Secondary containment means different things to different people. So it’s understandable that you may be a little confused! The first thing you need is a basic understanding of what secondary containment is. You also need to understand how your secondary containment needs are tied into the specific Environmental Protection Agency (EPA) or Occupational Safety and Health Administration (OSHA) regulation or regulations that apply to your facility.
The 411 on Secondary Containment
Here’s the scenario: Your primary container fails (e.g., a drum/barrel, IBC tote, storage tank — you get the picture). The spill is heading directly toward a drain that connects with the public sewer system. But you’re not too concerned, because your secondary containment stops the spill from spreading. So, basically, secondary containment is any system, device or control measure that is used to stop a discharge from leaving a specified area. The theory is that if a spill can be contained, it will not pollute the environment or cause additional harm. More than a dozen EPA and OSHA regulations require secondary containment, and it is mentioned in several industry standards.
Obviously, a secondary containment system is something you want to have.
What Does Secondary Containment Look Like?
Here’s where it gets a little sticky. Neither the EPA nor OSHA specifies what a secondary containment system must look like. They have guidelines on the spill volume that needs to be contained and what the secondary containment system must be capable of doing, but no specific design, device or product is specified by regulation, because both agencies recognize that each facility will have different scenarios and needs. For small spills, something as simple as absorbents can be used for secondary containment; in other cases you might need a highly engineered system.
So you have the liberty to build, design, install and use whatever type of systems or products you want — as long as they meet the regulated criteria and are truly capable of stopping a discharge from leaving an area.
Who Needs Secondary Containment?
If you store hazardous materials and/or hazardous wastes in your facility, you are likely to need secondary containment systems to meet one or more regulations. OSHA and EPA have very broad definitions of what constitutes a hazardous material. You probably already know if you have hazardous materials onsite, but basically, if it has a Safety Data Sheet (SDS) or it is a liquid that could harm a person or the environment, chances are good that there is a regulation that considers it to be hazardous.
Now, before you get overwhelmed thinking about containment for every single thing in your facility that has a SDS, let’s put things in perspective. That little half-ounce bottle of correction fluid on every desk is hazardous because it contains a flammable liquid. If it spills on someone’s desk, it’ll make a mess, but it’s not likely to enter a floor drain and contaminate a nearby creek. So, chances are good that it won’t need secondary containment. As a rule of thumb, look at the liquids that come in drums and totes, as well as anything that’s stored in bulk tanks, and focus your secondary containment efforts on those areas first.
Bottom line: You want to keep spills out of the environment just like OSHA and EPA do. And you have lots of ways to accomplish that goal. If you’re still not sure about what you need or are confused about regulations, give us a call. New Pig will contain your spills and set your mind at ease.
You tell us: What other questions do you have about secondary containment? Leave a comment below!
14 Comments
Curt Williamssays:
01/09/2014 at 8:02 amKindly direct me to a good reference source which reguires a sealant/protective coating for concrete surfaces in fuel download/transfer areas. There are various type sealants.
May be a Best Management Practice (EPA, OSHA, API, UFC).
Thanks!
Curt
Karen Hamelsays:
01/10/2014 at 7:33 pmSealing or applying a protective coating to concrete surfaces in fuel transfer areas would certainly be considered a Best Management Practice (BMP) because in the event of a spill, it would prevent the fuel from penetrating the surface of the concrete, making cleanup faster and easier.
Because regulations often have a broad applicability, most are performance based. This means that there is often room for interpretation.
Under EPA’s Spill Prevention Control and Countermeasures (SPCC) rule, there is no direct requirement for transfer areas to be sealed, however 40 CFR 112.8(c)(2) requires diked areas around bulk storage containers to be “sufficiently impervious” to oil. Also, SPCC plans must be “prepared in accordance with good engineering practice,” so a professional engineer certifying a plan or an authority having jurisdiction could make the argument that sealing the concrete is a good engineering practice. (40 CFR 112.3)
NFPA 30 doesn’t discuss transfer areas, but requires containment areas to be “liquidtight” (A.9.13) It also mentions that the authority having jurisdiction needs to deem the area to be “acceptable,” so sealing the concrete could certainly be deemed an “acceptable” practice.
