| With regards to spill containment the
EPA in the Resource Conservation & Recovery Act (RCRA) differentiates
between a containment system and a secondary containment system.
According to RCRA, a containment system consists of portable
containers such as 55-gallon drums that are used for the management
of hazardous substances is specified in 40CFR 264.175.
Containment System - Portable Containers
(Drums)
The EPA does not use the term "secondary containment"
when addressing portable containers. Instead, it refers only to
containment under 40 CFR part 264.175(b). A containment system
must be designed and operated as follows:
1. A base must underlie the containers which is free of cracks
or gaps and is sufficiently impervious to contain leaks, spills,
and accumulated precipitation until the collected material is
detected and removed;
2. 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;
3. The containment system must have sufficient capacity to contain
10% of the volume of containers or the volume of the largest container,
whichever is greater. Containers that do not contain free liquids
need not be considered in this determination;
4. Run-on into the containment system must be prevented unless
the collection system has sufficient excess capacity in addition
to that required in paragraph (b)(3) of this section to contain
any run-on which might enter the system; and
5. 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 part 264.175(a), the EPA established the following
requirements for storage areas that store portable containers:
1. The storage area is sloped or is otherwise designed and operated
to drain and remove liquid resulting from precipitation, or
2. The containers are elevated or are otherwise protected from
contact with accumulated liquid.
264.174(d) states that for certain wastes streams a containment
system and storage area are required.
Under Division IV, Section 80.402(b)(2)(F), Dispensing and Use,
the UFC addresses Spill Control, Drainage Control, and Secondary
Containment with regard to hazardous materials, stateing that, "Rooms
or areas where hazardous material liquids are dispensed into containers
exceeding a 1-gallon capacity or used in open containers or systems
exceeding a 5-gallon capacity shall be provided with a means to
control spills. Secondary containment shall be provided when the
capacity of an individual container exceeds 55-gallons or the aggregate
capacity of multiple containers exceeds 100-gallons."
The EPA is more specific with regard to the capacity of containment
a system needs to hold whereas the UFC addresses what situation
would be applicable for implementation.
Secondary Containment System –
Tank Systems
According to 40CFR 264.193 a secondary containment system is used
in regard to large stationary systems, such as tanks which contain
a hazardous substance.
EPA defines Secondary Containment under 40 CFR 264.193(b), Containment
and Detection of Releases. Secondary containment systems are usually
constructed and designed by a facility to meet the size requirements
of a stationary tank they have on their premises. The EPA lists
minimum requirements of how tank systems must be constructed as
follows:
1. Systems must be constructed of or lined with materials that
are compatible with the wastes(s) to be placed in the tank system
and must have sufficient strength and thickness to prevent failure
owing to pressure gradients (including static head and external
hydrological forces), physical contact with the waste to which
it is exposed, climatic conditions, and the stress of daily operation
(including stresses from nearby vehicular traffic).
2. Systems must be placed on a foundation or base capable of providing
support to the secondary containment system, resistance to pressure
gradients above and below the system, and capable of preventing
failure due to settlement, compression, or uplift;
3. Systems must be 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, or at the earliest
practicable time if the owner or operator can demonstrate to the
Regional Administrator that existing detection technologies or
site conditions will not allow detection of a release within 24
hours; and
4. Systems must be 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 is possible to prevent harm to human
health and the environment if the owner or operator can demonstrate
to the Regional Administrator that removal of the released waste
or accumulated precipitation cannot be accomplished within 24
hours.
In addition to the requirements above, a secondary containment system
is required to have one or more of the following devices:
1. A liner (external to the tank);
2. A vault;
3. A double-walled tank; or
4. An equivalent device as approved by the Regional Administrator
These four devices also need to meet stringent specifications. For
example, an external liner must be:
1. Designed or operated to contain 100 percent of the capacity
of the largest tank within its boundary;
2. Designed or operated to prevent run-on or infiltration of precipitation
into the secondary containment system unless the collection system
has sufficient excess capacity to contain run-on or infiltration.
Such additional capacity must be sufficient to contain precipitation
from a 25-year, 24-hour rainfall event.
