Cameron-Cole performed a system-wide evaluation of secondary containment structures and developed a three-part program to improve containment and achieve compliance with SPCC regulations for a Class I railroad in the western United States. The program included reviewing the regulatory basis for evaluating the secondary containment program. A review of the existing secondary containment program and evaluation of secondary containment facilities at existing facilities was then performed. A compilation of facility containment structures that were constructed with low-permeability material was created to curate a discussion of industry practices regarding secondary containment. Cameron-Cole then evaluated the availability of low-permeability materials for the construction of the secondary containment structures. Representative pricing was provided to the client to retrofit secondary containment structures with low-permeability materials as well as design considerations to retrofit these structures. The evaluation resulted in development and implementation of a cost-effective design program that resulted in retrofitting more than 40 fuel storage tank farms with low permeability materials that improved secondary containment specifications and achieved compliance with SPCC requirements.