Secondary Containment — Precautionary Measures Pay Off

Remember the catastrophe that happened in Charleston, West Virginia? There was no regulatory requirement for the chemical 4-methylcyclohexane methanol (MCHM) to have secondary containment, and when a tank ruptured, the contents of the tank ended up in the river.

This river was a source of drinking water for the local community of 300,000 people. Nothing could be done once this chemical was in the river, since the water could not be boiled to make it consumable (potable) again. The townsfolk could not drink or bathe in the water, and health concerns won’t be fully known for years. Many still will not drink the water.

What could have prevented this from happening and affecting the health of an entire town? Two words: secondary containment.

Environmental Protection Agency (EPA) and Occupational Safety and Health Administration (OSHA) regulations are aimed at secondary containment for hazardous waste, hazardous materials and oil. Since it’s not a requirement, why should you have secondary containment for nonhazardous waste or materials?

Stopping a chemical from leaking or rupturing may be impossible, but containing the potential spill is not. Taking precautions could have prevented the accident in West Virginia and others like it. Secondary containment collects the leaked material and makes it easier to clean up, keeps it from getting into the ground and waterways and allows for possible recycling of the material.

Secondary containment is a second barrier, or means of collecting, capturing or containing spilled or leaking material from a container or tank. It is a contingency plan to help prevent a disaster from happening. Use of secondary containment may be recommended as a preventative measure to reduce impacts on health, safety, and the environment.

Secondary containment can be used for something as small as a pail or as large as a tank and may be permanent or portable.

It can be a spill containment pallet, Collapse-A-Tainer, Build-A-Berm or a Roll-top. Or it can be something more permanent like a sloped room or area to accumulate liquids, a concrete-bermed area, or a lined dirt berm. Anything that will contain or hold back liquid in the event of a leak or spill can be considered secondary containment. Even absorbents can create containment.

Why use secondary containment if there is no regulation requiring it? The answer is simple: to prevent spills and keep our environments and communities safe.

Even though a regulation doesn’t mandate the use of secondary containment for the material you are storing, it’s still the best way to help prevent potentially catastrophic events. However, in those situations where a nonhazardous material may spill into a storm drain, or may pick up additional contaminants en route to a storm drain, secondary containment may be required by the state or the local authority.

NOTE: West Virginia Governor Earl Ray Tomblin recently introduced the WV Source Water Protection Act in response to the catastrophic event of MCHM spilling into the public drinking water source.

• • Implement reasonable regulations governing the storage of specified volumes of regulated material in industrial aboveground storage tanks within zones of critical concern in the vicinity of public water systems
• • Assure that industrial aboveground storage tanks are constructed and maintained in a manner consistent with acceptable industry safety standards
• • Assure that public water systems properly plan for contingencies and prepare appropriate emergency response plans to implement in the event that a leak from an industrial above-ground storage tank jeopardizes one or more public water systems
• • Protect human health and the environment from dangers posed by the storage of specified volumes of regulated material in industrial above-ground storage tanks located within zones of critical concern in the vicinity of public water systems.

Having secondary containment when it’s not required can be a Best Management Practice (BMP), pollution preventer, earth protector and lifesaver.

• • Keeps cleanup costs to a minimum
• • Keeps the air, land and water free from spilled chemicals
• • Keeps people and property safe
• • Keeps your business running in the event of a small or large catastrophe
• • Keeps your company’s name in the paper for a good reason and not for a bad reason
• • Saves money
• • Keeps slips, trips and falls from spilled liquid to a minimum
• • Keep critical business areas functioning
• • Keeps our planet clean for future generations

Recovering from a disaster is easy when you have a plan in place. That plan is as simple as two words: secondary containment. It’s easy to remember and easy to implement.