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PSARA
Interviews US EPA Regarding Secondary
Containment Requirements Around Loading and
Unloading Racks |
| In response to a number of inquiries, PSARA
contacted the US EPA to determine the applicability of the SPCC
Rules to both loading as well as unloading racks. Going
into the interview we knew the intent of the rule was to cover
the typical loading and unloading racks at bulk plants.
What was not clear, however, was whether or not the scope of the
rule was intended to cover less typical loading and unloading operations.
As of February 13, 2004, the EPAs interpretation is that all oil
loading and unloading
operations are covered by the secondary containment rule.
This interpretation opens a lot of scenarios to sites
covered by the SPCC rule. Will the EPA require
containment or quick drainage for every 275 or 500 gallon AST
at an affected site? We expect the EPA to offer further interpretation
prior to the August deadline.
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