If your facility stores hazardous materials in IBC totes, secondary containment is not a suggestion — it is a legal requirement. The EPA's regulations under 40 CFR 264 and 265 require that facilities storing hazardous wastes and materials have secondary containment systems capable of holding the entire volume of the largest container plus sufficient freeboard for precipitation. Violations can result in enforcement actions, fines, and liability for cleanup costs.
What Is Secondary Containment?
Secondary containment is a system designed to catch and contain leaks, spills, or failures from primary containers. For IBC totes, this typically means placing the container within or on top of a containment structure that can hold the full volume of the IBC plus a margin for rainfall. The containment structure must be made from materials that are compatible with the stored chemicals and must be regularly inspected for integrity.
Capacity Requirements
The EPA requires that secondary containment systems hold at least 110 percent of the volume of the largest container within the containment area, or 10 percent of the total volume of all containers in the area, whichever is greater. For a single 275-gallon IBC, the containment system must hold at least 302.5 gallons (275 x 1.1). For outdoor installations, additional capacity for rainfall must be factored in.
- Single IBC (275 gal): Minimum 302.5 gallon containment capacity
- Single IBC (330 gal): Minimum 363 gallon containment capacity
- Multiple IBCs: 10% of total volume or 110% of largest, whichever is greater
- Outdoor installations: Add estimated rainfall volume for the containment area
- Containment must be liquid-tight with no drains to the environment
Types of Secondary Containment
Several types of secondary containment systems are available for IBC totes, ranging from simple spill pallets to engineered containment berms and lined concrete sumps.
- Spill containment pallets: The most common solution for individual IBCs, available in polyethylene or steel
- Containment berms: Flexible, portable berms that create a containment area for multiple containers
- Concrete sumps: Permanent installations with coated or lined interiors for large-scale storage
- Containment walls: Built-up walls around storage areas with sealed floors
- Double-walled IBCs: Specialty containers with built-in secondary containment (expensive but convenient)
Inspection and Maintenance
Secondary containment is only effective if it is maintained. Regular inspections should verify that containment structures are free of cracks, corrosion, or accumulated liquids. Any liquid found in the containment area must be tested to determine if it is rainwater or a leak from the primary container. Rainwater must be removed promptly to maintain containment capacity. Leaked materials must be handled as hazardous waste.
Grand Rapids IBC stocks spill containment pallets and accessories for all standard IBC sizes. We can also advise on containment solutions for your specific facility layout and regulatory requirements. Contact us or visit our products page for current availability and pricing.