Yes, I would think a slab or waterproof barrier of some kind would be necessary, both to protect the soil and to avoid having to consider the submerged footing condition, which would negate most of the resisting weight. Perhaps I should have quoted DenverStruct's statement from yesterday in my response:
"It is exactly like avscorrie's drawing except it does not have a slab. The L shape is just buried down 3 ft with just soil. No concrete slab on the finished grade."
I was just saying the slab at finished grade, or some other means of keeping the liquid on top of the backfill and footing, is a key element. Without it, you only have the resistance of 87 pcf for the concrete heel and less than that for the soil on top of the heel.
Depending on the possible failure modes of the primary containment tank, dynamic water pressures may have to be considered, also.