Secondary Containment Program Template
Secondary Containment Program
Table of Contents
I.
II.
III.
OBJECTIVE AND SCOPE
DEFINITIONS
RESPONSIBILITIES
A.
Secondary Containment Program Manager
B.
Supervisors
C.
Employees
D.
Management
E.
Third Party Contractors
IV.
PROCEDURE
A.
Secondary Containment Applicability
B.
Design and Construction of Secondary Containment
C.
Containment Drainage
D.
Long Term Maintenance
E.
Protection and Security
F.
Ventilation and Lighting
G.
Loading and Unloading
H.
Cleaning up a Release
V.
TRAINING
A.
Employee Training
B.
Training Records
VI.
REFERENCES
A.
Business Unit Policy References
B.
Site Policy References
C.
Regulatory and Standard Industry References
VII. APPENDICES
Appendix A - Sample Calculation of Secondary Containment Capacity
Appendix B - Secondary Containment Water Drainage Log
Appendix C - Spill Control System Inspection Checklist
VIII. DOCUMENT CONTROL
Secondary Containment Program
for
[Company Name/Location]
I.
OBJECTIVE AND SCOPE
The purpose of the [Company Name/Location] Secondary Containment Program
(SCP) is to contain chemical releases and protect the facility, public health and the
environment by preventing chemicals from entering the soil, surface water and
groundwater. Secondary containments control or minimize chemical releases
from leaving the facility boundaries and provide additional time to properly clean
up the releases. Benefits of secondary containment also include reduced costs of
cleaning up releases, potential for environmental damage or injury to health and
safety of personnel, and liabilities in the event of a chemical release.
Secondary containment may be required by multiple governmental regulations
depending on the type and quantity of hazardous substances stored or handled. It
may also be a requirement under local regulations, which are usually incorporated
into zoning, building, fire protection, or other regulations.
The procedures described in this Program are intended to facilitate compliance
with applicable governmental regulations. If there is a conflict between this
program and a governmental regulation, the governmental regulation will apply
and this Program will be modified. However, all other requirements in this
Program will apply even if they are more stringent than governmental regulations.
II.
DEFINITIONS
Container - Any portable device in which a material is stored, transported,
treated, disposed of, or otherwise handled.
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 - A means of surrounding one or more primary storage
containers or articles to collect any hazardous material release in the event of loss
of integrity or failure of the primary container.
Tank - A stationary device, designed to contain a regulated material, which is
constructed primarily of non-earthen materials (e.g., wood, concrete, steel, plastic
which provide structural integrity and support).
Date: May 18, 2009
Version: Final Version 1.0
Next Review: May 18, 2010
Authorized by: Regulatory Affairs Counsel
Uncontrolled when printed
1
Tank system - A regulated material storage or treatment tank and its associated
ancillary equipment and containment system.
Ancillary equipment - Any device including, but not limited to, such devices as
piping, fittings, flanges valves, and pumps, that is used to distribute, meter or
control the flow of regulated material from its point of generation to a storage
tank(s), between tanks to a point of use on-site, or to a point of shipment for use
off-site.
III.
RESPONSIBILITIES
A.
Secondary Containment Program Manager
[Responsible Person] shall manage the SCP for [Company Name/Location.] The
Program Manager is responsible for implementing all aspects of the program and
shall:
1. Identify areas in the facility required to have secondary containment.
2. Determine secondary containment requirements under applicable
governmental regulations including local fire and building codes.
3. Identify local jurisdictions responsible for oversight of secondary
containment requirements.
4. Ensure proper maintenance of secondary containment monitoring and
drainage systems.
5. Ensure appropriate employees are trained in their responsibilities under
SCP.
6. Maintain records of all documents related to SCP requirements.
B.
Supervisors
Supervisors shall work with the Program Manager to ensure that:
1. The requirements of this program are implemented in their respective
departments.
2. Secondary containment areas are inspected and maintained.
3. Releases are cleaned up immediately and corrective actions are taken to
prevent such occurrences, in accordance with the facility Spill Response
Plan.
