EPA Container Storage Regulation

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A. SUMMARY:
  • The regulation addresses containers (primarily tanks and drums) that contain free liquids that are considered to be hazardous.
  • Secondary containment units are required that underlay the containers and are free of cracks or gaps; they must be “sufficiently impervious to contain leaks, spills and accumulated precipitation”.
  • The base of the containment unit must be sloped or designed to drain and remove liquids that result from leaks, spills or precipitation, unless the containers are elevated or otherwise protected from contact with accumulated liquids.
  • The containment unit must have sufficient capacity to contain 10% of the total volume of all containers in the grouping, OR the volume of the single largest container in the grouping, whichever is greater.

B. WHO MUST COMPLY?
  • The federal EPA regulations require Treatment, Storage and Disposal (TSD) facilities to comply with these standards and recommend that any company that stores containers of oil and hazardous wastes follow the regulations as well.
  • Many state and local levels enforce these regulations on a wide range of facilities and industries that store hazardous materials and/or wastes in drums and tanks. In many cases, containers stored both indoors and outdoors are covered by the regulation.

C. WHAT ACTIONS ARE NECESSARY FOR COMPLIANCE?
  • Each facility should survey its entire site, both indoors and outdoors. An onsite environmental manager or environmental consultant is typically qualified to perform the survey.
  • All containers used to store hazardous liquids should be reviewed to determine if sufficient containment measures have been taken.
  • A containment system that has been designed to meet the criteria outlined in 40 CFR 264.175 should be purchased or constructed for all containers that are not in compliance.

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