3. Free of cracks or gaps; and
4. Designed and installed to surround the tank completely and
to cover all surrounding earth likely to come into contact with
the waste if the waste is released from the tank(s) (i.e., capable
of preventing lateral as well as vertical migration of the waste).
The EPA states that a secondary containment system should be
designed to retain the spill from the largest single container.
The UFC adds to this by noting, "... plus the design flow
rate of the automatic fire extinguishing system from the area
of the room or area in which the storage is located or the system
design area, whichever is smaller, as well as being capable of
containing the flow for a period of 20 minutes."
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.
1. Is the system chemically compatible with the products
being stored?
- Containment system sumps are constructed of High-density
polyethylene or steel.
- Choice of grids or platforms depends on chemical resistance
and disposability of the product. Consider:
- Wood platforms once contaminated, need to be disposed
of according to local codes
- Fiberglass grids are compatible with a wide variety of
chemicals, but are not suitable for corrosive materials
- Polyethylene grids are compatible with a wide variety
of chemicals, including many corrosive materials
2. System Management - Monitoring and cleaning?
- Most units have drains. If they don't, usually a spill cleanup
kit will be adequate to clean up the internal sump area of the
system.
3. What volume and weight of the containers will be stored?
- Federal codes require that a containment system must have
sufficient capacity to contain 10% of the volume of containers
or the volume of the largest container, whichever is greater.
Check with your state for local restrictions that may apply
(i.e., Maine requires each building or separate storage area
to have containment and collection systems the capacity of which
must exceed 20% of the total capacity of all containers and
tanks used to store liquid wastes, or 110% of the capacity of
the largest container or tank, whichever is greater).
- What is the static weight capacity of the containment system.
This is a weight in a stationary mode.
4. How often will the containment system be moved?
How will it be moved?
- Portable containment units are intended to be moved without
containers on them. This is the safest mode of transport. The
containers can be replaced once the containment system has reached
its destination.
- Most portable containment systems are constructed with fork
pockets. These are designed to accept and be moved by forklifts.
5. How will the containers be loaded onto the system?
- Ramps that accommodate containment systems are the easiest
way to load a system. Low-profile containment systems have also
been developed to address the loading issues.
6. How many containers will be loaded on the system?
- Portable containment systems range from four 5-gallon pails
to one 55-gallon drum to whole-room containment systems for
drums. Make sure local fire codes are met when dealing with
flammable products and the larger containment systems. There
are restrictions for quantities of flammable products that can
be stored in one area depending on the class of flammable product.
7. Are there flammable products being stored?
- Special provisions need to be taken into account, such as
grounding and bonding and the amount of flammable product being
stored in one area. Check into local codes for these specifications.
8. What are the state and local codes for secondary containment
in your area?
- A listing of the regional EPA offices are shown (right) along
with phone numbers of divisions that deal with secondary containment
of wastes. For more information on state codes contact the regional
office who can refer you to state EPA agencies that can explain
state codes or contact your local Fire Marshal for additional
information on secondary containment requirements in your area.
Summary
The EPA has set federal guidelines addressing containment and secondary
containment; however, localities or regions are allowed to make
more stringent codes. Depending on the size and type of primary
container, a customized secondary container may be needed. For example,
Intermediate Bulk Containers (IBCs) require a specially designed
containment system to hold the weight and design of the tank. Check
with local codes on secondary containment or containment to find
the provisions for the area.
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Check with Local or regional EPA offices for other guidelines that may apply
in your area.
