total aboveground storage of 10,000 gallons or less AND no single container larger than 5,000 gallons AND a clean spill record may qualify for a self-certified Tier I plan. No Professional Engineer stamp is required, but you must follow EPA’s template precisely.

Qualified Facility (Tier II)

Facilities with total aboveground storage between 10,000 and 42,000 gallons may prepare their own plan but must have it certified by a licensed Professional Engineer.

Full SPCC Plan

Facilities with total aboveground storage exceeding 42,000 gallons must have a Professional Engineer prepare and certify the full plan.

Key Plan Elements

Regardless of tier, all SPCC plans must include: facility description and layout, storage container inventory, secondary containment description and calculations, inspection and testing procedures, personnel training program, spill response procedures, and management approval signatures.

Secondary Containment Requirements

Every oil storage container must have secondary containment capable of holding 110% of the largest container’s capacity. This is typically achieved through berms, dikes, or impervious surfaces. Foam berm systems are a cost-effective compliant solution for many facilities, particularly those with mobile equipment or multiple storage locations.

How OCA Can Help

The Oil Containment Association offers SPCC plan development services through our network of certified member consultants. We also offer free initial consultations to help facility operators determine their compliance requirements. Contact us at compliance@oilcontainment.org or call 1-800-610-1080.

Electric utility operators and renewable energy facility managers are increasingly subject to secondary containment requirements for transformer oil. This article covers the regulatory framework, technical requirements, and practical solutions for transformer oil containment.

Regulatory Framework

Transformer oil containment falls under multiple overlapping regulatory frameworks. Utility-scale transformers typically contain PCB-free mineral oil, sometimes up to 50,000+ gallons for large power transformers. Key regulations include:

• EPA 40 CFR Part 112 (SPCC Rule): Applies to facilities with total oil storage capacity exceeding 1,320 gallons that could discharge to navigable waters
• EPA 40 CFR Part 761 (PCB Regulations): Applies if transformer oil contains PCBs at or above 50 ppm
• NERC Standards: Reliability standards that indirectly address transformer protection including spill prevention
• State Environmental Regulations: Many states have additional requirements more stringent than federal minimums

Containment System Requirements

Secondary containment for transformers must hold at least 110% of the largest single container volume. For a 5,000-gallon transformer, this means your containment system must hold at least 5,500 gallons. Options include:

Permanent Concrete Containment Pads

Traditional approach for permanent installations. Reinforced concrete with impermeable coating, designed to hold 110%+ of largest transformer capacity. Sloped toward a collection sump. Cost: $15,000-$80,000 depending on size and site conditions.

Foam Berm Systems

Increasingly popular for substations, wind farm transformer pads, and solar inverter stations where permanent construction is impractical or prohibited. Polyurea-coated foam berms can be configured in custom shapes to fit pad geometries. Key advantages: no excavation required, deployed in hours, fully removable if site is decommissioned.

Modular Steel Containment Systems

Bolted steel panels with liner provide intermediate durability between temporary and permanent systems. Good choice for temporary substations and construction staging.

Renewable Energy Applications

The rapid growth of utility-scale solar and wind installations has created significant demand for flexible transformer containment solutions. A single 100 MW solar farm may have 30-50 pad-mount transformers, each requiring secondary containment. Foam berm systems with custom liner geometries are increasingly the preferred solution due to ease of installation during construction and lower cost versus poured concrete.

After reviewing hundreds of SPCC plans through our compliance assistance program, the OCA has identified the five most common errors that lead to plan deficiencies during EPA inspections. Here’s how to avoid them.

Mistake #1: Incorrect Capacity Calculations

Many facilities undercount their total aboveground oil storage capacity, sometimes inadvertently falling into a higher regulatory tier. Common omissions include: drums stored temporarily on-site, mobile equipment fuel tanks, emergency generator fuel storage, hydraulic fluid reservoirs on large equipment, and oil-filled electrical transformers.

The Fix: Conduct a comprehensive oil inventory that includes every container, vessel, and equipment tank at the facility. Update the inventory at least annually. When in doubt, include it.

Mistake #2: Inadequate Secondary Containment Sizing

The most technically common deficiency: containment systems that are too small. The rule requires 110% of the largest single container, but many plans incorrectly calculate this as 100%, or fail to account for accumulated rainwater reducing the effective containment volume.

The Fix: Calculate containment requirements at 110% minimum. For outdoor containment in areas with significant precipitation, consider designing to 150% to account for potential rainwater accumulation between drainage events.

Mistake #3: Outdated Plans

SPCC plans must be reviewed and if necessary amended whenever there is a change in facility design, construction, operation, or maintenance that affects the potential for an oil discharge. Many facilities fail to update their plans after adding storage tanks, changing processes, or modifying containment structures.

The Fix: Establish a formal management of change procedure that triggers SPCC plan review for any significant facility modification. Schedule annual plan reviews even in the absence of changes.

Mistake #4: Missing or Inadequate Inspection Documentation

The SPCC rule requires periodic inspections of containment systems, and those inspections must be documented. During EPA inspections, auditors routinely find inspection logs that are missing, incomplete, or not linked to corrective action records when deficiencies were noted.

The Fix: Implement a formal inspection program with standardized checklists, designated responsible personnel, and a closed-loop corrective action system. Digital inspection platforms can significantly improve compliance in this area.

Mistake #5: Undertrained Personnel

SPCC regulations require that oil-handling personnel understand the regulations, the facility’s SPCC plan, and their roles in spill prevention and response. Training records must be maintained. Many facilities have plans that satisfy the regulatory requirements on paper, but personnel don’t know what to do in an actual emergency.

The Fix: Implement annual SPCC training for all oil-handling personnel. Conduct at least one spill drill per year. Document all training with sign-in sheets and test results. OCA offers online and in-person SPCC training programs through our Certified Containment Specialist program.