If you store IBC tanks containing hazardous materials, petroleum products, or chemicals that could contaminate soil or water, secondary containment is not optional — it is a legal requirement. EPA regulations, California state laws, and local ordinances all mandate some form of containment around IBC storage to prevent ground and water contamination from leaks and spills.
What Is Secondary Containment?
Secondary containment is a barrier system that captures leaks, drips, and spills from a primary container (the IBC tank) before they reach the ground, storm drains, or waterways. The concept is simple: if the IBC tank leaks, the secondary containment catches and holds the spilled material until it can be properly cleaned up.
EPA Requirements
The primary federal regulation governing secondary containment is EPA 40 CFR Part 264.175 (for RCRA-regulated facilities) and 40 CFR Part 112 (the SPCC rule, for facilities storing oil and petroleum products).
Key requirements include:
Capacity: The containment system must hold at least 110 percent of the volume of the largest single container in the area, or 10 percent of the total volume of all containers — whichever is greater.
Impermeability: The containment base and walls must be impervious to the stored material for at least 72 hours — long enough for detection and cleanup.
Drainage: The containment area must not have drains that connect to storm sewers or waterways. Accumulated rainwater must be tested before discharge.
Accessibility: Containers must be accessible for inspection and response without entering the containment area.
California-Specific Requirements
California generally follows EPA requirements but adds additional provisions through CalEPA and local Certified Unified Program Agencies (CUPAs). Key California additions include:
- •Aboveground Petroleum Storage Act (APSA): Facilities storing 1,320 gallons or more of petroleum in aboveground containers must file a storage statement and prepare a Spill Prevention Control and Countermeasure (SPCC) plan
- •Hazardous Materials Business Plan (HMBP): Required for any facility handling reportable quantities of hazardous materials, including proper containment documentation
- •Local fire code: Many Bay Area jurisdictions require secondary containment for flammable and combustible liquids stored in IBC tanks, even at quantities below federal thresholds
Practical Containment Solutions
Spill pallets: The simplest solution for individual IBC tanks. A polyethylene spill pallet sits under the IBC tank and provides a built-in sump that captures leaks. Available in single-tank and multi-tank configurations with sump capacities from 66 to 275+ gallons. These are cost-effective, portable, and require no installation.
Containment berms: For larger IBC storage areas, flexible containment berms create a perimeter wall around multiple tanks. Made from PVC-coated fabric or polyurethane, they fold flat for storage and deploy quickly when needed. Available in custom sizes to fit any footprint.
Concrete containment areas: For permanent IBC storage, a poured concrete pad with integral curbing provides the most durable containment. The concrete must be coated with a chemical-resistant sealant appropriate for the stored materials. This is the preferred solution for high-volume, long-term storage operations.
Covered containment: Adding a roof over the containment area prevents rainwater accumulation — a significant practical advantage because accumulated rainwater in an uncovered containment system must be tested for contamination before it can be pumped out, creating an ongoing operational burden.
Compliance Strategy
Start by inventorying everything stored in IBC tanks at your facility and classifying each material. Determine which regulations apply (EPA SPCC, RCRA, CalEPA, local CUPA). Calculate the required containment volume. Select the appropriate containment solution. Document your containment system and include it in your facility emergency response plan. Inspect containment monthly and after any spill or heavy rain event.