• 5 Main Points of Secondary Containment Regulations
  • Karen

    Karen D. Hamel, CSP, WACH, is a regulatory compliance professional, trainer and technical writer for New Pig. She has more than 22 years of experience helping EHS professionals find solutions to meet EPA, OSHA and DOT regulations and has had more than 100 articles published on a variety of EHS topics. Karen is a Certified Safety Professional (CSP), Walkway Auditor Certificate Holder (WACH), Community Emergency Response Team (CERT) trainer and hazmat technician. She also serves on the Blair County, Pa., LEPC and has completed a variety of environmental, safety, emergency response, DOT and NIMS courses, including Planning Section Chief. She has conducted seminars at national conferences and webinars for ASSE and other national organizations. She can be reached at 1-800-HOT-HOGS (468-4647) or by email karenea@newpig.com.

  • Keith Stenosays:
    04/22/2015 at 9:32 am Reply

    If there is a minor overflow of the primary storage tank (diesel) into the secondary containment (about 10 gallons) is that considered a spill? No diesel touched the ground and all materials were evacuated from the secondary containment within the hour. Thanks for your answers. Keith

    • Karen Hamelsays:
      04/23/2015 at 8:32 am Reply


      Under the broad definition of “spill”, yes, this would be considered a spill. But the good news is that because you had a secondary containment system in place, that spill was not released to the environment. It also sounds like your facility was prepared to handle the spill quickly and effectively, which is fantastic.

      Unless there are other special circumstances that weren’t mentioned, this would be considered an incidental spill and shouldn’t require reporting. It might be a good idea, however, to review your filling procedures to help ensure that overflows don’t continue to happen in the future.


  • daiasays:
    07/08/2015 at 1:29 am Reply


    i have an inquiry… what if 110 gallons spill? i see that your calculation for secondary containment is only 55 gallons… what about the another 55 gallons?

    pls answer….

    • Brittany Svobodasays:
      07/08/2015 at 3:26 pm Reply

      Hi Daia,
      That’s a great question! The EPA only requires you to be prepared for 10% of the total volume, or 100% of the largest container – whichever is greater. The theory behind this is that it is unlikely for more than one container to rupture at the same time. However, you need to balance this theory with knowledge about your location. If you live in an area that’s prone to earthquakes or other natural disasters, the likelihood of more than one container rupturing may be greater and you should probably plan on having a larger containment system.
      Even with secondary containment, it’s still important to have absorbents or a vacuum on hand to soak up any liquid that for whatever reason didn’t stay in the secondary containment system.
      I hope that answers your question! If you have any others, do not hesitate to comment again.

  • daiasays:
    07/13/2015 at 9:59 pm Reply

    Hi Brittany,

    Yup! You really answer my question.

    Millions of thanks dear 🙂

  • Amandasays:
    11/03/2015 at 12:39 pm Reply

    Can you provide any links to find state containment requirements?

    • Brittanysays:
      11/04/2015 at 8:30 am Reply

      Hi Amanda,

      In most cases, secondary containment regulations mirror federal Resource Conservation and Recovery Act (RCRA) requirements. I haven’t come across a list that specifically provides a link to each state’s regulations, but the Environmental Protection Agency (EPA) does maintain a webpage that contains links to each state’s environmental agency.

      Hope this helps! If you have any other questions, do not hesitate to reach out.

  • Frank Ungarosays:
    12/17/2015 at 12:52 pm Reply

    I’m in the process of laying out a pump/water treatment station, the treatment chemicals are all liquid. I’m using scales with built in expandable containment bladders. My customer wanted to know if the expandable containment bladders can be overlapped. The thought is that 2 tanks won’t fail at the same time. Are there any regulations that would prevent me from overlapping the bladders?

    Thanks, Frank

    • Brittanysays:
      12/21/2015 at 11:53 am Reply

      Hi Frank,

      The purpose of a bladder is to provide containment in the event that the primary container fails. There is no specific regulation that says you can’t overlap bladders, but there are requirements for the facility to be prepared for its worst case scenario spill. If both bladders would be necessary to contain a worst-case scenario discharge, it would not be a good idea to allow them to overlap because you would lose containment capacity.

      Does this info help? Please leave another comment if you have any other questions.


