The regulations do not specify any particular materials that a secondary container should or should not be constructed from, only that its base and walls must be "impermeable to water and oil". A conventional bund constructed from bricks and mortar is unlikely to be impermeable without rendering of some kind. Information on coatings and surface treatments to achieve a satisfactory impermeability can be found in Masonry and Concrete Bunds For Oil Storage Tanks, which are taken from the CIRIA report 163 Construction of Bunds for Oil Storage Tanks.
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