Control Chemical Spills with Secondary Containment

Under the Resource Conservation and Recovery Act (RCRA), the U.S. Environmental
Protection Agency (EPA) is authorized to require secondary containment systems for
aboveground storage systems (ASTs) containing chemicals used in water and wastewater
treatment. According to 40 Code of Federal Regulations (CFR) Protection of the Environment
part 264.193(b), "Secondary containment systems must be designed, installed and operated
to prevent any migration of wastes or accumulated liquid out of the system to the soil,
ground water, or surface water at any time during the use of the tank system""

The federal regulation

further states that, "Secondary containment systems must be at a minimum constructed of
or lined with materials that are compatible with the wastes to be placed in the tank system
and must have sufficient strength and thickness to prevent failure owing to pressure
gradients (including static head and external hydrological forces), physical contact with the
waste to which it is exposed, climatic conditions, and the stress of daily operation (including
the stresses from nearby vehicular traffic)."
A variety of chemicals are used in drinking-water treatment for coagulation and flocculation,
pH adjustment, corrosion control, sequestering, disinfection and oxidation, fluoridation,
defluoridation, softening, taste and odor control, and as dechlorinators and antioxidants.
Chemicals are used in wastewater treatment for coagulation, precipitation, oxidation and
advanced oxidation, ion exchange, and neutralization and stabilization, which can be applied
to wastewater during cleaning.
Tnemec offers a line of chemical-resistant, fiberglass mat reinforced vinyl ester and 100
percent solids epoxy linings in 65 and 125 mils dry film thickness (DFT) for secondary
containment systems in water and wastewater environments. "These are thick, monolithic,
fiberglass reinforced lining systems designed to contain chemical spillage for up to 72
hours," according to Vaughn O'Dea, Director of sales, Tnemec Water and Wastewater
Treatment. EPA regulations require spillage removal within 48 hours or in as timely manner
as possible.
In addition to protecting against harsh chemicals, ChemBloc linings resist thermal cycling,
impact and abrasion, O'Dea noted. Specific products include Series 237SC ChemBloc, a
modified amine epoxy; Series 239SC ChemBloc, a modified novolac amine epoxy; and Series
252SC ChemBloc, a novolac vinyl ester. Each lining is available in two-component
containment kits, which are easily mixed and roller-applied for fiberglass reinforced mat
systems that specify 65 mil thickness. The linings are also available in three-component
mortar containment kits that include a Part C (aggregate) for trowel-applied
mortar/fiberglass reinforced applications requiring 125 mils thickness. "The fiberglass
reinforced mortar is typically used for applications where thermal shock or more aggressive
chemicals are considerations," O'Dea shared.
Specifications for secondary containment systems linings usually include the use of primers
or resurfacers to reduce outgassing, which is caused by voids and bugholes in both new and
repaired concrete secondary containment systems. Series 201 Epoxoprime, a modified
amine epoxy, is the primer specified for use with Series 237SC and Series 239SC mat-
reinforced amine epoxy systems, while Series 251SC ChemBloc, a novolac vinyl ester, is the
specified primer for Series 252SC.
At the 8.5 million gallons per day wastewater treatment plant in Salisbury, Md., three
concrete containment areas measuring 40 feet by 40 feet with a three-foot high curbing
used Tnemec's modified novolac amine epoxy to protect the substrate from harsh
chemicals, abrasion and thermal cycling. After the concrete was blast cleaned, the surface
voids were filled in with Series 218 MortarClad, a modified epoxy cementitious resurfacer,
followed by a prime coat of Epoxoprime and a trowel-applied basecoat of novolac amine
epoxy.
While the basecoat was still wet, the fiberglass mat was laid into the surface and saturated
with additional novolac amine epoxy until the mat was wet out. Additional coats of the
novolac amine epoxy were added to the initial coat after it cured to achieve the desired
thickness. A final topcoat of Series 282 Tneme-Glaze, a chemical- and solvent-resistant
novolac epoxy glaze coat, was roller-applied for added protection.
"With the various system choices we offer, the ChemBloc line covers a majority of the
chemicals and concentrations typically being stored for water and wastewater treatment,"
O'Dea said. "The primary reason for choosing one of these lining systems over another is
based on the chemical solutions in storage and the concentrations of those solutions."
Once a new lining system has cured, inspection of the lining should include high voltage
spark testing in accordance with NACE SPO188 Discontinuity (Holiday) Testing of Protective
Coatings to determine the presence and number of discontinuities. "It's always advisable to
perform holiday testing following coating application to ensure you are achieving a
monolithic barrier protection in a secondary containment system," O'Dea added.

In general, for RCRA (Hazardous waste) tanks, the secondary containment

requirements are the following:

Volume - 100% of the largest tank + the volume of the 25 yr 24 hr storm event
(note: when calculating precipitation volume make certain you use the area of the
containment system x the inches of rain for the storm).

Additionally, the material of construction for the secondary containment needs to be

compatible with the wastes. Typically, you'll see a concrete vault with PVC
waterstops at the joints and a coating (epoxy is common).