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.
RELATED POST: 5 Main Points of Secondary Containment Regulations
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.
RELATED POST: Secondary Containment Solutions for 8 Areas in Your Facility
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.
RELATED POST: Secondary Containment Checklist
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!
22 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
Mattsays:
02/08/2019 at 8:20 amGreetings,
We are a wastewater treatment plant with a room where we store approx. 10 drums at 55 gallon each of oil and about 15 pails at 5 gallons each. The room is small with only man entry doors, that is to say there is a very low risk of puncture since there are no forklifts or any other type of vehicle that can interact with the drums.
Is it fair to say that a relatively shallow 5.75″ deep containment, such as your product PAK565, would be sufficient to store 2 drums on?
Isabella Andersensays:
02/22/2019 at 1:23 pmHi there, thanks for your question!
Without knowing what regulations you are trying to meet, we can’t give a definitive yes or no answer. But, we can look at some scenarios and solutions.
If the oil is used and being managed under EPA’s Used Oil Management Rule (40 CFR 279), you would need to provide adequate containment for 10% of the total volume or 100% 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 containment.
If you are trying to comply with EPA’s Stormwater regulations, a drip deck like this one may be a best practice that you could use for managing the “most likely discharge” from a drum, but 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.
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 containment.
If you need to provide 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 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.
We hope this helps! Please let us know if you have any other questions.
Mariesays:
05/22/2019 at 4:30 pmCan you tell me where to find the threshold limit in which requires secondary containment?
Isabella Andersensays:
07/02/2019 at 12:00 pmHi there, thanks for your question!
Secondary containment is required by several different regulations, but it’s more of an “all or nothing” thing. There really aren’t thresholds.
The purpose of secondary containment devices and systems (pallets, sumps, berms, wiers, dams, etc.) is to provide a pre-determined area for spills to go if a primary container fails. They should, and in many cases are required to be, sized to accommodate a worst-case scenario container failure.
Most regulators define “worst-case” as the failure of the largest container stored in or on the secondary containment device or structure. In the EPA’s regulations for hazardous waste treatment, storage and disposal facilities, the requirement specifically states that a secondary containment system “must have sufficient capacity to contain 10% of the volume of the containers or the volume of the largest container, whichever is greater.” [40 CFR 264.175] If the containment system is outdoors, additional capacity is required to allow for rain and snowmelt in addition to the required volume from the container(s).
Nikisays:
08/27/2019 at 8:57 amFor secondary containment to meet OSHA regulations, does the waste container have to be elevated above the spill volume? I have seen many companies selling containment where the waste container would have to sit in the spillage. Is this still meeting OSHA regulations?
Isabella Andersensays:
09/23/2019 at 11:00 amHi there,
While secondary containment systems are a great way to promote good housekeeping and help prevent slips, trips and falls, OSHA does not have any specific requirements for secondary containment systems. This typically falls under the auspice of the EPA. For secondary containment systems in hazardous waste treatment, storage and disposal facilities, there are several options to prevent a container from sitting in its spillage. Elevating the drums on a spill containment pallet is one way to satisfy the requirement, but the regulation allows for many different types of systems. To allow for these variances, the rule requires that the base of a secondary containment system can be sloped, elevated, or “otherwise designed” to drain and remove any spilled liquids [40 CFR 264.175(b)(2)].
In the case of containment products where the container sits inside of the containment area, this would be an example of a system that needs to be designed to allow drainage. Some of the ways that this could be achieved are vacuuming or pumping any accumulated liquid from the containment area, or using a drain valve, if the unit has one.
No matter what type of secondary containment system or device is used, they all need to be inspected regularly. When spills or accumulated precipitation are discovered, then need to be removed in a timely manner [40 CFR 264.175(b)(5)].
Thanks for your question!
Isabella
Donald Goldensays:
12/10/2019 at 9:02 amHello Isabella-
I’m working with a plant manager who is convinced there is an exception that allows for the transfer (in this case he’s stating “offloading” specifically) of liquids (haz or non-haz) without containment as long as the process is continuously monitored. In 27 years I’ve never heard or read anything remotely close to this but I’ve certainly been wrong before (and will be again).
Thanks!
Isabella Andersensays:
01/30/2020 at 10:41 amHi there!
It’s not so much an exemption as it is a different way of approaching a regulatory requirement. When liquids (hazardous or non-hazardous) are transferred, there’s always the risk of a hose breaking, a coupling failing or something else happening that causes a spill.
Secondary containment is a highly recognized best management practice that many facilities use (especially when transferring hazardous materials) to help ensure that if there is a spill, it doesn’t reach a drain or other environmentally sensitive area. For many of EPA’s regulations, secondary containment is just that: a best management practice, rather than a strict requirement.
When your facility is subject to stormwater and other environmental regulations, in many cases, the EPA allows the facility to come up with a plan to prevent spills from impacting the environment. It’s up to the facility to look at their risks and mitigate those using the methods that make sense for their situation(s). Those methods need to be effective and realistic of course, but the EPA doesn’t always dictate the exact methods or practices that must be used.
So, in this situation if the transfer is done in an area with no drains; if the area is sloped to allow the liquids to be contained and collected; if there’s no means for a spill to be released to the environment; or if the materials being transferred do not present an environmental or health hazard; continuous monitoring may be sufficient – especially if it is coupled with an adequate way to quickly contain and control spills and a sufficient number of trained staff onsite to perform those duties.
Thank you,
Isabella
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