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25 October 2019 AdvancedGeo AGE Project No. 99-0637 Environmental Page 8 of 19 4.4. CONTAINMENT AND DIVERSIONARY STRUCTURES - 40 CFR 112.7(c) Methods of secondary containment at the Facility include a combination of structures (e.g., double-wall construction) and land-based spill response (e.g., booms or absorbents) to prevent oil and/or petroleum fuel from reaching navigable waters or adjoining shorelines. 4.4.1. Spill Pallets Each spill pallet has a minimum 110%, which can effectively contain the volume of any single 55-gallon drum. Drums are also stored inside the maintenance building and are not exposed to precipitation. The floor of the maintenance building and lower 3 inches of the outside walls are constructed of poured concrete that would restrict the flow of oil outside the building. 4.4.2. Fueling Area The Facility uses a double AST system to conduct fueling, located in the fueling area located to the southeast of the main office (210 East Wetmore). This area is slightly sloped to provide minimal containment from hose and connection leaks during fueling of Facility vehicles. 4.4.3. Oil Transfer Areas Drip pans are placed under fill ports for all ASTs when filling and used to catch leaks from the piping/hose connections. Sorbent material is placed in spill cleanup kits. An oil handling and transfer procedures list is included in Table 7. The spill kits are located near ASTs (Figure 2) with exposed piping for rapid deployment should a spill occur, such as spills associated with overfills or hose rupture. Due to the nature of the Facility, spill kits are located within enclosed rooms. The response equipment inventory for the facility is listed in Appendix E of this Plan. The inventory is checked monthly to ensure that used material is replenished. 4.4.4. Loading/ Unloading Area The unloading area is slightly sloped towards the storage container and provides minimal containment from hose and connection leaks during unloading. 4.4.5. Drainage System The facility surface drainage is sloped to direct oil that may be discharged outside of