RULES FOR THE
ENVIRONMENTAL MANAGEMENT DIVISION,
I&E DEPT, MCBCL
• The goal of the Oil Pollution Prevention
regulations in 40 CFR Part 112 is to
prevent oil discharges from reaching
navigable waters of the U.S. & adjoining
• Requirements established for prevention
are known as the Spill Prevention
Control & Countermeasures (SPCC)
• These requirements were first
established in 1973 & were amended in
One aspect of the amended changes…..
MAKES SPCC REQUIREMENTS -
….applicable to any facility that has bulk
DEFINES BULK OIL STORAGE -
….as any container with capacity of 55 gallons
OLD RULE required secondary containment for
tanks 660 gallons or more….
NEW RULE requires secondary containment for
tanks/containers 55 gallons or more…..
How are New Spill Prevention
Rule Changes Applicable to MCB
- Any unit aboard MCB Camp Lejeune which stores or manages
hazardous materials/chemicals in containers that are equal to, or
greater than, 55 gallons must adhere to these new requirements.
Six-Cons storing Fuel
Generators stored on lots
containing fuel + Storage
-Under the new revisions:
a. HM containers with > 55 gallons of product must be
stored and/or managed within a secondary containment
system if stored on the exterior of a building and/or if a
release of fluids from the container has the potential to
reach surface waters.
Drums surrounding this used oil
management facility show signs
of spillage – A rain event would
wash this residue into nearby
b. Uncovered exterior storage of these types of
containers must be able to contain 100% of the
largest container of stored fluids in addition to 5”
c. Containers of HM products designed to hold
>55 gallons and are stored inside a facility or
structure are exempt from these secondary
containment requirements IF fluids cannot
escape to the exterior of the building.
This is an example of drum storage
inside a POL room. The room has no
floor drains or doorways leading to
the outside of the bldg. This unit has
gone beyond what is required by
placing the drums on containment
pallets however these pallets, while
containing residual leaks, could not
contain the entire contents if there
was a catastrophic container failure.
d. (1) Operational/Tactical non-mobile equipment (ie.
generators, six-cons loaded on vehicles) containing >
55 gallons of hazardous materials and stored outside
the confines of a building are also subject to these
new secondary containment requirements.
(2) Operational/Tactical mobile equipment containing >
55 gallons of hazardous materials (ie AAVs, LAVs,
Tanks) are exempt from this requirement.
(3) Temporary structures used for containment in the
field must be able to contain 200% capacity of the
largest container + must be inspected daily
This vehicle contains 6-cons of fuel awaiting to go in the field the
next day. While it is parked in a temporary containment structure,
the structure is inadequate because of the sides have fallen down.
e. Certain types of secondary
containment systems (interior and
exterior) will no longer be
considered adequate based on
these new revisions.
Inadequate Exterior Secondary
In this picture, containers are
stored outside the berm.
This berm height is not adequate to
hold 100% of tank contents + 5”.
Additionally, the sand bags
comprising the berm are
deteriorated allowing for leakage
from the berm.
There are a number of problems with this containment structure. The
berm is inadequate in height for storage of the contents of the largest
container. There is too much material stored in this area which
reduces the volume that the containment can hold.
f. Secondary containment
systems located on the exterior of
a building but that are
encapsulated/enclosed from the
elements (i.e. rain) are exempt
from these requirements and need
only contain 100% of the product
Storage structure with berm
This self-contained systems is
being used to store Jerry cans &
5 gallons containers
Both of these systems are adequate for
the storage of POL in 55-gallon drums
g. Field grade tactical equipment otherwise subject
to these requirements but stored empty within the
confines of a unit’s facility are exempt from these
h. Base EMD personnel will determine the
adequacy and containment capacity of questionable
storage facilities aboard MCB, CL during the
scheduled, semi-annual Environmental Compliance
i. State and Federal regulators will place
greater emphasis on the utilization of covered, walled
or encapsulated, and self-contained secondary
j. Base EMD compliance regulators will also
place greater emphasis on the above-listed types of
containment IN ADDITION TO unit’s utilizing existing,
permanent secondary containment systems as well as
the interior storage rooms and areas located within the
confines of a unit’s facility.
Adequate Exterior Secondary
The best way to ensure that secondary containment is
adequate is to use facilities that limit exposure to the elements
•3- & 4-sided covered exterior storage facilities
•Interior storage w/ no outlets (ie doors to outside, drains)
Most Units have Existing Storage Facilities BUT are
Utilizing them for Purposes other than HAZMAT
HOW TO BEST MEET THE NEW
Use Existing Exterior Storage Facilities
Utilize Interior Storage Rooms
Don’t Use Storage Space by Placing
containers <55 Gallons in the containment.
•Utilize flammable lockers for those size
Reduce Inventory of Drums Requiring
Contact EMD at 451-5837 for assistance/ guidance