  • Trishasays:
    12/22/2015 at 5:48 pm Reply

    How do you clean out the 2nd wall of a double-walled steel tank w/ no visible drain, where diesel was overfilled & overflowed into the secondary containment?

    • Brittanysays:
      12/28/2015 at 4:48 pm Reply

      Hi Trisha,

      Thank you for your comment! Did you purchase your double-walled tank from New Pig? If so, we can send you cleaning tips. If not, your best bet is to go back to the manufacturer or supplier of the tank, who should have instructions specific to the one you purchased.


  • Johnsays:
    12/23/2015 at 12:38 pm Reply

    I have barrels of semi-synthetic water soluable coolant scattered around my shop. They are hooked up to auto-mixers that feed directly to my grinding machine sumps. Do the coolant barrels require secondary containment while they are being used?
    Thanks, John

    • Brittanysays:
      12/28/2015 at 3:16 pm Reply

      Hi John,

      Thank you for your comment! The barrels will need secondary containment because a coolant is a hazardous material (anything that can harm a person or the environment). Even though the solution is constantly being pumped to the machines, the barrel could still give out and spill out onto the floor. Your secondary containment must hold 100% of the largest container or 10% of all the containers combined, whichever is largest [40 CFR 264.175].

      Hope this information helps! If you have any other questions, do not hesitate to leave another comment.


  • Imransays:
    01/11/2016 at 8:38 pm Reply

    Good day!

    In your above example, we need 121 Gallons Secondary Containment for Two 55 Gal Drums?


    • Brittanysays:
      01/12/2016 at 8:41 pm Reply

      Hello Imran,

      Thank you for your comment!

      No, under this federal rule, you would only need 55 gallons of containment – assuming that the containers are stored inside and you don’t need additional sump capacity to accommodate run-on.

      This part of the rule always causes the most confusion.

      You EITHER need to contain the total volume of the largest container (55 gallons) OR 10% of the total volume of ALL containers stored – whichever one of the two volumes is GREATER. So, if you have two 55-gallon drums, you have a total volume of 110 gallons. Ten percent of that is 11 gallons. The largest single container is 55 gallons. Because the greater of these two volumes is 55 gallons, you would need to be able to contain 55 gallons.

      Please remember that many states have more stringent requirements, and there may be additional rules that apply to certain types of waste liquids.

      If you have any other questions, do not hesitate to leave us another comment.


      • Imransays:
        01/14/2016 at 5:19 am Reply

        Thanks for the reply, as per your provided response (OR 10% of the total volume of ALL containers stored – whichever one of the two volumes is GREATER. So, if you have two 55-gallon drums, you have a total volume of 110 gallons. Ten percent of that is 11 gallons) Here 11 gallons means 110+ 11=121 Gallons secondary containment?

        first portion as you mentioned is clear that 100% of Largest Container i-e 55 gallons so 55 gallons secondary container is sufficient.

        • Brittanysays:
          01/18/2016 at 8:52 am Reply


          Assuming you do not need to allow sump capacity for run-on or to meet additional regulations, in the scenario you presented, you would only need to be able to contain the quantity of the single largest container – which in your scenario is 55 gallons. If you were in a situation where the 10% part of the rule applied instead of the largest single container, you would only need to be able to contain 10% of the total volume being stored- not the total volume plus 10%.

          The 10% part of the rule really comes into play when you are storing several containers. For example, if you are storing twenty 55-gallon drums, the total volume of those drums collectively would be 1,100 gallons. Ten percent of that total volume is 110 gallons. So, in this situation, your secondary containment areas would need to have a sump capacity of at least 110 gallons because that volume (10% of the total volume being stored) is greater than the volume of your single largest container (55 gallons.)

          Hope this clears it up for you! If you have any other secondary containment questions, do not hesitate to leave another comment!


          • Imransays:
            01/20/2016 at 3:48 pm


  • Marisays:
    02/03/2016 at 4:14 pm Reply

    Are 30 gallon drums of hazardous liquid waste also required to have secondary containment?

    • Brittanysays:
      02/03/2016 at 4:15 pm Reply

      Hi Mari,

      Yes, you will need secondary containment. Unlike SPCC regulations, which are triggered at containers of 55 gallons or more, RCRA hazardous waste regulations apply to all hazardous waste regardless of the container size. So 30 gallon containers of hazardous waste would need to have secondary containment.

