Does your facility’s SPCC Plan properly account for mobile refuelers?

Does your facility's SPCC Plan properly account for mobile refuelers?

Does your facility’s SPCC Plan properly account for mobile refuelers?

In late 2006, the U.S. Environmental Protection Agency (EPA) revised its Spill Prevention, Control and Countermeasure (SPCC) Rule with the stated goal of easing compliance requirements for facilities that have relatively small oil storage capacity. Specifically, the agency granted mobile refuelers that operate exclusively within the bounds of non-transportation-related facilities an exemption from the following parts of its SPCC Rule:

  • Sections 112.8(c)(2) and (11) for petroleum oils
  • Sections 112.12(c)(2) and (11) for animal fats and vegetable oils.

These provisions require facilities to provide sized secondary containment systems in areas where mobile refuelers operate. Such systems must be large enough to contain the entire capacity of a mobile refueler’s largest compartment, with additional space for any precipitation that could be reasonably expected.

In 2008, the EPA extended the exemption from its sized secondary containment requirements to non-transportation-related tank trucks.

In a fact sheet describing the rule changes implemented in 2006, the EPA noted that the exemption described above does not apply to refuelers that are primarily used to store bulk quantities of oil in fixed locations, as these units are essentially acting as stationary containers. Likewise, portable bulk storage containers are subject to the sized secondary containment requirements during any period when they are stationary and not under the direct supervision and control of facility personnel.

Which units qualify as ‘mobile refuelers’ under EPA’s SPCC Rule?

The EPA defines a mobile refueler as a “a bulk storage container” that is either onboard or towed by a vehicle and is “designed or used solely to store and transport fuel” to or from:

  • Aircraft
  • Motor vehicles
  • Locomotive
  • Vessels
  • Ground service equipment
  • Other oil storage containers.

Examples of facilities where mobile refuelers are commonly found include:

  • Industrial sites
  • Airports
  • Military bases
  • Construction sites
  • Chemical complexes
  • Mining sites
  • Seaport terminals
  • Tank truck home bases.

Mobile refuelers operating at transportation-related facilities are subject to loading/unloading rack requirements and regulated by the U.S. Department of Transportation.

The EPA’s general secondary containment requirements

The EPA’s general secondary containment requirements – described in Section 112.7(c) of the SPCC Rule – still apply to all mobile refuelers, portable bulk storage containers and tank trucks at all times, as do the requirements associated with transferring oil from one container to another.

While the EPA’s general requirements do not set a specific standard for the size of secondary containment structures, they do stipulate that a system must be able to prevent spilled oil from escaping prior to cleanup. The SPCC Rule puts a particular emphasis on ensuring that discharges do not reach navigable waters or shorelines.

Section 112.7(c) states that “secondary containment may be either active or passive in design,” which means that facilities are not required to use measures such as enclosing the refueling unit’s area of operation with roll-over curbs. Having adequate spill kits and sorbent materials on hand, along with conducting regular inspections, should be sufficient for maintaining compliance with this part of the EPA’s SPCC Rule.