Frequent Questions

Do facilities need to provide secondary containment for containers used to manage liquid hazardous waste?

Pursuant to Part 264, Subpart I, an owner/operator of a permitted treatment, storage or disposal facility must provide secondary containment for containers used to manage liquid hazardous waste. Secondary containment is not required at generator or interim status facilities.  Only permitted container storage areas must have a secondary containment system ('264.175(a)).  Secondary containment provides a backup system to prevent a release into the environment should primary containment (i.e., the container) fail.  The containment system should catch leaks, spills, container residues, and precipitation that becomes contaminated.  Secondary containment usually consists of a poured concrete pad or other impervious base with curbing to prevent releases of hazardous waste into the environment and to allow drainage of any accumulated liquid to a sump, tank, or other container (46 FR 2802, 2829; January 12, 1981).

Additional guidance on secondary containment for containers is available in the following documents:

Memo, Heare to Taunton; February 6, 1998 (RCRA Online 14463)
Memo, McAlister to Hopper; June 30, 1995 (RCRA Online 11909)
Monthly Call Center Report Question; June 1988 (RCRA Online 13190)

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