Containment systems are always there for you to catch leaks and spills that may spring from the primary container. But are you using the right containment system for the job? Read on as we walk you through the process of how to choose the containment pallet or deck that best suits your needs.

Containment systems are always there for you to catch leaks and spills that may spring from the primary container. But are you using the right containment system for the job? Read on as we walk you through the process of how to choose the containment pallet or deck that best suits your needs.

Secondary containment devices provide a backup system to prevent the release of a spill should a primary container fail.

Custom-made secondary containment products – usually consisting of an impervious concrete pad and curbing – are commonly designed by engineering firms and help facilities comply with regulations. But with hundreds of prefabricated containment options available today, there's a ready-made solution for almost every need. Pre-fabricated systems save time and money. They can also be relocated as needs or processes change.

Traditionally, secondary containment systems were designed for compliance with the Environmental Protection Agency's (EPA) hazardous waste storage regulation, 40 CFR 264.175. However, other regulations, such as the EPA's Spill Prevention Control and Countermeasures (SPCC) rule, also require active and/or passive containment. Providing containment can also be considered a Best Management Practice (BMP) for the EPA's stormwater regulations.

Depending on the materials stored, fire codes can also play a role in containment requirements, as does the location of the containment system. Storing flammable liquids outdoors, for example, is more involved than storing them inside.

Being aware of regulations and applying knowledge of the liquids being contained are key steps in choosing a prefabricated containment system that will meet a variety of needs, and also be versatile enough to grow and change with the facility.

  • Engineered secondary containment systems are costly and hard to adapt as facility needs change
  • Prefabricated containment systems are less expensive but just as effective as engineered systems
  • Being aware of regulations will help ensure that the proper containment products are purchased

Regulatory Considerations

Federal EPA secondary containment regulations (40 CFR 264.175) apply to large quantity hazardous waste generators. To meet this regulation, containment systems must meet the following specifications:

  • The base must be free of cracks or gaps and must be sufficiently impervious to contain leaks, spills and accumulated precipitation (264.175(b)(1)).
  • The base must be sloped or the system must be designed so that spilled liquids can be removed. This is not necessary, however, if the container is elevated (e.g., on pallets) or otherwise protected from contacting accumulated liquids (264.175(b)(2)).
  • The secondary containment system must have the capacity to contain at least 10 percent of the total volume of the containers or 100 percent of the volume of the largest container, whichever is greater. (264.175(b)(3)).
  • Stormwater run-on must be prevented from entering the system unless the collection system has sufficient capacity to contain any run-on entering the system in addition to the capacity requirements (264.175(b)(4)).

Containment is also a key provision in the EPA's SPCC rule (40 CFR 112). In a guidance document, the EPA states, "Secondary containment systems provide an essential line of defense in the event of a failure of an oil container." Two forms of containment are outlined:

  • General secondary containment requirements address the most likely oil discharge from bulk storage containers; mobile/portable containers; production tank battery, treatment and separation installations; a particular piece of oil-filled operational or process equipment; (non-rack) transfer activity; or piping in accordance with good engineering practice
  • Specific secondary containment requirements are intended to address a major container failure (the entire contents of the container and/or compartment) associated with a bulk storage container; single compartment of a tank car or tank truck at a loading/unloading rack; mobile/portable containers; and production tank batteries, treatment and separation installations

The rule also specifies procedures for active and passive containment. Active containment measures are those that require deployment or other specific action by the owner or operator. Passive measures do not require deployment or action by the owner/operator.

A goal of EPA's Stormwater Regulation is to prevent "illicit discharges," which are broadly defined as any discharges into a storm drain system not composed entirely of stormwater. The regulation calls upon facilities to use proactive Best Management Practices (BMPs) to prevent discharges. Properly maintained containment systems can be considered BMPs because they capture liquids at the source of the spill, preventing discharges.

Too often, a spill containment system is designed and installed to satisfy an isolated need: to comply with a specific state or local environmental regulation, to meet a specific objective, or maybe the desire to eliminate the slippery floor around waste collection containers. Unfortunately, engineered systems are hard to adapt if processes or the facility layout changes, or if additional needs are uncovered later.

Pre-fabricated containment devices help satisfy a number of different environmental, health and safety requirements, and can help lower insurance premiums. Because they are not "built in," they can be moved or relocated as processes or needs change without extensive deconstruction and reconstruction time and costs.

The wide variety of pre-fabricated containment pallets and spill decks available means that, for most facilities, the products needed for compliance are not more than a phone call away. Considering the following factors will aid you in selecting a system that best meets your facility needs.

Containment Pallet or Spill Deck?

Polyethylene, Fluorinated Polyethylene or Steel?

Chemical resistance of polyethylene or steel is often the primary factor when choosing materials for a containment device. Fluorinated polyethylene, with its increased chemical resistance, offers another choice when handling chlorinated solvents or other liquids that degrade regular polyethylene.

Storing flammables or combustibles?

Flammable liquid storage and handling is a highly-regulated subject, yet there is little guidance offered by OSHA, the NFPA or the Uniform Fire Code on using — or not using — polyethylene spill containment devices when storing flammables and combustibles.

When polyethylene or fluorinated polyethylene is compatible with a flammable or combustible liquid, consider these factors when determining if a steel containment unit is needed:

Stationary or Mobile?

Consider the current and future physical requirements of spill containment devices when choosing between a pallet and deck.

  • Will the containment area need to be expanded or reconfigured in the future?
  • Will the containment units need to be moved while the containers are on them?
  • Is drum top height at waste collection stations a concern?
  • Will high-specific gravity liquids be stored on the pallets?

Modular Spill Decks feature inter-connectable bulkheads that allow multiple units to be connected on all four sides. These ports may be linked or closed as future needs require. The low profile also allows easier drum loading/unloading along with convenient access to drum tops.