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.