      Does this info help? If you have any other questions, please leave another comment below!


  • James Leachsays:
    03/23/2016 at 10:42 am Reply

    If I am utilizing secondary containment that stores only one 55 gallon drum on each secondary containment pallet (storing caustics/acids), am I required to have secondary containment for the full 55 gallons if it is only one drum per secondary containment pallet? Or is 10% sufficient for single drum containment? Hope this makes sense. Thanks in advance.

    • Brittanysays:
      03/23/2016 at 9:02 pm Reply

      Hi James,

      Thanks for your comment. If the secondary containment area is being used to store hazardous wastes and you are only storing one 55 gallon drum, you will need to have containment for the 55 gallon drum because it is the “largest container.” The 10% part of the rule comes into play when you are storing multiple containers in a containment area. For example, if you were storing 20 drums, 20 x 55 gallons = 1,100 gallons. In this case, your containment area would need to be capable of holding 110 gallons (10% of the total volume) rather than just 55 gallons (the volume of the largest single container) because 110 is greater than 55.

      When storing hazardous materials, it is also important to keep incompatible materials segregated. You mention acids and caustics. If these have the potential to react, each type needs to be stored on separate containments pallets or in containment areas with segregated sumps so that, in the event that both containers would fail, the spilled liquids would not share a common sump and react.

      Please leave another comment if you have any additional questions.


  • James Leachsays:
    03/24/2016 at 4:25 pm Reply

    I figured as much after reading all of the previous comments. I guess I am just a bit confused as to why most single drum containment pallets I have found state that they are for 55 gallon drums, but they do not technically contain a sufficient volume in the event of a spill. I will continue looking for the correct containment products.

    I do segregate the chemicals when stored and when connected to our pumps for use. I store like chemicals together when stored on our racks, but I am currently looking for individual containment pallets to utilize when our drums are on the floor level and connected to our chemical supply pumps.

    Thank you for taking the time to share your knowledge with me.

  • Lucassays:
    06/28/2017 at 10:27 am Reply


    In Florida I’ve seen the letter of intent for all tanks needing to be dual contained and it excludes any tank below 550 gallons needing dual containment. I know the federal regulations prohibit any single wall tank on premises if to total tank storage capacity is over 1320 gallons. However, I’ve spoken with many DEP inspectors in Florida and none of them ever mention the federal regulation, and solely enforce the 550 gallon tanks needing secondary containment and nothing else.

    So therefore, is it safe to assume that the federal and state regulations in these circumstances are similar to what California & Colorado are doing with Cannabis? As stated before I’ve never once come across anyone besides an advising firm mention nor enforce the 1320 storage capacity federal regulation.

    Thank you!

    • Karensays:
      06/30/2017 at 11:05 am Reply

      Florida is one of many states that has enacted environmental protection regulations that are more stringent that the federal regulations. The federal EPA encourages this and has empowered each state to enact more stringent regulations to safeguard their land, air and water resources as they see fit – as long as those regulations are at least as stringent as the federal rules.

      So, in this case, it looks like Florida has chosen to vary from the federal rule and require tanks smaller than 1,320 gallons to have secondary containment. Because enforcement happens at the state level in all but a small handful of states, and because state rules are always at least as stringent as federal rules, they must be followed. Note that in some areas, there may also be local ordinances that are even more stringent than state regulations. When that is the case, the local ordinance must be followed.


  • Johnsays:
    12/22/2017 at 1:12 pm Reply

    We have 4 – 55 gallon drums of oil, transmission fluids, and coolant along a wall in our service bay for daily use by our 25 trucks. They each have a Pig drum spill tray w/grate secondary containment under them that can hold 6 spilled gallons with the drum on them. Is this acceptable or do I need we need to rethink this?

    • Karensays:
      01/02/2018 at 10:03 am Reply

      Hi John, thanks for your question!

      Spill trays are a great way to catch nuisance leaks and drips in your service bay. They’ll help keep your floors clean and minimize the chance of slips and falls. In some situations, spill trays are acceptable. But, you may want to consider full containment (55 gallon capacity) for the drums if any of the following situations exists:

      • A spill from any of the containers could reach a floor drain that leads offsite
      • A spill from any of the containers could reach an environmentally sensitive area, such as a river or wetland
      • You are storing waste fluids for recycling or disposal
      • A spill from one of the containers could reach an electrical panel or other equipment and cause a safety hazard, such as sparking or a fire

      If you do determine the need for full containment, you could keep the drums in the spill trays to help with incidental spills and add a berm around the area to contain larger spills.

