Question: We have a room to store about ten 55-gallon oil drums and fifteen five-gallon oil pails at our wastewater treatment plant. Forklifts and other vehicles can’t make it into the room, which lowers the risk of a drum being punctured. We’d like to provide secondary containment for these drums. Would a relatively shallow, 5.75” deep containment deck, such as this Poly Drip Deck, be sufficient to store two drums on?
Answer: It is important to protect your drums with secondary containment to prevent leaks and spills making their way to a nearby drain or getting into walkways and creating a slip hazard. Choosing the right type of secondary containment isn’t always clear, especially when you factor in multiple environmental regulations that may apply. Let’s dive into the most common regulations that require containers to have secondary containment and figure out what options might work for your facility.
If the oil is used and being managed under the Environmental Protection Agency’s (EPA) Used Oil Management Rule (40 CFR 279), you would need to provide adequate secondary containment for 10 percent of the total volume or 100 percent of the largest container, whichever is greater. Your largest container is 55 gallons, but the total volume stored is 625 gallons, so you would need to provide 62.5 gallons of secondary containment.
Related content: Does the EPA Allow New Oil to Be Stored Outside of Secondary Containment?
If you are trying to comply with EPA’s Stormwater regulations, a drip deck like the one you mentioned may be a best practice that you could use for managing the “most likely discharge” from a drum. However, if spills from this area could reach a storm drain or water body, you would need to have additional plans/provisions to prevent that in addition to the drip deck such as having spill kits, drain blocking devices or other methods that will successfully keep the pollutant (in this case, oil) from reaching navigable waters.
If the oil is a hazardous waste that is not being managed under EPA’s Used Oil Management Rule, it would be subject to RCRA hazardous waste management rules and require full secondary containment.
If you need to provide full secondary containment for this area, and the room has a floor that is free of cracks and can be sealed, you could possibly use the room itself as containment by putting a berm near the doorway and around the perimeter of the room instead of using drip decks or spill pallets. Many of our customers use our Build-A-Berm System to achieve their secondary containment needs while allowing forklift, dolly and cart traffic to move freely in and out of the room.
The good news is that when it comes to providing secondary containment, you have many options. This allows you to choose the best type – or types – for your situation, and allows you to comply with multiple regulations.