• 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.

  • Debbie Keyssays:
    11/07/2017 at 12:15 pm Reply

    I 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 am Reply

      Actually, 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, 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 am Reply

    If your facility has a waste water treatment facility where all drains flow to is secondary containment required?

    • Karensays:
      03/05/2018 at 4:22 pm Reply

      Hi 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.


Your email address will not be published.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