Appendix F. Secondary Containment For New Construction and Existing Facilities

Appendix F.
Secondary Containment for New Construction and

Existing Facilities
Abstract
This Appendix reviews the regulations, requirements, and recommendations for
secondary containment in both new and existing facilities. It provides guidance on
secondary containment for equipment that processes, conveys, and stores solids and
liquids. The general principles relating to secondary containment are reviewed,
followed by guidelines for specific cases. References are provided to direct the
reader to the appropriate environmental regulations. This appendix also provides
example designs typically used for both new construction and existing facilities.
The reader should review the Introduction, Legal Requirements, and Environmental
Factors sections of this Appendix before proceeding to a specific section. Each of
the sections contain information on applicable regulations, recommendations for
secondary containment in absence of regulations, and a discussion on designs for
both new and existing facilities.
Contents
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Page
F1.0
Introduction
F-3
F1.1
Secondary Containment
F1.2
Legal Requirements (Federal or Local Regulation)
F1.3
Environmental Factors
F1.4
Determining the Need for Secondary Containment
F2.0
Legal Requirements
F2.1
Resource Conservation and Recovery Act (RCRA), 40 CFR 260-282
F2.2
Oil Spill Prevention - Regulation of Oil Pollution Prevention; Spill

Prevention Control and Countermeasures (SPCC), 40 CFR 112
F2.3
Air Pollution - The Clean Air Act (CAA), 40 CFR 60
F2.4
Water Pollution - The Clean Water Act (CWA) - National Pollutant

Discharge Elimination System, (NPDES), 40 CFR 122
F3.0
F3.1
Toxicity, Mobility, And Persistence Of Chemicals
F3.2
Geology and Soil Conditions
F3.3
Sensitivity of the Site Environment
F3.4
High Activity Areas
F4.0
Designs
F-4
F-7
F-9
F-1
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Appendix F
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Civil and Structural Manual
F5.0
Trenches and Sumps
F-9
F5.1
Regulation of Trenches and Sumps
F5.2
Recommendations for Trenches and Sumps
F5.3
Designs For New Construction
F5.4
Designs For Existing Installations
F6.0
Aboveground And Underground Piping Systems
F6.1
Regulations for Aboveground and Underground Piping Systems
F6.2
Recommendations for Aboveground and Underground Piping Systems
F6.3
General Notes For New Construction And Existing Facilities
F6.4
F6.5
Designs For Existing Facilities
F7.0
Aboveground Storage Tanks
F7.1
Regulations for Aboveground Storage Tanks
F7.2
Recommendations for Aboveground Storage Tanks
F7.3
Designs for New Construction: Aboveground Storage Tanks
F7.4
Designs For Existing Tanks
F8.0
Underground Storage Tanks
F8.1
Regulations for Underground Storage Tanks
F8.2
Recommendations for Underground Storage Tanks
F8.3
Design For New Construction
F8.4
F9.0
Process Areas
F9.1
General Information
F9.2
Regulations for Process Areas
F9.3
Recommendations for Process Areas
F9.4
F9.5
Designs For Existing Process Areas
F10.0
General Plant Drainage
F-24
F11.0
References
F-24
F-12
F-16
F-19
F-21
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F1.0
Appendix F
Introduction
F1.1
Secondary containment refers to the measures taken to ensure that material leakage
does not spread from the process in which it was generated to the adjacent soil,
groundwater, surface water, or local environment. Secondary containment is also
used as a method for minimizing air emissions from process piping and equipment.
Secondary containment should be considered for all equipment that processes,
conveys, and stores solids and liquids. Secondary containment strategies include
paved surfaces, collection systems, impermeable berms or walls, double-wall
vessels, tanks, and piping.
Secondary containment is required in two circumstances:
F1.2
1.
When there is a Federal or local regulation requiring it.
2.
A consideration of environmental factors and a risk analysis lead to the conclusion that secondary containment is necessary.
Legal Requirements (Federal or Local Regulation)

Most of the Federal law dealing with secondary containment is found in the Code
of Federal Regulations (CFR). The CFR generally requires secondary containment
for new systems which manage hazardous wastes, used oil products (e.g., spent
lubricating oil, spent hydraulic fluid, and spent heat exchanger fluid), or Underground Storage Tanks (USTs). The CFR prescribes the minimum standards for
containment. State and local laws may be more stringent and require secondary
containment for a broader range of conditions. It is important to consult with environmental engineers regarding local regulations.
F1.3
Even when secondary containment is not legally required, sound engineering judgment may dictate the need for implementation of a containment strategy.
Secondary containment can be inexpensive insurance against substantial liabilities.
F1.4
Determining the Need for Secondary Containment

Analyzing both the legal requirements and environmental factors will assist in
deciding which secondary containment strategy to employ, if any.
Legal requirements regarding specific materials are as follows:
1.
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Release of hazardous wastes to soil and groundwater is regulated by the

Resource Conservation and Recovery Act (RCRA), 40 CFR 260-282
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Appendix F
2.
Oil pollution of surface waters is regulated by the Regulation of Oil Pollution

Prevention; Spill Prevention Control and Countermeasures (SPCC), 40 CFR
112
3.
Release of emission to the atmosphere is regulated by the Clean Air Act

(CAA), 40 CFR 60
4.
Administered Permit Programs: The Clean Water Act (CWA) - National

Pollutant Discharge Elimination System, (NPDES), 40 CFR 122
Environmental factors to consider include:
F2.0
1.
The toxicity, mobility, and persistence of the materials being contained
2.
The geology and soil conditions at the site
3.
The sensitivity of the site environment to contamination
Legal Requirements
Public health and the environment are protected through a series of regulations
designed to protect the air, land, surface waters, and groundwater. The regulations
are divided into categories based on the materials they regulate: hazardous waste,
oil spill prevention, air pollution, and water pollution.
F2.1
Resource Conservation and Recovery Act (RCRA),

