In our latest installment of Ask the Expert, brought to you by the team of industry experts at EHS Hero®, we look at a recent question from a subscriber asking about secondary containment of hazardous liquid waste. See what the experts had to say.
Q: Is secondary containment of hazardous liquid waste recommended or required for satellite accumulation areas?
There is no secondary containment requirement for either large quantity generators (LQG) or small quantity generators (SQG) in satellite accumulation areas (SAA). Some states, however, (Maryland being one example at COMAR 26.13.03.05E(1)(d)) require hazardous LQGs to have a secondary containment system for containers used to accumulate hazardous waste in central accumulation areas.
The SAA rules do require that a container holding a hazardous waste that is incompatible with any waste or other materials accumulated nearby in other containers be separated from the other materials or protected from them by any practical means. Under these circumstances, secondary containment for containers of incompatible waste could be an effective and “practical means” to comply with this separation requirement.
While the legal editors of Enviro.blr.com do not make recommendations as to whether those who accumulate or store hazardous waste in containers should use secondary containment when it is not a regulatory requirement, we recognize that some hazardous waste managers consider it a best management practice to use secondary containment as a backup system should a container fail without warning.