• Does Secondary Containment Have Your Head Spinning
  • 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.

  • 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).



    • 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”. (

      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.



    • 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.

Your email address will not be published. Required fields are marked *