Next, we come to RCRA regulations. Technically, these apply to hazardous wastes, but they may still be relevant. If portable containers are stored in this area, 40 CFR 264.175 requires secondary containment systems that are “sufficiently impervious” to leaks and spills. Secondary containment for tank systems have similar requirements at 40 CFR 264.193
The UFC secondary containment requirements apply to hazardous materials(not just hazardous wastes) but their secondary containment standards are similar to the RCRA requirements. In their verbiage, containment areas should be “liquid tight”. (60.3.2.8.2.2)
API Bulletin D16 is another source of information that contains guidance for developing systems to help facilities comply with the EPA’s SPCC and secondary containment requirements.
I hope that these resources are helpful!
Mikesays:
09/16/2015 at 3:02 pmCan you please tell me where I may find the guidelines on the spill volume that needs to be contained? Or any guidelines, given by either agency, for liquid drum and tote secondary containment.
Thanks!
-Mike
Brittanysays:
09/18/2015 at 12:46 pmHi Mike,
Thanks for your comment! This blog post on how to calculate secondary containment should answer your question.
If you have any other questions or concerns, do not hesitate to leave another comment.
Thanks,
Brittany
Debbie Keyssays:
11/07/2017 at 12:15 pmI understand that there are regulations noting that secondary containment is to be kept clean and dry. Where are these located? While this is common sense, I’m being asked to provide justification for the statement.
Brittanysays:
11/13/2017 at 10:17 amActually, there is more than one reference about the need to keep secondary containment areas tidy. The two most frequently cited are from RCRA and SPCC. Neither specifically says “clean and dry” verbatim, but that is the EPA’s intent.
RCRA: 40 CFR 264.175(b)(5) states that “spilled or leaked waste and accumulated precipitation must be removed from the sump or collection area in as timely a manner as is necessary to prevent overflow of the collection system.”
SPCC: 40 CFR 112, Appendix F, 1.8.1.3 requires secondary containment areas to be inspected for precipitation, debris, vegetation, cracks, erosion and other situation that could compromise the integrity of the area and/or limit the containment capacity.
Hope this info helps!
Charlessays:
02/08/2018 at 7:18 amIf your facility has a waste water treatment facility where all drains flow to is secondary containment required?
Karensays:
03/05/2018 at 4:22 pmHi Charles, thanks so much for your comment and question!
Secondary containment is not always required when a waste water treatment facility is present. But it is important to consider the following situations when it may be necessary or desirable to have secondary containment.
First: Review the language in your wastewater treatment permit. Some facilities are only permitted to handle and treat the pollutant loads that are normally expected from their daily processes. They aren’t permitted to handle upset conditions, off-specification batches of chemicals or spills. If the treatment facility is not permitted to handle these situations, secondary containment can help prevent spills from reaching the treatment facility.
Second: Is the spilled/discharged material able to be treated by the waste water treatment facility? This is sort of related to the first point, but consider what types of chemicals could be sent to treatment and how they will affect the waste water treatment facility. If the facility isn’t expecting a material, it could pass through their system, harm sensors or destroy their current treatment systems.
Third: Consider the physical and chemical characteristics of the chemicals stored onsite. If there is a potential for incompatible chemicals to mix on their way to treatment, if there are corrosives that would damage pipelines, or if there is any other situation that would cause a safety or environmental emergency while the spill was traveling from the drain to the treatment facility, secondary containment may be necessary.
I hope this information is helpful! Please let us know if you have any other questions.
Thanks,
Karen
Haven Snowsays:
04/25/2018 at 9:12 amHow are certain companies and big box stores (i.e. home depot, wal-mart) allowed to store chemicals directly on the ground, with no containment?
Karensays:
04/27/2018 at 3:16 pmSecondary containment is always a good idea, because it keeps leaks and spills in check and in many cases allows the spilled product to be recovered and reused or recycled. But, the EPA’s secondary containment rules only apply if the facility meets the conditions of the regulation.
So, in the case of big box stores, or other types of facilities with hazardous chemicals, storing chemicals directly on the ground, the RCRA secondary containment rules for hazardous waste storage would not apply because they are storing virgin products, not hazardous wastes. If you aren’t storing or managing hazardous WASTES, the RCRA secondary containment rule does not apply. It is still a great best management practice, but it is not a requirement at the federal level.
