EPA, UFC and RCRA Secondary Containment requirements come from a variety of sources, with the main source being the Environmental Protection Agency.
Title 40 of the Code of Federal Regulations (CFR) part 264
2006 Uniform Fire Code (UFC) in standard 18.104.22.168.3
2006 International Fire Code (IFC) in 2704.2
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
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 the 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.
The EPA does not bring secondary containment requirements into context when addressing portable containers. Instead, they refer only to containment under 40 CFR part 264.175(b). It says that a containment system must be designed and operated as follows:
Under 40 CFR part 264.175(c), the EPA also addresses storage areas that store containers holding only wastes that do not contain free liquids and sets the following provisions for the storage areas:
There are certain wastes for which a storage area alone will not suffice. These waste streams are listed under 40 CFR part 264.175(d) and require a containment system in addition to the storage area.
EPA Requirements for Tank Systems
The EPA specifies under 40 CFR part 264.193(b) that secondary containment systems are required to prevent any migration of wastes to soil, ground water or surface water during the use of the tank system. Within this citation, minimum requirements of how the system must be constructed are listed in detail in paragraph (c):
Along with the above requirements, a provision has been made that requires that one or more of the following devices also be implemented:
These four devices need to meet rather stringent specifications. As an example, an external liner must be:
UFC/IFC Requirements for Secondary Containment
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 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:
UFC/IFC Requirements for Indoor Storage Areas
The UFC and IFC differs 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.
IFC Requirements for Outdoor Storage Areas
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.
UFC/IFC Requirements for Drainage
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.
UFC/IFC Requirements for Monitoring
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 provide if subject to water intrusion. Monitoring devices shall be connected to an approved visual or audible alarm.
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.
Regional EPA Offices
|Region 1:||Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont
General Information Hotline: 888-372-7341
Waste Management Division: 617-573-5700
|Region 2:||New Jersey, New York, Puerto Rico, U.S. Virgin Islands
Environmental Services Division: 212-637-3660
Hazardous Waste Compliance: 212-264-8356 or 212-264-0504
|Region 3:||Delaware, District of Columbia, Maryland, Pennsylvania, Virginia, West Virginia
Environmental Services Division: 215-814-3215
Hazardous Waste Management Division: 215-814-3110
|Region 4:||Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee
Environmental Accountability Division: 404-562-9655
Waste Management Division: 404-562-8651
|Region 5:||Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin
General Information Hotline: 800-621-8431
Waste Management Division: 312-886-6112
|Region 6:||Arkansas, Louisiana, New Mexico, Oklahoma, Texas
General Information Hotline: 800-887-6063
|Region 7:||Iowa, Kansas, Missouri, Nebraska
General Information Hotline: 800-223-0425
|Region 8:||Colorado, Montana, North Dakota, South Dakota, Utah, Wyoming
General Information Hotline: 800-227-8917
|Region 9:||Arizona, American Samoa, California, Guam, Hawaii, Nevada
Environmental Information Center: 415-947-8000
|Region 10:||Alaska, Idaho, Oregon, Washington
Environmental Services Division: 206-553-0521
Waste Management Branch: 206-553-6640
The following 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. Any vessel of 60 gallons (227L) or less capacity used for transporting or storing hazardous materials.
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.
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 of the presence of a release of hazardous waste into the secondary containment structure.
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.
Portable tank: 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, mounting or accessories to facilitate handling or 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.
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.
Secondary containment: That level of containment that is external to and separate from the primary containment.
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 lb. water capacity.
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.
Note: The information contained in this publication is intended for general information purposes only. This publication is not a substitute for review of the applicable government regulations and standards, and should not be construed as legal advice or opinion. Readers with specific questions should refer to the cited regulation or consult with an attorney.
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