Do Portable Containers Need Secondary Containment?
It's quite possible, yes! Here are some commonly applicable containment regulations:
1. SPCC (Spill Prevention, Control, and Countermeasures)
If your facility has the capacity to store more than 1,320 gallons of oil, it is regulated under EPA's SPCC regulations and all oil containers greater than 55 gallons need to be within sized secondary containment. The volume of this secondary containment should be the capacity of the largest container, plus a 25-year, 24-hour storm event. This secondary containment must also be sufficiently impervious. (See 40 CFR 112.8(c)(11))
2. Hazardous Waste Regulations
If your site generates more than 2,200 pounds of hazardous waste per month, it is considered a large quantity generator. As a large quantity generator, all hazardous waste containers need to be covered and within impermeable containment that is at least 10% of the total volume of the containers or 100% of the volume of the largest container, whichever is greater. (See 40 CFR 264.175(b))
3. Stormwater Regulations
If activities at your site fall under a regulated Standard Industrial Classification (SIC) code, you must either apply for a No Exposure Certification or coverage under a Storm Water Permit. If you need to pursue a No Exposure Certification, providing secondary containment and a cover for portable containers will be necessary.
If you need to apply for a permit, secondary containment for portable containers becomes an important best management practice.
4. Fire Code
Both the International Fire Code and Uniform Fire Code require that secondary containment be provided for certain liquids (including corrosive, flammable, toxic, and combustible liquids) if an individual container exceeds 55 gallons or the aggregate capacity of multiple containers exceeds 1,000 gallons. Generally, these containments shall be designed to contain the largest container plus 20 minutes of fire-extinguishing water if indoors or rainfall from a 24-hour, 25-year storm event if outdoors.
How Much Precipitation Is in a 25-Year, 24-Hour Storm Event?
It depends on your location. The easiest way to determine the inches of precipitation associated with your location is to consult NOAA's website.
1. Determine precipitation in inches for a 25-year, 24-hour storm event from NOAA
2. Convert to feet: inches / 12 = feet
3. Multiply by containment area: feet x square footage = cubic feet
4. Convert to gallons: cubic feet x 7.4805 = gallons
What Does EPA Mean by "Sufficiently Impervious"?
The Environmental Protection Agency (EPA) does not offer explicit criteria, such as permeability or hydraulic conductivity, to determine the adequacy of containment in terms of being "sufficiently impervious." Instead, the EPA's SPCC Guidance for Regional Inspectors, specifically Chapter 4, outlines that secondary containment structures like dikes, berms, and retaining walls can be deemed sufficiently impervious if they enable timely cleanup to prevent discharges into navigable waters or adjoining shorelines.
How Can SPCC Software Help?
EHS software, such as the Ecesis SPCC Software, will calculate tank volumes and containment capacities automatically. It also enables quick updating and generation of SPCC Plan components (such as tank inventories), tracks integrity testing requirements, and enables SPCC inspections on mobile devices such as phones and tablets through the Ecesis Mobile Application.