If the facility does not have more than 1,520 gallons of oil or oil products onsite (or 42,000 gallons in an underground storage tank), SPCC rules do not apply. Some big box stores do have more than these thresholds onsite, but there are exemptions to this rule for retail establishments. Again: secondary containment is a great idea, but not required for those under the threshold or those selling it to general consumers.
This brings us to EPA’s Stormwater Pollution Prevention Rule, which is the most encompassing because it encompasses any type of pollutant: virgin or waste. If the chemicals are stored in an area where there are no floor drains or storm drain that discharge to navigable waters, or if a spill of the hazardous pollutant (chemical) would not leave the facility and cause water pollution in some other way (such as getting into underground wells, etc) secondary containment is not required.
Thanks,
Brittany
Virak Tomsays:
05/11/2018 at 6:10 pmWould secondary containment be required for 1200 gal of a non-oil / non-hazardous chemical under any regulation?
Karensays:
05/15/2018 at 3:25 pmHi Tom,
Thanks for asking.
I’m not aware of regulations that specifically require secondary containment for non-hazardous chemicals. However, the scope of what is “hazardous” is broad enough that many things that you wouldn’t typically consider to be hazardous can indeed be.
Good examples of this are food products such as milk and corn syrup. Neither requires a SDS and is not traditionally viewed as hazardous, but each of these liquids can cause significant environmental harm if released to land or waterways, so in many cases each of these liquids would need to have secondary containment or some other effective means of preventing an accidental release. Facilities are permitted to determine the methods, devices, etc. that they will use to effectively prevent environmental pollution. Secondary containment is definitely a proven option, but it is not the only acceptable method.
Another consideration is employee safety. Could employees be harmed if this tank fails? For example, if this is a (non-hazardous) water tank and employees are working in close proximity to it, could they be knocked over, engulfed by the water or otherwise harmed if the tank fails? Employers need to evaluate all types of hazards at their facilities, including both physical and chemical, and develop plans and procedures to protect employees. In this example, secondary containment around the tank might be one measure to take, but it is not specifically spelled out or required in OSHA regulation, which instead encourages employers to choose the methods that they feel will best accomplish their needs.
Hope that helps! Please reply if you need further information.
Karen
Steve Docekalsays:
10/08/2018 at 10:16 amWe are a small aviation company in Florida located on a large airport. We produce very little <5 gals a year in waste a year. We store very little in the way of hazardous materials. Our largest item would be a 55 gal drum of aircraft soap (Surfactant) which is Carbon-X, this is stored in the hanger well behind the oil-water drain/separator. We were recently told during our annual SWPPP inspection that we should have secondary containment for this drum. I have read the rule, but I am confused on the size of containment I need. Do I need containment of 55 gallons or 5.5 gallons of containment. We will only store this single 55 gallon drum in the containment. Thanks in advance. Steve
Karensays:
10/12/2018 at 9:15 amHi Steve, thanks for your comment.
Because there are several different EPA regulations that require secondary containment, it can be confusing to try to determine which particular rules need to be followed. You mention choosing between 55 and 5 gallons of containment. This stems from the RCRA hazardous waste generator rules, which require your secondary containment system to be able to hold 100% of the largest container being stored in the system OR 10% of the total volume of all of the containers being stored in the system. Because you’re only storing one container, you would need enough capacity for 55 gallons. But, remember that this body of regulation is specific to hazardous waste storage.
You also mentioned that your need for secondary containment stems from a Stormwater Pollution Prevention Plan (SWPPP) inspection. EPA’s Stormwater Regulations do not specifically require secondary containment systems, but they do require facilities who could cause water pollution to put a plan in place (namely an SWPPP) that describes the control measures that they have implemented to prevent spills and minimize hazards. Secondary containment systems are one of the most commonly used control measures used to meet this requirement. Because the goal is to prevent a spill from entering a drain, the secondary containment system needs to be capable of holding the entire contents of whatever is stored in the system. In this case, 55 gallons. In your case, if the secondary containment will be in a hanger, you do not need additional sump capacity to allow for rain or snow melt. If the secondary containment system is stored outdoors where it could also collect rainwater or snow, it should be appropriately over-sized to accommodate the 55 gallons as well as the rainwater or snow.
Hope this information helps! If you have any other questions, feel free to leave another comment or email us at karenea@newpig.com
Thanks,
Karen
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