40 CFR 260-282
Most secondary containment requirements come from the RCRA, which specifies
the definition of wastes and hazardous materials.
To come under the secondary containment provisions of the RCRA, the material
must be defined as a hazardous waste, used oil, or a hazardous substance. An abbreviated list of RCRA hazardous wastes typically encountered in refining and chemical plant operations is presented below.
If the material under consideration is defined by the RCRA as a hazardous waste,
handling, storage, treating, and disposal equipment must be constructed and operated in compliance with 40 CFR 264.193(b), (c), (d), (e), and (f). Note that
264.193(f) permits exemptions for certain specified equipment if it is inspected on
a daily basis. Give careful consideration to the potential for the release of a
hazardous waste, the degree of hazard if the material is released, the cost, and the
difficulty of remediation before relying solely on the daily inspection exemptions
contained in 264.193(f).
Once it is determined that the material is a hazardous waste, it is important to know
what constitutes secondary containment. The CFR defines secondary containment
as liners, vaults, double-walled pipes, tanks or other equipment, or an equivalent
acceptable to the Regional Administrator. All of these serve to intercept material
before leaks or ruptures can contaminate the soil or groundwater. Secondary
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Appendix F
containment is also usually provided for ancillary equipment like piping, pumps,
and valves.
In addition to requirements for hazardous waste, secondary containment is also
required when storing used oil as defined in CFR Section 279 and when storing
hazardous substances (fuels, chemicals) in USTs, as discussed in CFR Section 280.
RCRA Hazardous Wastes and Constituents

The following regulations define hazardous wastes, hazardous constituents, and
materials that may require secondary containment. These regulations also specify
the practices required for managing and handling them.
40 CFR 148
Restrictions on Underground Injection of Hazardous Wastes
40 CFR 261
Identification and Listing of Hazardous Wastes
40 CFR 262
Standards Applicable to Generators of Hazardous Wastes
40 CFR 268
Land Disposal Restrictions
40 CFR 279
Used Oil Management Standards
40 CFR 280
40 CFR 302
CERCLA Designation, Reportable Quantities, and Notification
The following materials are commonly encountered in refineries and chemical

plants, and are considered hazardous because they exhibit a hazardous characteristic or because they are generated in identified processes or storage equipment. In
addition to the examples presented here, the full list includes many common chlorinated solvents and pesticides. The reader is encouraged to consult the CRTC
Health, Environment & Safety Group plus the appropriate section in 40 CFR 261,
Subpart C before making final determinations.
Characteristic Wastes
Ignitable, corrosive, reactive, or toxic wastes as defined in 40 CFR 261.21-24.
Toxicity can result from materials such as Arsenic, Barium, Benzene, Cadmium,
Chloroform, Chromium, Cresols, Lead, Mercury, Methyl ethyl ketone (MEK), and
Selenium.
Listed Wastes (Non-Specific Sources) 40 CFR 261.31
Number Material
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F037
Petroleum refinery primary sludges, mainly from process tanks, sumps

and trenches.
F038
Petroleum refinery secondary sludges, mainly from IAF/DAF (Induced

Air Flotation/Diffused Air Flotation) units and other equipment in
Waste Water Treatment plants.
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Appendix F
Listed Wastes (Specific Sources), 261.32

Number Material
F2.2
K048
DAF float
K049
Slop oil emulsion solids
K050
Heat exchanger bundle cleaning sludge
K051
API separator sludge
K052
Leaded tank bottoms
Oil Spill Prevention - Regulation of Oil Pollution Prevention; Spill

Prevention Control and Countermeasures (SPCC), 40 CFR 112
The SPCC regulations are intended to prevent release of oil (defined essentially as
petroleum, petroleum derivatives, sludges, etc.) to surface waters. For refineries,
these are petroleum-based materials that are not otherwise covered by the RCRA.
The SPCC covers surface treatments for drainage control, piping and storage, as
well as berms designed to prevent spills from reaching surface waters. These regulations do not require secondary containment, except in the case of metal underground oil storage tanks. Refer to 40 CFR 112.7 for design and performance
requirements.
F2.3
Air Pollution - The Clean Air Act (CAA), 40 CFR 60

As a general rule, air pollution regulations do not require secondary containment of
atmospheric contaminants. However, in 40 CFR 60, the Clean Air Act refers to
New Source Performance Standards (NSPS) and National Emission Standards for
Hazardous Air Pollutants (NESHAP). NSPS and NESHAP require implementation
of technology that controls emissions to the fullest extent possible. This technology is known as Maximum Achievable Control Technology (MACT). Fugitive
emissions (volatiles leaked from pump or valve packings, for example) are regulated through specified Leak Detection and Repair (LDAR) programs. Emissions
of 189 substances, including benzene, benzene from gasoline, cresols, chlorinated
solvents and aromatics, are also covered under this regulation.
Refer to the CAA (40 CFR 60) and Air Pollution Control Guidance Document,
March 22, 1993 with updates (CRTC), and Fugitive Air Toxic Reduction Design
Guidelines, April 19, 1991 with updates (CRTC), for a summary of applicable air
pollution regulations including design guidelines and specifications. (These documents are available from CRTCs Health, Environment & Safety Group; CTN-2424826). In some cases, secondary containment may be the most effective means for
controlling fugitive air emissions.
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F2.4
Appendix F
Water Pollution - The Clean Water Act (CWA) - National

Pollutant Discharge Elimination System, (NPDES), 40 CFR 122
The CWA, through the NPDES permit system, provides technology-based regulation of discharges to surface waters or Publicly Owned Treatment Works (POTW).
In refining operations, process and waste waters, which would otherwise meet the
definition of hazardous wastes, are usually treated to meet NPDES permit effluent
limitations in Waste Water Treatment (WWT) plants. All equipment which is part
of the WWT, including the collection system, is regulated by the NPDES, not the
RCRA, provided the treatment is done in tanks and the wastewater does not contact
the ground prior to disposal. This means components of the WWT plants do not
need to conform to RCRA secondary containment standards.
F3.0
An analysis of environmental factors may dictate that secondary containment is a
prudent choice, even in the absence of Federal or local regulations. Deciding
whether secondary containment is justified in absence of any legal requirements is
based on a consideration of the environmental factors reviewed in this section.
Additionally, the design engineer should undertake a cost benefit analysis to determine if the costs associated with secondary containment are justified in light of any
potential damage.
Aboveground equipment manufacturing pure benzene or benzene-containing gasoline, for example, would not be subject to secondary containment regulations.
Nevertheless, release to the soil of either material would very likely create a level of
contamination sufficient to trigger an expensive and complicated cleanup. Benzene
is a carcinogen and considered toxic in drinking water when present at greater than
5 parts per billion. Although equipment handling benzene is not required to meet
secondary containment standards (because it is not handling wastes or storing a
hazardous substance in an underground tank), it may be appropriate to build to such
standards if release is considered a significant risk.
Chemical toxicity, chemical mobility, persistence of chemicals, local geology, soil
conditions, and sensitivity of the site environment should all be considered when
evaluating the need to design for secondary containment of any material. Also,
regulations are changing in this area and secondary containment could be required
for new aboveground storage tanks at some point in the future. Verify the design of
any new facilities with the appropriate professional.
F3.1
Toxicity, Mobility, And Persistence Of Chemicals