C.
Employees
Employees in each department will be responsible for complying with these SCP
requirements.
Date: May 18, 2009
Version: Final Version 1.0
Next Review: May 18, 2010
Authorized by: Regulatory Affairs Counsel
Uncontrolled when printed
2
D.
Management
[Company Name/Location] will provide all necessary resources and training to
comply with this SCP. Facility Manager will ensure proper adherence to this
Program through regular review.
E.
Third Party Contractors
Third Party Contractors are responsible for complying with this Program, and
shall insure that their employees have the necessary training to comply with this
Program.
IV.
PROCEDURE
A.
Secondary Containment Applicability
[Company Name/Location] will provide secondary containment in areas of the
facility where regulated materials are handled or stored in containers including
tanks, totes, drums, or small pails including:
1.
2.
3.
4.
5.
Flammable and combustible materials
Hazardous substances
Hazardous waste
Materials included on governmental lists of regulated materials
Oil and other petroleum-based products or waste
Unless otherwise required, containers less than 5-gallon in capacity are not
required to have secondary containment.
B.
Design and Construction of Secondary Containment
Secondary containment systems will be designed, installed, and operated to
prevent any migration of accumulated liquid out of the secondary containment. It
must also be capable of holding liquids until the collected materials are removed.
1. Containment Volume The containment will be constructed such that the
containment area is large enough to meet the regulatory volumes specified
for the type of material stored.
a. The effective capacity of secondary containment for a single container
will be a minimum of 110% of the primary container.
b. Effective capacity of secondary containment for multiple containers
will be a minimum of 110% of the largest container's volume or 10%
of the aggregate volumes of all containers, whichever is greater.
c. All secondary containment systems exposed to rainfall must be able to
hold 4.5 inches of rainfall in addition to the required secondary
containment volume.
d. All secondary containment systems exposed to fire sprinkler discharge
must be able to hold the discharge from all sprinkler heads over the
Date: May 18, 2009
Version: Final Version 1.0
Next Review: May 18, 2010
Authorized by: Regulatory Affairs Counsel
Uncontrolled when printed
3
secondary containment system for 20 minutes in addition to the
required secondary containment volume.
Appendix A contains a sample of calculation of secondary containment
capacity.
2. Structural Strength - The base and walls of the system will be strong
enough to support the weight of all the materials and equipment that will
enter it. Materials designed and approved to withstand weathering effects
and wear and tear and be able to withstand a full hydrostatic head will be
used for construction.
3. Impermeability and Compatibility – The system will be constructed so that
it is liquid tight. All joints and cracks will be sealed. The surface of the
system must be resistant to penetration by the materials stored there and be
compatible with them. The structure must be made of noncombustible
materials if flammable or combustible materials are stored in the area.
Incompatible materials will be accumulated in separate secondary
containment areas.
4. Integrity – The secondary containment system will be designed so that any
leaking materials cannot be released into the environment or into sewer
systems. Side walls and the base will not be penetrated by drains, piping
channels, or openings of any kind where liquids may escape. If drains or
openings do exist, any discharges into them will be manually controlled.
C.
Containment Drainage
Uncontrolled drainage from a secondary containment system is prohibited.
Accumulated storm water or sprinkler flow water may only be released from a
secondary containment system after it has been determined to be uncontaminated
following the method below.
1. Drain valves for storage tank secondary containment systems, if provided,
must be kept closed and locked at all times, except when draining
accumulated storm water.
2. A visual check of accumulated storm water must be performed and
documented prior to draining.
3. For tanker unloading areas, available drains for secondary containment
must be closed whenever a tanker is present within the containment area.
Date: May 18, 2009
Version: Final Version 1.0
Next Review: May 18, 2010
Authorized by: Regulatory Affairs Counsel
Uncontrolled when printed
4
Appendix B is a sample Secondary Containment/Water Drainage Log for
use during containment drainage.
D.