Regional EPA Offices
Region 1: Connecticut, Massachusetts, Maine, New Hampshire,
Rhode Island, Vermont
General Information Hotline:
617-565-3420
Waste Management Division:
617-573-5700
Region 2: New Jersey, New York, Puerto Rico, U.S. Virgin
Islands
Environmental Services Division:
215-597-4532
Hazardous Waste Compliance:
212-264-8356 or 212-264-0504
Region 3: Delaware, District of Columbia, Maryland, Pennsylvania,
Virginia, West Virginia
Environmental Services Division:
215-597-4532
Hazardous Waste Management Division:
215-597-8181
Region 4: Alabama, Florida, Georgia, Kentucky, Mississippi,
North Carolina, South Carolina, Tennessee
Environmental Services Division:
404-546-3136
RCRA Permit and Compliance:
404-347-3433
Region 5: Illinois, Indiana, Michigan, Minnesota, Ohio,
Wisconsin
RCRA: 312-353-0398
Waste Management Division:
312-886-7579
Region 6: Arkansas, Louisiana, New Mexico, Oklahoma, Texas
Environmental Services Division:
214-655-2210
Region 7: Iowa, Kansas, Missouri, Nebraska
Environmental Services Division:
913-551-5000
Region 8: Colorado, Montana, North Dakota, South Dakota,
Utah, Wyoming
RCRA Management Branch:
303-293-1513
Region 9: Arizona, California, Hawaii, Nevada, American
Samoa, Guam
Hazardous Waste Management Branch:
415-744-1730
Region 10: Alaska, Idaho, Oregon, Washington
Environmental Services Division:
206-871-8701
Waste Management Branch: 206-553-2782
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Below are some related terms as defined by the EPA and UFC.
Container: Any portable device in which a material
is stored, transported, treated, disposed of, or otherwise handled
(EPA).
or
Any vessel of 60 United States gallons or less capacity used for
transporting or storing hazardous materials (UFC).
Containment Building: A hazardous waste management
unit that is used to store or treat hazardous waste under the
provisions of subpart DD of parts 264 or 265 of Title 40 (EPA).
Leak-Detection System: A system capable of detecting
the failure of either the primary or secondary containment structure
or the presence of a release of hazardous waste or accumulated
liquid in the secondary containment structure. Such a system must
employ operational controls (e.g., daily visual inspections for
releases into the secondary containment system of aboveground
tanks) or consist of an interstitial monitoring device designed
to detect continuously and automatically the failure of the primary
or secondary containment structure or the presence of a release
of hazardous waste into the secondary containment structure (EPA).
Liner: A continuous layer of natural or man-made
materials, beneath or on the sides of a surface impoundment, landfill,
or landfill cell, which restricts the downward or lateral escape
of hazardous waste, hazardous waste constituents, or leachate
(EPA).
Portable Tank: Any packaging over 60 U.S. gallons
capacity and designed primarily to be loaded into or on or temporarily
attached to a transport vehicle or ship and equipped with skids,
mounting, or accessories to facilitate handling of the tank by
mechanical means. It does not include any cylinder having less
than a 1000 pound water capacity, cargo tank, tank car tank or
trailers carrying cylinders of over 1000 pound water capacity
(UFC).
Primary Containment: The first level of containment,
consisting of the inside portion of that container which comes
into immediate contact on its inner surface with the material
being contained (UFC).
Secondary Containment: Systems must be:
1. Designed, installed, and operated to prevent any migration
of wastes or accumulated liquid out of the system to the soil,
ground water, or surface water at any time during the use of the
tank system; and
2. Capable of detecting and collecting releases and accumulated
liquids until the collected material is removed (EPA 40 CFR Part
264.193(b)).
or
That level of containment that is external to and separate from
primary containment (UFC).
Stationary Tank: Packaging designed primarily
for stationary installations not intended for loading, unloading
or attachment to a transport vehicle as part of its normal operation
in the process of use. It does not include cylinders having less
than 1000 pounds water capacity (UFC).
Sump: Any pit or reservoir that meets the definition
of a tank and those troughs/trenches connected to it that serve
to collect hazardous waste for transport to hazardous waste storage,
treatment, or disposal facilities; except that as used in the
landfill, surface impoundment, and waste pile rules, "sump"
means any lined pit or reservoir that serves to collect liquids
drained from a leachate collection and removal system or leak
detection system for subsequent removal from the system (EPA).
Tank: A stationary device designed to contain
an accumulation of hazardous waste which is constructed primarily
of non-earthen materials (e.g., wood, concrete, steel, plastic)
that provide structural support (EPA).
or
A vessel containing more than 60 gallons (UFC).
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