The properties of the chemicals being handled are a primary consideration in
whether secondary containment is needed. Secondary containment must be considered for materials that can move quickly through soils and are toxic. Low viscosity,
high toxicity, high water solubility, and environmental persistence (non-degrading)
are properties that can lead to significant environmental damage, public outcry, and
costly cleanup efforts. On the other hand, materials that are high viscosity, low
toxicity, and low water solubility are not likely to move offsite and damage human
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Appendix F
health or the environment, and therefore, are not a priority for secondary containment.
Examples of problem chemicals include benzene, light-end petroleum fractions
(like gasoline fractions which contain benzene), and aromatic solvents. These
chemicals typically have a low viscosity, are mobile and toxic.
Methanol is another compound which might require secondary containment based
on a consideration of environmental factors. Methanol is a good solvent for other
organics, is toxic to bacteria at concentrations greater than a few hundred parts per
million, and is water soluble. Thus, depending on the circumstances, a methanol
spill will dissolve and mobilize other organics in a soil, move them into the groundwater, and kill bacteria that might otherwise degrade the organics, thus moving
them offsite.
Chlorinated hydrocarbons should also give rise to secondary containment considerations. They are very mobile, mildly soluble in water, slow to degrade and dense.
Thus, they are quick to move from shallow aquifers into deeper aquifers and are
very difficult to remove. These characteristics should make the design engineer
seriously consider secondary containment.
F3.2
Geology and Soil Conditions

Geology and soil conditions at the site are also important in defining the need for
secondary containment. A hydrogeologist should be involved in assessing the
potential of a leak to migrate and cause damage. Clay soils have low permeability
and spilled materials are not likely to migrate quickly. Conversely, sandy soils
provide little resistance to materials flowing through the ground and into groundwater.
The larger geologic picture is also important. Tanks built on rock in hills may seem
safe, but this type of terrain will often feed deeper aquifers and leaks could pose
unique and difficult problems. Tanks near creeks or other water bodies pose a
ready threat, given the short migration path, and should be considered for
secondary containment.
F3.3
Sensitivity of the Site Environment

Another factor is the potential for offsite damage. A sensitive environmental
receptor (city drinking water, wildlife refuge, etc.) that could be affected by release
of a toxic material increases the need for secondary containment. The need for
secondary containment is reduced if there is no potential to contaminate drinking
water or expose wildlife or humans to toxins.
In some cases, a plant will be built on a previously used site. The contaminants
already in the soil may require removal before a fixed facility is placed over it. If
the material will remain, assess the site and consider the long term consequences of
the unmitigated contamination. The need for secondary containment depends on
whether the potential contaminants from the new process will make the problem
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Appendix F
worse. The need for secondary containment is less if precautions are already in
place to intercept any migration of existing toxins.
F3.4
High Activity Areas

High activity areas increase the potential for spills or release of oil or chemicals to
the ground. Areas where there is frequent maintenance such as around pump pads
and filter change-out areas, at tank entries and at vessel and pipe cleanouts, are
good examples. In such areas, secondary containment may also be recommended
even if the material or process under consideration does not necessarily involve
hazardous wastes.
F4.0
Designs
Designs typically used for secondary containment of trenches and sumps, aboveground and underground piping systems, aboveground storage tanks, underground
storage tanks, and process areas are discussed in each of the following sections.
Sample designs for new and existing facilities are illustrated in Figures F-1 through
F-12, located at the end of this Appendix. The figures are schematic in nature and
should be developed further for a particular case.
F5.0
Trenches and Sumps

F5.1
Regulation of Trenches and Sumps

Trenches and sumps normally contain leaks and spills and collect stormwater in
processing, product transfer, blending and storage areas. The leaks and spills may
then be recycled, discarded or discharged in compliance with the sites NPDES
permit or the Resource Conservation Recovery Act (RCRA), 40 CFR 260-282.
Waste Water Treatment (WWT) systems permitted under the Clean Water Act
(CWA) are exempt from RCRA secondary containment requirements, provided the
treatment is done in tanks and the wastewaters do not contact the ground.
The RCRA definition of tanks (40 CFR 260.10) requires that the underlying soil
supporting the trench or sump not be essential to its structural integrity. The tank
must be self-supporting if the soil was removed. For example, concrete trenches
are considered self-supporting whereas plastic or gunnite-lined trenches are not.
Though they may be handling hazardous waste waters, trenches and sumps meeting
the RCRA definition of tanks which also feed a WWT, are included in the WWT
unit and are exempt from secondary containment requirements.
Note that sumps generally meet the definition of Underground Storage Tanks
(USTs) in 40 CFR 280.12. As USTs, they require secondary containment under
280.42 if they handle materials defined as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).
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Appendix F
However, three exemptions from secondary containment remove most of Chevrons

sumps from the requirements of 280.42:
280.10(b)(1) Any UST (i.e. sump) holding hazardous wastes is covered by the
RCRA (not by CERCLA)
280.10(b)(2) A wastewater treatment tank (trenches and sumps) that is a Clean
Water Act WWT unit
280.10(b)(6) Any emergency spill or overflow containment UST (sump) which
is expeditiously emptied after use
As a rule, process or contaminated wastewaters should be segregated from stormwater.
Secondary containment is required for hazardous waste treatment, storage and
disposal (TSD) facilities. TSD facilities and equipment must be constructed and
operated in compliance with 40 CFR 264.193(b), (c), (d), (e), and (f). Refer to 40
CFR 112.7 for construction guidelines that apply to oil tanks and ancillaries.
40 CFR 264 Regulation for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities, Subpart J - Tank Systems.
264.193(b) Secondary containment systems must be designed to
prevent the release of hazardous wastes, and must
include leak detection and monitoring capability,
which may be by instrumentation or visual observation.
264.193(c) Defines requirements for materials of construction, of
foundations, and of leak detection systems. This
section also specifies operating capabilities such as
containment volume and response times.
264.193(d), Defines secondary containment as liners, vaults,
(e), and (f) double walled sumps & trenches, or an equivalent
device acceptable to the Regional Administrator.
Ancillary equipment like piping, pumps and valves is
also defined.
Part 112
Regulation of Oil Pollution Prevention - SPCC

