Secondary containment requirements are addressed by the Environmental Protection Agency (EPA) through the Resource Conservation and Recovery Act (RCRA) contained in title 40 of the Code of Federal Regulations (CFR) part 264, the 2006 Uniform Fire Code (UFC) in standard 18.104.22.168.3 and in the 2012 International Fire Code (IFC) in 5004.2.
The EPA refers to the need for secondary containment in two different areas: Subpart I, Use and Management of Containers (40 CFR 264.175), which covers portable storage containers, such as 55-gallon drums, for hazardous waste, and the second in Subpart J, Tank Systems (40 CFR 264.193), which covers large stationary containers, such as tank systems, for hazardous waste. Facilities that store hazardous materials may also be required to meet either the UFC or IFC depending on what the locality has adopted.
Throughout this document, the federal secondary containment requirements from the EPA will be listed along with the UFC and IFC standards. If there is any question regarding compliance, consult with a local fire marshal for more information.
Both the UFC and IFC cover secondary containment requirement standards for facilities that store hazardous materials and not just hazardous wastes that are the focus of the EPA standards. The UFC and IFC are very similar, except the IFC goes into more detail in regards to the outdoor design of secondary containment, monitoring and drainage systems. Both state that buildings or portions thereof, used for any of the following shall be provided with secondary containment to prevent the flow of liquids to adjoining areas:
The UFC and IFC differ from the EPA because it states that the secondary containment for indoor storage areas must contain a spill from the largest vessel plus the flow volume of fire protection water calculated to discharge from the fire-extinguishing system over the area in which the storage is located for a period of 20 minutes. It also mentions that incompatible materials shall be separated from each other in secondary containment systems.
The IFC mentions outdoor secondary storage areas that follow the EPA tank system design stating that they shall be designed to contain a spill from the largest individual vessel. If the area is open to rainfall, it shall be capable of containing the volume of a 24-hour rainfall as determined by a 25-year storm. The UFC does not mention outdoor storage areas.
Both the UFC and IFC state that secondary containment shall be achieved by means of drainage control to prevent the discharge of liquids to public waterways, public sewers, or adjoining properties. The building room or area shall contain or drain the hazardous materials and fire protection water through the use of one of the following methods:
The IFC adds to this, stating the slope of floors shall not be less than 1%, drains for indoor storage areas shall be sized to carry the volume of the fire protection water as determined and drains for outdoor storage areas shall be sized to carry the volume of the fire flow and the volume of a 24-hour rainfall as determined by a 25-year storm.
The UFC and IFC state that an approved method shall be provided to detect hazardous materials in the secondary containment system, but the IFC further mentions that a visual inspection is allowable and that detection for water in secondary containment systems must be provided if subject to water intrusion. Monitoring devices shall be connected to an approved visual or audible alarm.
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.
The following are some related terms as defined by the EPA and UFC.
Any portable device, in which a material is stored, transported, treated, disposed of or otherwise handled. Any vessel of 60 gallons (227L) or less capacity used for transporting or storing hazardous materials.
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.
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 above-ground tanks) or consist of an interstitial monitoring device designed to detect continuously and automatically the failure of the primary or secondary containment structure of the presence of a release of hazardous waste into the secondary containment structure.
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.
Any packaging over 60 gallons (227L) capacity and designed primarily to be loaded into, on or temporarily attached to a transport vehicle or ship and equipped with skids, mountings or accessories to facilitate handling of the tank by mechanical means. It does not include any cylinder having less than a 1000 lb. water capacity, cargo tank, tank car tank, or trailers carrying cylinders of over 1000 lb. water capacity.
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.
That level of containment that is external to and separate from the primary containment.
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 lb. water capacity.
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.
U.S. Environmental Protection AgencySpill ContainmentReady BermL-Bracket BermIf you need help with your spill containment requirements or how to choose the right spill berm give us a call 941-739-9486.
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In addition to our proprietary testing procedures. Ready Containment tests all seams according to IAW ASTM D-751 standards.
We are an ISO 9001:2015 certified company in the design and manufacture of flexible liquid/vapor storage tanks, bladders, inflatables, and spill containment products, and while it’s rare that we have to repair our own products, we are occasionally called upon to repair the inferior work of others.