Ask the Expert, Q&A, Special Topics in Environmental Management

SPCC: Secondary Containment

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?

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.


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