112.7
F5.2
This applies to aboveground and underground bulk

storage tanks for oil. The focus is prevention of
contamination of surface waters. Below-ground
tanks would be double-walled with leak sensing and
collection.
Recommendations for Trenches and Sumps

Secondary containment is recommended where there is a potential for release of
oil or chemicals to the ground. High activity areas create the potential for spills.
Examples of high activity areas include around pump pads and filter change-out
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Appendix F
areas, at tank entries, at vessel and pipe cleanouts, and where there is frequent maintenance.
It is particularly important that construction materials selected for sumps and
trenches be compatible with potential spills in order to prevent cracks and further
release. Trenches should be designed (sloped) to be free of collected material and
sumps should be emptied frequently.
The cost of secondary containment must be weighed against the probability of a
leak occurring and the cost and consequences of an actual leak. Inspection
programs, corrosion control, and other efforts can reduce the probability of
prolonged leakage. Use of secondary containment is a judgment call involving
many factors including the specific properties of the chemicals which might be
released, materials of construction, local hydrogeology, and existing site contamination. (Refer to Section F3.0, Environmental Factors for further information).
F5.3

The following guidelines should be noted where secondary containment will be
used for trenches and sumps:
All joint sealants and waterstops must be of a material compatible with the
product being contained.
The surface of the concrete that can come into contact with the contained material may need to be coated or lined to protect it from damage.
All concrete work shall conform to ACI 350R - Environmental Engineering

Concrete Structures (American Concrete Institute, Environmental Engineering
Concrete Structures Report).
The surface of any metal may need to be coated to protect it from the product
being contained.
The following drawing and figures show designs for new construction:
Note
All figures are located at the end of this Appendix.
Standard drawing Secondary containment and leak detection details for concrete
GD-S1119-2
basins. (This drawing is located in the Civil and Structural
Manual, Volume 2, in the Standard Drawings And Forms
Section.)
Chevron Corporation
Figure F-1
Concrete Trench Within Concrete Trench
Figure F-2
Steel Trenches Within Concrete Trenches
Figure F-3
Steel Sump Within A Concrete Sump
Figure F-4
Prefabricated Double Contained Trench
F-11
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Appendix F
F5.4
Designs For Existing Installations

The guidelines that are listed under Designs for New Construction (Section F5.3)
are applicable to designs for existing installations as well. With slight modifications, the designs shown in Figures F-1, F-2, and F-3 can be used for existing installations. The modifications necessary when using the designs in Figures F-1, F-2,
and F-3 for existing installations are listed below:
Figure
Modification for Existing Installations
Figure F-1
Concrete Trench Within Concrete Trench - Coat the inside surface of

the outer existing trench and install a new precast concrete trench
inside the existing trench. Cut a small groove on the bottom of the
existing trench to provide leak detection.
Figure F-2
Steel Trenches Within Concrete Trenches - Coat the inside surface

of the existing trench and install a new steel liner or HDPE liner on
the inside. Cut a small groove on the bottom of the existing trench
to provide leak detection.
Figure F-3
Steel Sump Within A Concrete Sump - The modification is similar

to one required for Figure F-2. Anchor a new steel liner to the inside
of the concrete sump and fill the void between the steel and the
concrete with grout. Add a channel to the bottom and sides of the
steel liner to provide leak detection.
Another alternative is to remove existing trenches and sumps and install new
secondary containment trenches and sumps. However, this method can be disruptive, expensive, and difficult to complete.
F6.0
Aboveground And Underground Piping Systems

F6.1
Regulations for Aboveground and Underground Piping Systems

The Resource Conservation and Recovery Act (RCRA) requires secondary containment in systems handling materials defined as both wastes and hazardous. As a
practical matter, aboveground piping would be first containment and a paved
surface or other catchment to prevent leaks from reaching soil or groundwater is
considered secondary containment (if potential leaks would not release air toxins).
40 CFR 264.193(f) permits exemptions for piping if it is inspected on a daily
basis. However, it is recommended that careful consideration be given to the potential for, and consequences of, a release before depending solely on visual inspections. Refer to the discussion on the Clean Air Act (CAA) above and Air Pollution
Control Guidance Document, March 22, 1993 plus updates (CRTC) and Fugitive
Air Toxic Reduction Design Guidelines, April 19, 1991 plus updates (CRTC) for a
summary of applicable air pollution regulations plus design guidelines and specifications. (These documents are available from CRTCs Health, Environment &
Safety Group; CTN-242-4826). Refer also to the RCRA (40 CFR 260-279) for
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Appendix F
definitions of hazardous wastes and constituents commonly encountered in refining

environments.
As a general rule, air pollution regulations do not require secondary containment.
However, in 40 CFR 60, the Clean Air Act sets New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants
(NESHAP). NSPS and NESHAP require implementation of technology that
controls emissions to the fullest extent possible. This technology is known as
Maximum Achievable Control Technology (MACT). Fugitive emissions (volatiles
leaked from pump or valve packings, for example) are regulated through specified
Leak Detection and Repair (LDAR) programs. Emissions of 189 substances,
including benzene, benzene from gasoline, cresols, chlorinated solvents and
aromatics, are also covered under this regulation.
Secondary containment is required for hazardous waste treatment, storage and
disposal (TSD) facilities. Piping in handling, storage, treating, and disposal equipment must be constructed and operated in compliance with 264.193(b), (c), and
(f). Refer to 112.7 for metallic tank construction guidelines.
40 CFR 264 Regulation for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal (TSD) Facilities, Subpart J - Tank
Systems. Piping is in the category of ancillary equipment,
264.193(f). Note that secondary containment would not be
required if the piping and tanks are part of a WWT unit.
264.193(b) Secondary containment systems must be designed to
prevent the release of hazardous wastes, and must
264.193(c) This section defines requirements for materials of
construction, of foundations, and of leak detection
systems, and specifies operating capability, such as
containment volume and response times.
264.193(f) This section defines ancillary equipment like piping,
pumps and valves. Secondary containment is not
required for piping, pumps, joints, flanges, etc., which
can be visually inspected on a daily basis. For the
most part, this may be taken to mean aboveground
hazardous waste systems do not need double-walltype secondary containment because providing an
impermeable paved surface or trench to capture drips
and spills would qualify as secondary containment.
Underground hazardous waste systems require doublewall-type secondary containment. Screwed fittings are
not permitted, because they are presumed to leak,
unless such leaks would be managed by secondary
containment, such as being within the containment
wall around a tank.
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Appendix F
264.193(f) Flanges are acceptable in hazardous waste service.

