In previous articles, we learned about the basics of secondary containment through "Secondary Containment 101" and have a general idea when and where the spill containment pallet is needed.
For industrial facilities engaged in bulk storage of hazardous liquids, petroleum derivatives, and chemical commodities, secondary containment is a statutorily mandated compliance with the “110% rule”;
And this article targets to:
The EPA’s SPCC regulation explicitly requires containment structures to retain the maximum potential volumetric discharge from the largest single container within a designated storage footprint, supplemented by additional capacity to accommodate hydrological inputs.
EPA does not codify a mandatory 110% capacity threshold within federal SPCC statutes. Instead, the 110% standard constitutes a universally adopted industry best practice and pragmatic compliance–typically quantified as a 25-year, 24-hour precipitation event per regional engineering standards.
The 10% volumetric buffer is engineered to account for three key operational and environmental variables:
This section illustrates how to calculate single-container, multi-container, and displacement-adjusted scenarios in consideration of regulatory compliance and field-ready accuracy.
For individual storage vessels—including tanks, drums, and intermediate bulk containers (IBCs)—the minimum required containment capacity is calculated using the following formula:
For multiple containers in the same area under EPA regulations (SPCC and 40 CFR 264.175), secondary containment must hold:
Illustrative Technical Example: Storing ten 55-gallon drums (550 total gallons) in one area:
| Calculation Method: | 10% of total volume | 110% of largest container |
| Mathematics Result: | 55 gallon*10ea*10%=55 Gallon | 55 gallon* 110%=60.5 Gallon |
| Requirement: | The containment system must hold at least 60.5 gallons. | |
Freeboard Requirement: If the containment is outdoors, the system must hold the required volume plus additional capacity for a 24-hour, 25-year storm event (often managed by adding a 10% freeboard allowance to the 110% figure).

Critical engineering consideration must be given to structural displacement volume, defined as the volumetric space occupied by container bases, support structures, fixed piping, and permanent fixtures within the containment perimeter. This factor reduces the system’s effective holding capacity, requiring a compensatory adjustment to the baseline calculation:
Common sources of structural displacement include tank support legs, reinforced concrete piers, drum racking systems, and fixed piping assemblies located within the containment boundary.
Inadequate containment capacity caused industrial incidents include:
The primary adverse outcomes of inaccurate containment capacity calculations include:
Once containment capacity requirements are finalized, facility engineering and EHS teams should select containment systems that meet SPCC regulatory standards and are engineered for the facility’s unique storage profile, operational conditions, and hazardous material characteristics.
Designed for stationary drum and IBC storage applications, these industrial-grade units are SPCC-compliant drum spill pallets. Featured compact, corrosion-resistant construction and integrated sump reservoirs built to meet 110% capacity requirements for low-to-moderate volume bulk storage. All systems are SPCC-compliant and optimized for seamless industrial workspace integration.

Ideal for temporary storage, bulk tank farms, and mobile equipment applications, flexible containment berms enable rapid deployment, customizable dimensions, and scalable volumetric capacity to meet large-scale 110% compliance mandates. These systems perform reliably in indoor and outdoor settings and adapt to uneven subgrade conditions.
Regulatory and Technical References