What Are the EPA Regulations for Secondary Containment Systems?
Updated: Feb 5
Chemical spills can wreak havoc on facility equipment and the environment, as well as present dangers for both worker and product safety. Secondary containment is a method which supports a primary containment system, and it safeguards against the spread of such dangers.
By having an effective secondary containment system and chemical resistant epoxy flooring, you can better prevent the unauthorized release of toxic or hazardous materials into work areas and the environment.
What EPA regulations are there for secondary containment systems?
The Environmental Protection Agency (EPA) addresses containment and secondary containment systems in the Resource Conservation and Recovery Act (RCRA), found in Title 40 Code of Federal Regulations (CFR) Part 264.
The EPA refers to the need for containment and secondary containment in two different areas. First in Subpart I, Use and Management of Containers (40 CFR 264.175), which covers portable storage containers for hazardous waste, and the second in Subpart J, Tank Systems (40 CFR 264.193), which covers large stationary containers for hazardous waste.
EPA: Portable Containers
The EPA refers to secondary containment under 40 CFR 264.175(b), which says that a containment system must be designed and operated as follows:
A base must underlie the containers until the collected material is detected and removed.
The base must be sloped or the containment system must be otherwise designed and operated to drain and remove liquids resulting from leaks, spills or precipitation, unless the containers are elevated or are otherwise protected from contact with accumulated liquids.
The food grade epoxy containment system must have sufficient capacity to contain 10% of the volume of containers or the volume of the largest container, whichever is greater.
Run-on into the containment system must be prevented unless the collection system has sufficient excess capacity to contain any run-on which might enter the system.
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.
Under 40 CFR 264.175(c), the EPA addresses storage areas that store containers holding only wastes that do not contain free liquids, and sets the following provisions for the storage areas:
The storage area must be sloped or otherwise designed and operated to drain and remove liquid resulting from precipitation.
The containers must be elevated or otherwise protected from contact with accumulated liquid.
There are certain wastes for which a storage area alone will not suffice. These waste streams are listed under 40 CFR 264.175(d) and require a containment system in addition to the storage area.
EPA: Tank Systems
The EPA specifies under 40 CFR 264.193(b) that secondary containment systems are required to prevent any migration of wastes or accumulated liquid out of the system to the soil, groundwater or surface water during the use of the tank system. Minimum requirements of how the urethane cement flooring system must be constructed are listed in 40 CFR 264.193(c) and include:
Constructed materials that are compatible with the wastes to be placed in the tank system and must have sufficient strength and thickness to prevent failure.
Placed on a foundation or base capable of providing support to the secondary containment system, resistance to pressure gradients above and below the system.
Provided with a leak-detection system that is designed and operated so that it will detect the failure of either the primary or secondary containment structure or the presence of any release of hazardous waste or accumulated liquid in the secondary containment system within 24 hours.
Sloped or otherwise designed or operated to drain and remove liquids resulting from leaks, spills or precipitation. Spilled or leaked waste and accumulated precipitation must be removed from the secondary containment system within 24 hours, or in as timely a manner as possible to prevent harm to human health and the environment.
Uniform Fire Code and International Fire Code
Facilities that store hazardous materials may also be required to meet either the Uniform Fire Code (UFC) or International Fire Code (IFC).
If you have questions regarding compliance with either the UFC or IFC standards, consult with your Authority Having Jurisdiction (AHJ) – normally your local fire marshal. When referring to the UFC you need to clarify with the AHJ, which fire code release needs to be applied to achieve compliance.
Choosing a Containment System
When selecting a containment system for an application, many issues need to be considered. A list of issues and some things to contemplate are listed below.
Is the system chemically compatible with the products being stored?
How will the system be monitored and cleaned?
What volume and weight of the containers will be stored?
How often will the containment system be moved? How will it be moved?
How will the containers be loaded onto the system?
How many containers will be loaded on the system?
Are any of the products being stored considered flammable?
What are the state and local codes for secondary containment in your area?