(cont.)
40 CFR 112 Regulation of Oil Pollution Prevention - SPCC
112.7
F6.2
This applies to aboveground and underground bulk

storage tanks for oil. The focus is on prevention of
contamination of surface waters. Below-ground tanks
would be double-walled with leak sensing and collection.
Recommendations for Aboveground and Underground Piping

Systems
areas, at tank entries, at vessel and pipe cleanouts, and where there is frequent maintenance. Piping locations where leaks and spills are more likely (drain points, valve
and flanges joints, etc.) should also be reviewed for secondary containment.
The cost of secondary containment must be weighed against the probability of a
leak occurring and the cost and consequences of leaking. Inspection programs,
corrosion control, and other efforts can reduce the probability of prolonged
leakage. Use of secondary containment is a judgment call involving many factors
including the specific properties of the chemicals which might be released, materials of construction, local hydrogeology, and existing site contamination. (Refer to
the Section on Environmental Factors for further information.)
F6.3
General Notes For New Construction And Existing Facilities

The material selected for the secondary containment should be compatible with the
fluid for which containment is ultimately being provided. When the primary piping
is intended for chemical transport, the material of the primary piping must corrode
at an acceptable rate (metallic materials), and not be susceptible to other forms of
corrosion that can lead to a failure (stress corrosion cracking, pitting, etc.).
If the primary piping material is nonmetallic, it should be selected such that it will
not lose a significant amount of tensile strength, or will not be subjected to a significant amount of weight gain over its life due to contact with the fluid to be transported. The primary nonmetallic material must also be resistant to other forms of
degradation that can lead to failure such as environmental stress cracking and
delamination. The material of the secondary containment must also be resistant to
the corrosive effects of the surrounding environment. The characteristics of the
fluids, the temperature and pressures involved, the stresses inherent in the system
design, and the surrounding environment should also be considered.
Systems can be designed in a compartmentalized manner so long as each compartment provides an unobstructed, definable annulus for detection of leaks. In installa-
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Appendix F
tions where the primary piping is based on pressure ( 15 psig or 0 psig), the
secondary containment system should be designed to the same rating unless:
1.
The system is equipped with a self-monitoring automatic leak detection system

that is interfaced with a control system capable of shutting off the source of
pressure, and with a redundant monitoring device and control system; or
2.
The systems annulus is designed with at least one open end. Consider the
possibility of pressure accumulation in the annulus if the fluid being transported has a solids content.
At least one low point drain and high point vent should be provided in the annulus,
except where the low point is the end of the system, and the system is designed as
an open-ended system.
The design engineer should consider the effects of differential thermal expansion
and contraction (if applicable), and insure that sufficient flexibility is inherent in the
layout of the system so that it will function properly and without failure. Alternatively, the system can be devised with a restrained design such that each of the
components and joints have sufficient strength to withstand the loads that may be
imposed on them. Expansion joints should not be installed as part of the primary
piping system unless they are readily accessible for maintenance.
In aboveground installations, expansion devices, joints or couplings may be used on
the outer jacket in order to accommodate all or a portion of the thermal expansion
and/or contraction. The design engineer should take into account the fact that while
such devices can be used to alleviate stresses due to differential thermal expansion/contraction, the system as a whole must be laid out to accommodate the differential growth.
In underground installations, the outer jacket is restrained by soil friction and
changes in direction. The design engineer should be aware that in a restrained
design, the outer jacket is not free to expand and contract simultaneously with the
primary pipe.
The primary piping system and the secondary containment piping system should be
tested. When testing the secondary containment piping, caution should be taken so
as not to collapse the primary pipe system due to the external pressures that are
imposed on it.
Systems where there is a likelihood of false leaks due to moisture condensation
should be purged with an inert gas.
F6.4

Double pipe (pipe-within-a-pipe), trough or trench designs are described in Section
550 of the Civil and Structural Manual. The double pipe system uses a pipe-withina-pipe so that the inner pipe is the actual liquid drain and the outer pipe will contain
any leakage from the inner pipe. The trough or trench containment system consists
of a trough or a trench to contain any leakage from the drain.
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June 1997
Appendix F
There are many types of leakage detectors on the market. Section 544 of the Civil
and Structural Manual discusses various types of leak detection for double pipe
and trough and trench containment systems. Three types of leak detectors, observation monitoring, point detection, and continuous monitoring, are discussed below.
Observation monitoring requires inspecting and gathering samples at a series of low
points where liquids collect. The presence of a liquid at these low points is
assumed to indicate leakage in the upstream system until sample analysis indicates
otherwise. This type of system is shown in Figure F-5.
Point detection is another containment strategy worth considering. Point detection
involves an electronic device that indicates the presence of liquids. The presence of
liquids will electronically send a signal to either a control panel or alarm circuit
indicating a leak upstream. This type of system is shown in Figure F-5.
Continuous monitoring is usually done with a leak detection cable or a vapor detection tube within the secondary containment. In either system, the leak detection
device is continuous along the length of the system being protected, and is automatically monitored. This type of system is shown in Figure F-6.
F6.5
Designs For Existing Facilities

There are several methods that can be used to upgrade existing piping facilities to a
double-contained system. The methods described in Section 540 of the Civil and
Structural Manual require installation of a new internal lining inside the existing
pipe with a new primary pipe, as shown in Figure F-7.
Complete replacement with new double-contained systems is another alternative,
However, excavation and replacement of sewers is disruptive and expensive.
F7.0
Aboveground Storage Tanks

F7.1
Regulations for Aboveground Storage Tanks

Regulation of aboveground storage tanks (ASTs) to prevent release of certain specified materials comes from three main sources:
Release of hazardous wastes
to soil and groundwater
Resource Conservation and Recovery Act

(RCRA, 40 CFR 260-279)
Oil pollution of surface waters
The Regulation of Oil Pollution Prevention; Spill

