Q. In an automobile dealership service department, can the floor (inside of a building) or oil/water separator drains be counted as secondary containment for containers ranging from 55 gallons (gals) to 500 gals?
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A. Floors are generally not acceptable secondary containment methods. However, oil/water separator drains are acceptable.
40 CFR 112.7(c) requires the use of the following prevention systems or their equivalent at onshore facilities, including automobile dealerships:
- Dikes, berms, or retaining walls sufficiently impervious to contain oil
- Curbing or dripping pans
- Sumps and collection systems
- Culverting, gutters, or other drainage systems
- Weirs, booms, or other barriers
- Spill diversion ponds
- Retention ponds
- Sorbent materials
Other methods may be used as long as they are consistent with “good engineering practice.” The EPA considers other such practices to include oil/water separators combined with drainage systems. The EPA would not consider the floor of a building to be consistent with good engineering practice for the purposes of SPCC secondary containment.