Question: Do my 500- and 1,000-gallon kerosene tanks need secondary containment? What if the material being stored is considered used oil? I know that hazardous waste has secondary containment requirements, but what if the material is not waste but a product that is used?
Answer: We always recommend secondary containment as a best practice, whether it’s required or not, to stop the release of spills and help ensure your facility is in compliance. However, there are certain regulations that could require you to have secondary containment around those tanks.
Because you have the capacity to store 1,500 gallons of kerosene, your facility is most likely subject to the Environmental Protection Agency’s (EPA) Spill Prevention Control and Countermeasures (SPCC) regulations. One of the requirements in this regulation is to provide secondary containment to prevent spills from leaving your property and polluting waterways or underground water tables [40 CFR 112].
RELATED POST: Shedding Light on SPCC Secondary Containment Requirements
If the oil you’re storing is considered hazardous waste, then the EPA requires you to have enough secondary containment to contain 100 percent of your largest container or 10 percent of the total volume, whichever is greatest [40 CFR 264.175].
RELATED POST: How to Make Hazardous Waste Determinations
RELATED POST: Calculating Secondary Containment Needs
If you’re going to recycle the used oil, you may qualify to take advantage of the EPA’s used oil standard, which provides some relief from regulation. You will still be required though to have best management practices in place, such as secondary containment, to prevent spills from reaching the environment.
Virgin Hazardous Materials
Most local jurisdictions follow either the Uniform Fire Code (UFC) or the International Fire Code (IFC) in regards to corrosive, flammable and combustible materials stored in the workplace. The rules very slightly, but both require secondary containment systems to be used to contain not only spills from the containers stored in them,, but water from sprinkler systems or other firefighting operations as well.
In addition to these rules, both the EPA and the Occupational Safety and Health Administration require you to be prepared for spills. Neither agency says what you need to have to prepare for spills, but common solutions include pallets and decks for drums, berms and dikes for larger areas with multiple containers and absorbents and spill kits.
If your tanks are stored indoors, pallets and decks may be a good option for you. If the tanks are outdoors, berms may be a better option, especially if they are fitted with filtration devices that allow water to be removed from the containment area while preventing spills from being discharged.
It’s also important to remember that your state and local municipality might have more stringent requirements than the federal government. Check with both to find out what additional secondary containment regulations may apply to your tanks.