EPA & OSHA Secondary Containment Requirements

Expert Advice > Blog Post > Does Secondary Containment Have Your Head Spinning

Does Secondary Containment Have Your Head Spinning
by Karen

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!

TAGS: Secondary Containment

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.

4 Comments

Curt Williamssays:
01/09/2014 at 8:02 am Reply
Kindly 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 pm Reply
  Sealing 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 pm Reply
Can 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 pm Reply
  Hi 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