      Hope this info helps! If you have any other questions, do not hesitate to reach out.


  • Mariansays:
    03/21/2018 at 2:19 pm Reply

    We have 55 gallon drums of paint coming into our plant at different times. How long are we allowed to let them set on wood pallets until we get them into our paint kitchens? Thanks!

    • Karensays:
      03/26/2018 at 12:15 pm Reply

      Hi Marian,

      Thank you for your question. The EPA does not have a set time frame or “grace period” for getting containers into or onto a secondary containment unit. The only reference to time is that if there is a spill of hazardous waste into a secondary containment sump, it needs to be cleaned out in a “timely” manner. (Note that some states do specify a time period for liquids to be removed from the sump.)

      With that being said, consider your facility, your processes and what is reasonable. Putting the drums onto a secondary containment pallet is a highly recognized best management practice that is used by many different types of facilities, especially if the drums will be left unattended or are in an area where they could be compromised by forklifts, pallet jacks or traffic.

      If you choose not to use secondary containment for the drums and there is a risk of a spill getting into a drain or the spilled product leaving the facility and causing pollution, consider what you would do to prevent that from happening in lieu of providing secondary containment. For example, you may be able to plug or cover floor drains in the area. Or if employees are in the area and would immediately be able to see a spill, stocking spill kits in the area could also work.

      Please let us know if you have any other questions!


  • Dansays:
    04/18/2018 at 1:09 pm Reply

    55 gallon drums of DEF sits in a building on the same concrete floor as 30 vehicles, including half as diesel vehicles. There is a gutter to capture leakage from the vehicles. Do the 55gallon drums of DEF REQUIRE a secondary containment.

    • Karensays:
      04/19/2018 at 3:48 pm Reply

      Hello Dan,

      Diesel Exhaust Fluid (DEF) is a high-purity urea and water solution. Because the drums of DEF are virgin liquids, RCRA containment rules do not apply at the federal level. Some states do have more stringent requirements and in some states and municipalities secondary containment is specifically required when storing DEF.

      If the gutter in your facility will take the DEF to an onsite retention pond or to another on-property location, the DEF may not require secondary containment. If, however, the DEF would be released to an environmentally sensitive area, such as a wetland or water body, it does have the potential to cause water quality problems in some situations, and therefore may require secondary containment or another effective means of preventing it from being released from your property.

      Please let us know if you have any additional questions.


  • Stephensays:
    07/03/2018 at 7:10 pm Reply

    Hi, would 100 bbl tank of glycol require secondary containment? It will be operated monthly with no level.

    • Karensays:
      07/09/2018 at 1:19 pm Reply

      Hi Stephen,

      Thanks for the question. If there is a potential for the glycol to enter a waterway, the tank should have secondary containment. The EPA’s Stormwater Regulations require facilities ( collectively called “point sources”) to identify potential sources of water pollution. If a spill from the glycol tank could cause water pollution, the facility needs to develop a plan that specifies actions for preventing pollution as well as for cleaning up any spills .

      Providing secondary containment can also help to minimize the costs associated with cleaning up spills, because the spill will stay in a defined area. This allows the spilled glycol to be pumped into another tank for reuse or recycling instead of costlier cleanup and remediation methods. 

      Please let us know if we can be of further help.

  • Judysays:
    09/26/2018 at 1:49 pm Reply

    Is it acceptable or unacceptable to store four drums on a wood pallet on top of the four-drum spill containment pallet?

    • Karensays:
      10/03/2018 at 2:21 pm Reply

      Hi Judy,

      It is a common practice for facilities to store their drums on wood pallets on spill containment pallets. This helps facilitate movement of the drums when they are needed in other areas. There is no regulation that specifically forbids this practice. However, you should consider whether a leak of whatever liquid is stored in the drums could react with the wood. If that is a possibility, you may want to consider switching to a plastic or metal pallet instead of wood.

      Thank you for asking about this. Please follow up with any further questions.

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