Maintenance
Inspections of the secondary containment systems shall be conducted monthly and
documented. Any necessary repairs will be scheduled and performed and records
will be kept. Appendix C is a list of items to check during a secondary
containment system inspection.
E.
Protection and Security
Access to the containment system will be restricted to protect against tampering
or trespassers. Isolation distance requirements from property lines and streets,
alleys, or other public ways and sources of ignition are as follows: [Fill in]
All applicable storage requirements for flammable and combustible liquids
storage are [attached] hereto and will be met including aisle widths, spacing
distances between storage tanks, and stacking limit of the containers.
F.
Ventilation and Lighting
Adequate ventilation to avoid the buildup of explosive or flammable fumes and to
protect workers entering the area will be provided. This will be accomplished by
natural or mechanical ventilation with discharge or exhaust to a safe location
outside the building. Without adequate ventilation, a secondary containment area
could become a confined space. Secondary containment areas will be properly
lighted for safety and to deter vandalism.
G.
Loading and Unloading
Materials will be handled safely when being transferred in and out of the
containment system and in the dock area. These areas must have safe approaches
and adequate space for vehicle access and maneuvering room. Avoid excessive
sill height which would hinder movement. Any spilled material in a dock area
must be prohibited from entering public sewers, drainage systems, or waterways.
H.
Cleaning up a Release
Any releases into the secondary containment will be cleaned up in accordance
with the facility Spill Response Plan and the Emergency Action Plan. If the
precipitation and/or other materials collected is determined to be a hazardous
waste it will be managed according to hazardous waste management
requirements. If the fluid is not a hazardous waste, it may be discharged to a
municipal wastewater sewer system only if properly authorized by governmental
requirements.
Date: May 18, 2009
Version: Final Version 1.0
Next Review: May 18, 2010
Authorized by: Regulatory Affairs Counsel
Uncontrolled when printed
5
V.
TRAINING
A.
Employee Training
All appropriate employees will be trained in the requirements of this SCP.
B.
Training Records
All training pertaining to this program shall be maintained in accordance with the
facility Records Retention Plan.
VI.
REFERENCES
A.
B.
C.
VII.
Business Unit Policy references
Site Policy references
Regulatory and Standard Industry references
1. Uniform Fire Code
2. OSHA (General Industry) where spill containment is specified 1910.10,
Flammable and Combustible Liquids 1910.106(d)(6)(iii),
1910.106(e)(2)(iii), 1910.106(f)(7)
APPENDICES
Appendix A
Appendix B
Appendix C
Sample Calculation of Secondary Containment Capacity
Secondary Containment Water Drainage Log
Spill Control System Inspection Checklist
VIII. DOCUMENT CONTROL
This SCP shall be reviewed annually, or as needed if changes to the facility
operations, processes, or personnel are made, by [Responsible Person]. Following
each change, [Responsible Person] shall document the change and inform all
affected by the changes.
Document History:
Procedure
version
Date
Approved
Approved by
Date: May 18, 2009
Version: Final Version 1.0
Next Review: May 18, 2010
Reason for
Change
Authorized by: Regulatory Affairs Counsel
Uncontrolled when printed
6
APPENDIX A
SAMPLE CALCULATION OF SECONDARY CONTAINMENT CAPACITY
The maximum 24-hour rainfall recorded in the last 25 years at this location is 4.5
inches.
Bulk Storage Dike
Capacity of Tanks within the diked area:
Tank 1 = 20,000 gallons (saddle-mounted tank, no significant displacement)
Tank 2 = 20,000 gallons (saddle-mounted tank, no significant displacement)
Tank 3 = 20,000 gallons (need to account for tank displacement)
Tank 7 = 10,000 gallons (on legs, no significant displacement)
Dike Dimensions:
Dike footprint = 50 feet x 60 feet
Dike height = 18 inches = 1.5 feet
Dike volume = 50' x 60' x 1.5' = 4,500 ft3 x 7.48 gal/ft3 = 33,660 gallons
Displacement Volume of Tank 3:
Tank diameter = 10 feet
3.1415 * (10 ft)2 / 4 * 1.5' = 117.8 ft3 x 7.48 gal/ft3 = 882 gallons
Available Freeboard for Precipitation:
33,660 gallons - (20,000 gallons + 882 gallons) = 12,778 gallons
12,778 gallons / 7.48 gallons/ft3 / (50 ft x 60 ft) = 0.57 ft = 6.83 inches
The dike therefore provides sufficient storage capacity for the largest bulk storage
container within the diked area, tank displacement, and precipitation. The
containment capacity is equivalent to 164% of the capacity of the largest container
(33,660 gallons - 882 gallons)/20,000 gallons).
