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Operational Area Containment & Pads for Bulk Pesticides - page 2 / 4





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Operational Area Containment for Bulk Pesticide Sites

Pad Capacity

40 CFR 165.85(c)(3) & (4) and 165.87(c)(2) and (3)

All old and new containment pads must have a capacity of:

(1) 750 gallons; or

(2) 100% of the capacity of the largest container or equipment used on the pad (if no container or equipment on the pad exceeds 750 gallons).

Pad Design

40 CFR 165.85(e) and 165.87(e)

New and old containment pads must:

be designed to intercept leaks and spills;  

have enough surface area to extend under containers on it;  

accommodate at least the portion of the transport vehicles where the hose couples to it for delivering pesticide;  

allow for removal/recovery of spilled, leaked or discharged material and rainfall;  

have no automatic pumps without overflow cutoffs;  

have a surface sloped to a watertight sump or depression (new pads only).

Dike & Pad Materials

40 CFR 165.85(a) and 165.87(a)

Containment structures must be constructed of steel, reinforced concrete or other rigid material capable of withstanding the full hydrostatic head and load placed on the structure and must be compatible with the pesticides stored.

The structure must be liquid-tight with cracks, seams and joints sealed.  

Natural earthen material, unfired clay and asphalt are prohibited.

Plan Approval

AASA recommends reviewing plans prior to construction with the authority having jurisdiction for your state.  This may be the state department of agriculture, state EPA, state department of environmental quality, state chemist office, or fire marshal, along with local boards and commissions.  Some states require a review.  Enforcement of the 2006 EPA Pesticide Container & Containment Rule is typically by state environmental protection personnel, but may vary.

Until You Achieve Full Compliance

Meeting the August 2009 EPA requirement will take some time.  At minimum, use temporary portable containment (i.e. catch pans) under the connections when receiving product from delivery trucks or when dispensing until a permanent containment pad is in place.

Check List

The self-check below may help in evaluating existing pads, or plans for new pads.




Has the design been reviewed by applicable authorities?


Is the capacity greater than any container placed on it, or at least 750 gallons for containers larger than 750 gallons?


Is it wide and long enough to catch leaks and spills off transport vehicles?  (At least the portion near point of connection)


Is it sloped to a sump or otherwise allow for recovering spills and rainfall?

Rev. 2, 5/22/09

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