Q. Would the interior of a building count as a secondary containment area if you can assure the nothing can leak out?
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A. No, the interior of a building cannot count as secondary containment. 40 CFR 112.7(c) requires the use of the following prevention systems or their equivalent at onshore facilities:
- 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 interior of a building to be consistent with good engineering practice for the purposes of SPCC secondary containment.
Am curious as to the reasoning behind this expert opinion. The first line quoted in 40 CFR 112.7(c)identifies “dikes, berms, or retaining walls . . .” While not all manufacturing floor interiors have side walls, concrete flooring (with attention to seams)would certainly meet the requirement of being “sufficiently impervious to contain oil”. Depending on the potential quantity of and oil product spill, (and slope geometery of the floor) there may not even be any contact with a side wall. The spirit of the regulation is to assure that oil does not lost to the environment and reach surface or groundwater. I can easily see circumstances where this objective would be accomplished within a building.