Secondary containment, a physical barrier designed to capture liquid released from a primary container, is one of the most commonly misunderstood obligations in industrial and agricultural liquid storage. Many operators believe it applies only to petroleum tanks or hazardous waste facilities. In reality, a broader set of operations storing liquids in IBC totes may need containment under federal EPA rules and state environmental regulations. Getting this wrong exposes a business to penalties and, more importantly, to real environmental and liability risk.
This article is general education, not legal advice. Check current regulations and consult your state environmental agency or a qualified professional about your situation.
Which Regulations May Apply to You?
Several frameworks can govern secondary containment for liquid storage, and your operation may fall under one, several, or none of them:
- —Hazardous waste rules: Facilities that generate, store, or treat hazardous waste under the federal Resource Conservation and Recovery Act generally face container storage and containment requirements.
- —EPA Spill Prevention, Control, and Countermeasure (SPCC) rule: Applies to certain facilities with aboveground oil storage above a set capacity threshold that could reasonably be expected to discharge oil to navigable waters. This is where many agricultural and industrial IBC users encounter containment requirements. Check the current thresholds.
- —State and local rules: Kansas and local authorities may have storage and spill-prevention rules that go beyond federal minimums. The Kansas Department of Health and Environment is the natural starting point for questions.
Sizing: The 110% Rule
A widely used sizing standard for oil storage secondary containment is often called the "110% rule": the containment should be able to hold at least 110% of the capacity of the largest single container within the containment area. This is a product-sizing convention, and the exact requirement depends on which rules apply to you, so check current regulations.
For example, if you store four 330-gallon IBCs in a single containment area, the largest single container holds 330 gallons, so containment sized to the 110% rule must hold at least 363 gallons. Under this approach the volumes of the other three totes do not need to be added, only 110% of the largest single vessel.
That assumes your layout is designed so that a failure of one container cannot cascade into others. If one failure could breach several totes at once, a regulator or engineer may want containment sized for more. Consult a qualified professional if you are unsure. Also remember that rainfall can use up containment capacity in an open outdoor area.
Construction Materials
Secondary containment must be built so that a discharge from the primary container does not escape before cleanup occurs. The material must be compatible with the stored product and able to resist the chemical, thermal, and physical stresses it may meet.
- —Concrete: The most common material for permanent containment berms. It should be sealed or coated with a chemical-resistant sealant if storing acids, caustics, or solvents, because bare concrete is porous and absorbs petroleum products over time.
- —HDPE or other synthetic liners: Used for earth-berm containment areas. Thicker liners generally last longer. Inspect them regularly and replace them when breached or degraded.
- —Steel: Galvanized or coated steel containment pans suit petroleum products but corrode quickly with chlorinated solvents or acids. Verify chemical compatibility before choosing steel.
- —Portable polyethylene containment pallets: Molded containment pallets sized for one or two IBCs are widely available and are a practical solution for smaller operations and temporary storage. Check the rated sump capacity against the tote you plan to put on it.
Indoor vs Outdoor Containment
Indoor containment avoids rainwater accumulation, a significant operational issue outdoors. Open outdoor containment must be drained after rain, and the collected water may need to be checked and properly disposed of if it could be contaminated. That creates ongoing work.
For outdoor tote storage, covered containment (a roof over the berm or pad) is strongly preferred. A roof eliminates precipitation management, reduces UV exposure for the totes, and simplifies inspection. The roof does not compromise containment as long as the walls and floor are properly sealed.
Portable IBC Containment Options
| Type | Typical Setup | Best Use |
|---|---|---|
| Single-IBC polyethylene pallet | One tote on a molded sump | Indoor, lower-risk products |
| Double-IBC polyethylene pallet | Two totes on a shared sump | Indoor, grouped tote storage |
| Steel containment pallet | Welded steel sump with grating | Petroleum products, outdoor |
| Collapsible berm system | Flexible walls around a liner | Temporary or field deployments |
Pricing for containment products is by quote from suppliers.
Inspection and Documentation
Facilities covered by spill-prevention rules generally need to inspect storage areas at regular intervals and keep written records. Many operators do a quick weekly visual check plus a more detailed periodic inspection on a standard form. Check current regulations for the required frequency and record retention in your case.
Key checkpoints for tote containment include the integrity of walls and floor (cracks, spalls, liner breaches), accumulated liquid in the containment area (rainwater or leakage?), the condition of drain valves or pumps (closed and secured except during controlled drainage), the condition of the tote valves and fittings (drips and weeps), and vegetation growing into earthen berms, where roots can breach liners.
Common Problems Found During Inspections
- —Insufficient containment volume. Many facilities calculate from nominal container capacity rather than actual maximum fill capacity, which leads to undersized containment.
- —Drain valves left open. An open valve lets spilled product bypass containment entirely. Keep drains closed and locked except during controlled drainage.
- —Incompatible containment material, such as unsealed concrete or steel used with corrosive products.
- —No inspection records. An inspection that is not documented is hard to prove happened.
- —Written plans not updated after the storage layout changes, for example after adding totes to an area the plan does not cover.
Is a Spill Prevention Plan Required?
A facility may need a written spill prevention plan if its aboveground oil storage exceeds a federal capacity threshold and there is a reasonable possibility of discharge to navigable waters or adjoining shorelines. A group of totes holding petroleum-based products near a drainage ditch that flows to a creek is the kind of situation where this question comes up. Smaller facilities may qualify for simplified plan options. The thresholds and qualifying criteria change, so check current EPA rules and talk to a qualified professional.
Investing modestly in proper containment up front is almost always cheaper than dealing with a spill after the fact, when you add up cleanup, lost product, regulatory attention, and liability. A well-built containment pad sized to the 110% rule for your tote storage area is a sensible baseline for most users.
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