Prevention Control and Countermeasures
(SPCC) 40 CFR 112
Releases to the atmosphere
The Clean Air Act (CAA), 40 CFR 60
As a practical matter, aboveground (or onground) tanks are considered first

containment and a paved surface plus wall surrounding the tank to prevent leaks
from reaching soil or groundwater could be considered secondary containment.
Additional rules apply to construction of the tank bottom. Refer to the RCRA (40
June 1997
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Appendix F
CFR 260-279) definitions and handling requirements for hazardous wastes and
constituents commonly encountered in refining environments.
Maximum Achievable Control Technology (MACT). Fugitive emissions are regulated through specified Leak Detection and Repair (LDAR) programs, which may
apply to the appurtenances of the tank. Emissions of 189 substances, including
benzene, benzene from gasoline, cresols, chlorinated solvents and aromatics, are
also covered under this regulation.
pollution regulations including design guidelines and specifications. (These documents are available from CRTCs Health, Environment & Safety Group; CTN-2424826).
Secondary containment is required for new hazardous waste treatment, storage and
disposal (TSD) facilities. Tanks handling, storage, treating, and disposal systems
must be constructed and operated in compliance with 264.193(b), (c), and (f).
Refer to 112.7 for oil storage tank construction guidelines.
40 CFR 264
Regulation for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal (TSD) Facilities, Subpart J - Tank
Systems. Note that secondary containment would not be required
if the tank is part of a WWT unit.
264.193(b) Secondary containment systems must be designed
to prevent the release of hazardous wastes, and must
264.193(c) Defines requirements for materials of construction,
of foundations, of leak detection systems, and specifies operating capability such as containment
volume and response times.
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June 1997
Appendix F
264.193(f) Defines tank appurtenances such as piping, pumps

and valves. Secondary containment is not required
for those which can be visually inspected on a daily
basis. For the most part, this may be taken to mean
aboveground hazardous waste systems do not need
double-wall-type secondary containment because
providing an impermeable paved surface or trench
to capture drips and spills would qualify as
secondary containment. Underground hazardous
waste systems require secondary containment.
Screwed fittings are not permitted, because they are
presumed to leak, unless such leaks would be
managed by secondary containment, such as being
within the containment wall around a tank. Flanges
are acceptable in hazardous waste service.
40 CFR 112.7 Regulation of Oil Pollution Prevention - SPCC
112.7
F7.2
This section applies to aboveground and underground bulk storage tanks for oil. The focus is on
preventing contamination of surface waters. Belowground tanks are to be double-walled with leak
sensing and collection.
Recommendations for Aboveground Storage Tanks

Tanks can leak for long periods of time if proper detection systems are not in place.
This has been a source of significant soil contamination and liability for Chevron.
Some locations place double bottoms on all tanks due to soil condition. The cost of
secondary containment must be weighed against the probability of a leak occurring
and the cost and consequences of leaking. Inspection programs, corrosion control,
and other efforts can reduce the probability of prolonged leakage.
Use of secondary containment is a judgment call involving many factors, including
the specific properties of the chemicals which might be released, materials of
construction, local hydrogeology, and existing site contamination. (Refer to the
Section on Environmental Factors for further information.)
F7.3
Designs for New Construction: Aboveground Storage Tanks

Section 500 and Figure 500-18 of the Tank Manual detail designs typically used for
new construction of ASTs. Figure 500-18 shows most of the commonly used
designs. The N figures cover the designs that include leak detection for new
June 1997
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Chevron Corporation
Appendix F
installations. Figures F-8 and F-9 (this Appendix) show tanks with lined dikes and
lined sumps.
F7.4

The R figures of Figure 500-18 of the Tank Manual illustrate retrofit designs in
cases where a new tank bottom replaces an existing one. Design 1R has been used
in many Chevron facilities. Standard Drawing GD-D1120, in the Standard Drawings and Forms Section of Volume 2 of the Tank Manual, shows a standard bottom
replacement for existing tanks.
F8.0

F8.1
Regulations for Underground Storage Tanks

Regulation of underground storage tanks (USTs) to prevent release of certain specified materials comes from three main sources:
Release of hazardous wastes
to soil and groundwater
Resource Conservation and Recovery Act

(RCRA, 40 CFR 260-280)
Oil pollution of surface waters
The Regulation of Oil Pollution Prevention; Spill

Prevention Control and Countermeasures
(SPCC) 40 CFR 112
Releases to the atmosphere
The Clean Air Act (CAA), 40 CFR 60
USTs holding petroleum need not be double-walled, but must have leak detection
capability as specified in 40 CFR 280.41. USTs holding hazardous wastes or
hazardous substances must be double-walled (40 CFR 280.42) and meet the
design requirements of 280 Subpart B and D (leak detection).
USTs require secondary containment under 280.42 if they handle materials
defined as hazardous substances under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA). However, three exemptions from secondary containment, remove some USTs from the requirements of
280.42. They are:
280.10(b)(1) Any UST holding hazardous wastes is covered by the RCRA.
280.10(b)(2) Any wastewater treatment tank in a Clean Water Act WWT unit.
280.10(b)(6) Any emergency spill or overflow containment UST which is expeditiously emptied after use.
Except for the exemptions noted above, secondary containment is required for
hazardous waste treatment, storage and disposal (TSD) facilities and when storing
hazardous substances as defined in CERCLA. USTs that handle, storage, treating
and disposal systems must be constructed and operated in compliance with 280,
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June 1997
Appendix F
Subparts B, C and D. Refer to 112.7 for UST oil storage tank construction guidelines.
40 CFR 280 Technical Standards and Corrective Action Requirements for
Owners and Operators of Underground Storage Tanks (UST). Note
that this regulation does not apply to USTs in a Waste Water
Treating (WWT) unit, because those are regulated by the Clean
Water Act (CWA).
280 Subpart B
UST Systems: Design, Construction, Installation

and Notification. Materials of construction,
design of appurtenances, and certain recordkeeping requirements are defined.
280 Subpart C
General Operating Requirements: The design

must meet specified overflow protection, inspection and repairability requirements.
280 Subpart D
Release Detection: General requirements for, and

methods of, release detection are described.
Petroleum USTs (280.41) and hazardous
substance USTs (280.42) are defined specifically.
40 CFR 112 Regulation of Oil Pollution Prevention - SPCC

112.7
This section applies to aboveground and underground bulk storage tanks for oil. The focus is
preventing contamination of surface waters.
Below-ground tanks are to be double-walled with
leak sensing and collection.

