ULTRATECH UNIVERSITY:  Containment Capacity Requirements

 

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Today I'm going to talk about the containment capacities required by the EPA.  It's very important to understand what the requirements are so that you can be sure that you are using the appropriate products and staying in compliance. The main regulation that dictates the requirements is EPA 40 CFR 264.175.  You can find a summary of this on our website or you can find the complete text online on the EPA's website.

The regulation states three requirements for spill containment systems.  The first one is this:

The containment unit must underlie the containers, and must be free of cracks or gaps, and be sufficiently impervious to contain leaks, spills and accumulated precipitation.

Pretty straightforward stuff there.  Doesn't make a whole lot of sense to contain a spill with something that is gonna leak or spill itself. 

The second point is:  The base of the containment unit must be sloped or designed to drain and remove liquids resulting from leaks, spills or precipitation unless the containers are elevated or otherwise protected from contact with accumulated liquids.

Again, pretty straightforward.  You don't want your drums sitting in spilled material.

But the third and final point is the one that I'm going to focus on in this session. It states:

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. 

This one is not as straightforward as the others.  It actually gets misinterpreted quite often.  So let's take a closer look.  

We'll start with a scenario where we need to have spill containment for four 55-gallon drums.  Again the regulation states that whatever we use must have "sufficient capacity to contain 10% of the volume of containers or the volume of the largest container, whichever is greater." A quick calculation tells us that the total of those four 55-gallon drums is 220 gallons.  10% of 220 is 22.  But before we start shopping for a 22-gallon spill pallet, we need to look at the rest of the regulation.  The second part says, "or.. the volume of the largest container… whichever is greater."  In this scenario we have four 55-gallon drums, so the single largest container would be 55-gallons. 55 is greater than 22 so we would need to have a spill containment unit with at least 55 gallons of containment to be in compliance.

For the second scenario, let's try a larger quantity of drums.  Let's try 12. Twelve drums at 55 gallons each, would total 660 gallons.  10% of 660 gallons equals 66 gallons.  The single largest container is 55 gallons.  So in this instance, the requirement to meet the regulations would be 66 gallons since that is the larger number of the two.  

One last scenario and then we'll move on.  Let's say that you've got an IBC or Intermediate Bulk Container that you need spill containment for.  Now, these tanks come in quite a few shapes and sizes but for this example, we'll go with one of these which holds 275 gallons.

It's going to be the only thing on the spill containment unit so the total volume of the containers and the single largest container will be the same:  275 gallons.  10% of 275 is 27.5.  Which is, of course, much less than 275.  So this scenario requires at least 275 gallons to be in compliance.

A few final notes to keep in mind: 

  1. The numbers that are used to calculate the required spill containment capacity is based on the containers' capacity.  In other words, if you are using a 55-gallon drum that never has more than 20 gallons of liquid in it, you are still responsible for containment as if it had 55 gallons in it.
  2. The regulation that we looked at is a federal requirement.  This is the MINIMUM requirement.  State and other local regulators have the authority to enforce more stringent requirements.  In other words, they can require greater containment capacity than what we've reviewed today.  They are not allowed to require less but they can require more.  So it is important that you check with your local authorities to make sure that you are in complete compliance.

Well, I hope that this session proved to be valuable to you and that you now understand what is required by the EPA.

If you have any questions, please feel free to contact us at (904) 288-8195 or via our website at www.spillcontainment.com