By Mike McSwain
Regulation of containment systems is primarily handled by the Environmental Protection Agency (EPA), which focuses on hazardous waste. The EPA regulates two types of storage systems: Portable storage containers, such as portable tanks and 55-gallon drums; and fixed tank systems.
Tank containment systems are required to have a secondary containment system to provide a critical line of defense in case of a failure of the primary containment unit. Secondary containment must be treated with nonporous coatings—often 1/8″ to 2″ thick.
Facilities that store or process hazardous waste aren’t the only ones bound by containment regulations; the 2006 Uniform Fire Code (UFC) and the 2006 International Fire Code (IFC) govern the storage of hazardous materials, not just hazardous waste.
Since the goal of material containment systems is to protect human health and the environment due to leakage, routine inspections of these systems are essential.
Three Reasons to Perform Secondary Containment Inspections
Physical inspections are a crucial tool to maintain containment integrity. Inspections can detect existing leaks or identify problem areas that may lead to hazardous material releases if not repaired. Spotting trouble areas early is a key reason to inspect containment systems on a routine schedule.
Even the highest quality nonporous coatings break down. Spills, which can happen when hazardous materials are transferred into or out of containment units, are the most common cause of coating breakdown. Environmental factors can also cause coatings to breakdown—even for interior units. Temperature, moisture levels, oxidizing agency, and other factors contribute to the breakdown of industrial coatings and the corrosion of tank systems.
Spotting damage due to environmental factors or spills early may provide an opportunity to take action and prevent more significant (and more expensive) damage. Upon the initial identification of damage or coating break down, you should contact a licensed and NACE Certified coatings contractor.
Regulatory compliance is another reason to inspect hazardous material tanks. The EPA requires facilities that process, store, or transport hazardous materials to perform regular inspections of containment units. These self-inspection reports must be presented to EPA evaluators as part of agency inspections.
In addition to facility-conducted inspections, EPA inspectors will also evaluate your containment systems. An EPA inspector evaluates whether a secondary containment system is adequate for the facility and whether it is properly maintained to contain discharges. The EPA evaluator may review inspection reports and maintenance records.
Depending on the type of facility and the material(s) in question, an EPA inspector may combine visual inspection with other testing techniques, as well, such as hydrostatic testing, radiographic testing, or ultrasonic testing.
By regularly inspecting your containment systems, you reduce your risk of a failed EPA inspection, which can lead to fines or a shutdown of your operations.
What a Secondary Containment Inspection Should Look For
Chipped or peeling coatings can indicate a tank that is starting to fail. A single crack can cause an entire tank to fail, so take extra care to look for cracked coatings. Small cracks can sometimes be filled if they’re caught early, but left untreated, a small crack will grow larger with exposure to rain or other moisture.
Finding cracks in industrial coatings can be difficult due to the thickness of those applications; detecting cracks requires close visual inspection. Small cracks—which can be easy to overlook—can indicate the coating is starting to break down, while large cracks may indicate a containment breech.
When inspecting coatings, pay extra attention to connect/disconnect points and floor-to-wall joints. Connection points where materials are loaded or unloaded are especially vulnerable to spills that can degrade protective coatings. Floor-to-wall joints are especially vulnerable to chemical run-off and are common trouble areas.
During inspection, special care should be paid to the types of materials in the inspected container. Material Safety Data Sheets should be referenced to understand the required level of secondary containment necessary as well as the coatings required to maintain EPA compliance. For any questions regarding coatings requirements consult with a coatings contractor that specializes in secondary containment and spill prevention.
Avoid Costly Damage and Fines: Set Up a Schedule for Containment Unit Inspections
While containment requirements vary based on the materials you store, failure to maintain containment system integrity can lead to costly fines and repairs. By inspecting primary and secondary containment systems regularly—with particular focus on the coatings of these systems—you may be able to catch small problems before they grow into expensive breaches.
McSwain is a NACE Certified Inspector with A&K Painting Company. Mike has 18 years of experience in industrial coatings, specifically facility maintenance and renovations.
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