Maximum Achievable Control Technology (MACT). Fugitive emissions are regulated through specified Leak Detection and Repair (LDAR) programs, which may
apply to the appurtenances of the tank. Emissions of 189 substances, including
benzene, benzene from gasoline, cresols, chlorinated solvents and aromatics, are
also covered under this regulation.
pollution regulations including design guidelines and specifications.
F8.2
Recommendations for Underground Storage Tanks

Secondary containment is strongly recommended for all USTs in refineries and
chemical plants, unless the UST will be storing a material which can be released
directly to the ground, such as non-industrial waste water. The cost of secondary
June 1997
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Chevron Corporation
Appendix F
containment must be weighed against the probability of a leak occurring and the
cost and consequences of leaking. Inspection programs, corrosion control, and
other efforts can reduce the probability of prolonged leakage. Use of secondary
containment is a judgment call involving many factors including the specific properties of the chemicals which might be released, materials of construction, local
hydrogeology, and existing site contamination. (Refer to the Section on Environmental Factors for further information.)
F8.3
Design For New Construction

The standard underground tank for new construction is a composite or a fiberglass
reinforced plastic (FRP) double-walled tank with leak detection for the annulus.
Composite tanks have double steel walls with fiberglass resin covering the outer
wall. Composite tanks are used more often than FRP tanks. The double-walled
tank design is used to avoid groundwater contamination from leaks. Section 1200
of the Tank Manual provides additional information on double-walled underground
tanks.
Figures F-10 and F-11 in this Appendix illustrate two other ways to provide
secondary containment for USTs. Figure F-10 shows an underground tank with a
buried liner. Figure F-11 shows underground tanks contained in a concrete vault.
F8.4

There are several ways to provide secondary containment for an existing tank:
F9.0
Replace it with a new double-walled tank.
Add a buried liner as shown in Figure F-10.
Add a concrete vault as shown in Figure F-11.
Process Areas
F9.1
General Information
Secondary containment in process areas is not specifically mandated except for
units processing or handling materials defined as hazardous wastes by the RCRA.
Secondary containment must be provided in units handling RCRA hazardous
wastes (40 CFR 264.193). Examples of compliance include, double-wall vessels
and piping, walls and berms around tanks, and addition of an impervious surface
cover. Piping, fittings, etc., which can be visually inspected on a daily basis may be
exempt from secondary containment requirements; however, judgment should be
exercised before relying on this exception. Refer to the Section on Legal Requirements for further information.
Determining whether secondary containment is justified for units handling nonhazardous constituents or wastes, requires an analysis of the following factors:
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June 1997
Appendix F
applicable regulations
the physical, chemical, and toxicity characteristics of the contained material
the potential for release of the constituent or waste
the costs and risks of a release
Paved surfaces and catchment systems may provide the secondary containment to
piping, tanks and reactors. Accordingly, double-wall vessels and piping are seldom
necessary in aboveground service.
Sludges that are generated by the mixing of process wastewaters and oily wastes,
and by contamination of stormwater with oily wastes in refineries, are F037
hazardous wastes. As a rule, leaks and spills of refining process materials and
hazardous wastes and hazardous constituents should be segregated from stormwater. Furthermore, they should be isolated and recovered within process units and
not allowed to exit the unit boundaries. This will minimize hazardous waste
management costs.
Non-RCRA process areas experiencing drips, spills and other contamination should
generally be surfaced with an impermeable material. Concrete or asphalt is usually
sufficient to prevent contamination of soil or groundwater, or releases to surface
waters. In some services it may be prudent to add membranes or coatings. The
important factors here are material resistance to abrasion, potential drips and spills,
and selection of a surface material which will not develop cracks. Runoff from nonhazardous waste service is regulated by either SPCC or NPDES requirements.
Consideration of the relevant factors presented here will often lead to the decision
to provide continuous, sealed drainage surfaces. (Refer to the Sections on Legal
Requirements and Environmental Factors for further information.)
F9.2
Regulations for Process Areas

Secondary containment is required if the material being handled meets the definition of an RCRA Hazardous Waste. Handling, storage, treating and disposal equipment must be constructed and operated in compliance with 40 CFR 264.193.
Note that secondary containment is not required if the equipment is part of a WWT
unit. Surface cover is recommended in this service and would, in effect, be part of
the overall system which includes trenches and sumps to collect and control leaks,
spills and runoff. Double-wall design is usually not required for equipment and
piping in process areas. 40 CFR 112.7 applies to drainage and collection systems
designed to prevent oily materials and waste from being released to surface waters.
F9.3
Recommendations for Process Areas

June 1997
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Chevron Corporation
Appendix F
In the case of process areas, surface paving is recommended to intercept spills and
prevent contamination of the ground or groundwater. The cost of secondary
containment must be weighed against the probability of a leak occurring and the
cost and consequences of leaking. Inspection programs, corrosion control, and
other efforts can reduce the probability of prolonged leakage. Use of secondary
containment is a judgment call involving many factors including the specific properties of the chemicals which might be released, materials of construction, local
hydrogeology, and existing site contamination. (Refer to the Section on Environmental Factors for further information.)
F9.4

The following considerations should be noted where secondary containment in
process areas is required:
F9.5
Secondary containment in process areas may be obtained by paving, curbing,

walls, pits, or combinations of these.
All concrete work shall conform to ACI 350R - Environmental Engineering

Concrete Structures (American Concrete Institute, Environmental Engineering
Concrete Structures Report).
Areas designed for secondary containment should use monolithic pours whenever possible. Waterstops should be used where joints are required.
All joint sealants and waterstops shall be of a material compatible with the
product being contained.
All containment areas should have at least one collection point from which
spills can be removed.
Refer to Figure F-12 for a design typically used for new construction requiring
secondary containment.
Designs For Existing Process Areas

There are several ways to provide secondary containment for existing facilities:
Chevron Corporation
Replace existing paving with new concrete as shown in Figure F-12.
Add new concrete on top of existing paving to withstand maintenance loadings. This includes waterstops, joint sealants, and new curbs. This alternative
is viable only if the change in elevation is acceptable.
The considerations listed in Section 9.4, Designs for New Construction, are
applicable to existing process areas.
F-23
June 1997
Appendix F
F10.0 General Plant Drainage