APPENDIX B
SECONDARY CONTAINMENT/WATER DRAINAGE LOG
This log is to be completed whenever water is discharged from a containment area.
Only clean water may be discharged from the containment area. The manual valve
must remain closed except when draining water from the containment area. The valve
must be closed promptly after the containment area is drained.
Containment
Area #
Date
Visible Oil
Sheen?*
Yes/No
Time
Valve
Opened
Time
Valve
Closed
Signature
*Note: Water which has a sheen must not be discharged from the containment area.
Contaminated water must be treated so that it does not have a sheen prior to being
discharged from the containment area, or transported off site by a licensed hazardous
waste or waste oil contractor for disposal.
APPENDIX C
SPILL CONTROL SYSTEM INSPECTION CHECKLIST
SPILL CONTROL SYSTEM Inspection checklist
This program deals with chemical and waste container and tank storage
areas. The questions in this program element pertain to the responsibility
and management practices for the prevention, detection, and containment
of spills or leakage from tanks and containers.
1
2
3
4
5
6
7
Are outdoor spill control structures sized for the larger of the following:
1.5X the volume of the largest individual container or tank, or
For hazardous waste, 1.0X the largest single container or tank plus (+) the
amount predicted for 24 hours of rainfall from the site's "25-year storm", or
2% of the volume of all containers served by the structure?
(For this program, a "tank" is defined as a container of greater than 55
gallons (208 liters). Double-walled, self-contained storage tanks do not
require additional spill control protection, provided transfer operations use
dripless connectors, valving and/or pricing which can preclude spillage.)
Are indoor spill control structures sized for the larger of the following:
1.0X the volume of the largest individual tank, or
10% of the combined volume of all tanks served by the structure, or
2% of the combined volume of all containers served by the structure?
(Indoor spill control structures are those protected from direct rainfall or
run-on flow.)
8
Are all spill control structures free of cracks, unsealed joints or otherwise
impermeable to leakage or migration to spills to the ground or underlying
foundation?
9
For spill control structures which may be shared (via piping) by tanks or
containers holding incompatible material, are there written procedures to
ensure those materials are never commingled within the structure?
10
Do all tanks have readily accessible means for determining liquid level?
11
Do hazardous waste tanks, or unattended containers collecting liquid
waste, have a means to prevent overfilling?
12
For tanks installed in below-grade, open-top, or enclosed spill controls
structures, are leaks easily detected?
13
14
15
16
Are the following labeling requirements met:
For hazardous waste tanks, labeled for content and capacity?
For any vessel or structure holding hazardous waste, labeled either as
"hazardous waste", or with the specific name of the waste substance?
Are all labels directly affixed to the container or conveyance which holds or
transports the material?
Do labels on piping indicate the direction of flow?
Are all tanks and spill control facilities inspected for leaks or releases,
Yes
No
NA
structural damage and/or deterioration as follows:
17
18
19
Hazardous waste tanks and piping on a daily basis?
If not spill controlled, piping on outdoor pipe-racks which do not contain
hazardous waste, on a daily basis.
Containers of oil, fuel and hazardous materials on a weekly basis.
20
Are spill control structures which collect rainwater emptied within 24 hours
(allowing for intermittent rainstorms?)
21
Are records of spill control inspections, integrity testing, rainwater or
residue analysis, and maintenance records kept on-site for at least three
years?