General plant drainage is regulated by either the SPCC (40 CFR 112) or the
NPDES (40 CFR 60); secondary containment is usually not required. General
plant drainage includes pipeways and off-plot areas. However, a surface impoundment that stores refinery contaminated wastewaters is regulated by the RCRA, 40
CFR 264 Subpart K, Surface Impoundments.
Drainage systems should be designed to segregate stormwater from process and
other contaminated waters where possible. Contaminated water usually must be
treated in a WWT unit where secondary containment is not required, provided treatment occurs in tanks. However, by definition, sludges (from trenches or ditches)
generated by mixing process wastewaters and oily wastes, or by contaminating
stormwater with oil, are F037 hazardous wastes (in refineries, but not chemical
plants) and require secondary containment. Uncontaminated stormwaters may be
discharged directly to surface waters or to a Publicly Owned Treatment Works
(POTW) if they meet conditions set in an NPDES permit. Consideration of applicable regulations, the physical, chemical, and toxicity characteristics of the
collected material, the potential for release of the material, and the costs and risks
of a release may lead to a decision to provide continuous, sealed drainage.
Usually a material like concrete or asphalt is sufficient to prevent contamination of
soil or groundwater, or release to surface waters. The important factors here are
material resistance to potential drips and spills, and selection of a surface material
which will not develop cracks.
Surface impoundments are thoroughly regulated in Subpart K, of 40 CFR 264.220264.231. Multiple liners, leachate collection, and closure requirements make
surface impoundments a very undesirable choice among the options for waste and
contaminated water management.
SPCC regulations, (specifically 40 CFR 112.7) apply to drainage and collection
systems designed to prevent oily materials and waste from being released to surface
waters.
F11.0 References
June 1997
1.
The American Society of Civil Engineers, Petrochemical Energy Committee,

Task Committee on Secondary Containment, Design of Secondary Containment in Petrochemical Facilities, publication expcected in 1997.
2.
Carl C. Faller, In-Place Rehabilitation of Process Sewers, Trenchless Technology, July 1994.
3.
DuPont Engineering, Groundwater Protection Practices, April, 1993.
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Chevron Corporation
Fig. F-1
Appendix F
Concrete Trench Within Concrete Trench Courtesy of American Society of Civil Engineers
Figure is schematic in nature and

should not be used for design.
Fig. F-2
Steel Trenches Within Concrete Trenches Courtesy of American Society of Civil Engineers

Chevron Corporation
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June 1997
Appendix F
Fig. F-3
Steel Sump Within Concrete Sump Courtesy of American Society of Civil Engineers

Fig. F-4
Prefabricated Double Contained Trench Courtesy of DuPont Engineering Existing Trenchless Sumps

June 1997
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Chevron Corporation
Fig. F-5
Appendix F
Visual Detection and Point Detection Courtesy of American Society of Civil Engineers

Fig. F-6
Continuous Monitoring Courtesy of American Society of Civil Engineers

Chevron Corporation
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June 1997
Appendix F
Fig. F-7
Secondary Containment for Existing Pipe

Fig. F-8
Storage Tank With Ringwall Foundation Courtesy of American Society of Civil Engineers

June 1997
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Chevron Corporation
Fig. F-9
Appendix F
Storage Tank With Earth Foundation Courtesy of American Society of Civil Engineers
Fig. F-10 Buried Liner Courtesy of American Society of Civil Engineers

Chevron Corporation
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June 1997
Appendix F
Fig. F-11 Concrete Vault Courtesy of American Society of Civil Engineers

Fig. F-12 Process Area Courtesy of American Society of Civil Engineers

June 1997
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Chevron Corporation

Appendix F. Secondary Containment For New Construction and Existing Facilities

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Appendix F. Secondary Containment For New Construction and Existing Facilities

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Appendix F.

Secondary Containment for New Construction and

Legal Requirements (Federal or Local Regulation)

Determining the Need for Secondary Containment

Resource Conservation and Recovery Act (RCRA), 40 CFR 260-282

Oil Spill Prevention - Regulation of Oil Pollution Prevention; Spill

Air Pollution - The Clean Air Act (CAA), 40 CFR 60

Water Pollution - The Clean Water Act (CWA) - National Pollutant

Toxicity, Mobility, And Persistence Of Chemicals

Geology and Soil Conditions

Sensitivity of the Site Environment

High Activity Areas

Civil and Structural Manual

Trenches and Sumps

Regulation of Trenches and Sumps

Recommendations for Trenches and Sumps

Designs For New Construction

Designs For Existing Installations

Aboveground And Underground Piping Systems

Regulations for Aboveground and Underground Piping Systems

Recommendations for Aboveground and Underground Piping Systems

General Notes For New Construction And Existing Facilities

Designs For New Construction

Designs For Existing Facilities

Aboveground Storage Tanks

Regulations for Aboveground Storage Tanks

Recommendations for Aboveground Storage Tanks

Designs for New Construction: Aboveground Storage Tanks

Designs For Existing Tanks

Underground Storage Tanks

Regulations for Underground Storage Tanks

Recommendations for Underground Storage Tanks

Design For New Construction

Designs For Existing Tanks

Regulations for Process Areas

Recommendations for Process Areas

Designs For New Construction

Designs For Existing Process Areas

General Plant Drainage

Civil and Structural Manual

When there is a Federal or local regulation requiring it.

Legal Requirements (Federal or Local Regulation)

Determining the Need for Secondary Containment

Release of hazardous wastes to soil and groundwater is regulated by the

Civil and Structural Manual

Oil pollution of surface waters is regulated by the Regulation of Oil Pollution

Release of emission to the atmosphere is regulated by the Clean Air Act

Administered Permit Programs: The Clean Water Act (CWA) - National

Environmental factors to consider include:

The toxicity, mobility, and persistence of the materials being contained

The geology and soil conditions at the site

The sensitivity of the site environment to contamination

Resource Conservation and Recovery Act (RCRA),

Civil and Structural Manual

RCRA Hazardous Wastes and Constituents

Restrictions on Underground Injection of Hazardous Wastes

Identification and Listing of Hazardous Wastes

Standards Applicable to Generators of Hazardous Wastes

Land Disposal Restrictions

Used Oil Management Standards

Underground Storage Tanks

CERCLA Designation, Reportable Quantities, and Notification