Transfer Area vs. Rack Secondary Containment (SPCC Discussion)

Today’s article is not a new one; however, as with many topics I write about this is certainly one that pops up quite frequently. Frequently enough to warrant revisiting every couple of years, anyway. Over the course of the last three weeks I have assisted one of our clients with this conversation across several of their assets and it has popped up in one of our internal meetings as well.

I’m speaking to loading/unloading racks verse transfer areas containment requirements at an Environmental Protection Agency (EPA) Spill Prevention, Control, and Countermeasures (SPCC) Plan regulated facility.

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Witt O'Brien's will be hosting Troy Swackhammer, Mark Howard and Chris Perry, EPA Region SPCC Plan and Facility Response Plan (FRP) Coordinator in Houston for an all-day Free SPCC Plan and FRP workshop. Click here to RSVP.

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Setting the tone: Do transfer areas and loading/unloading racks fall under the same secondary containment requirements under the SPCC Rule?

Firstly, here are their definitions of how these two areas differ under the SPCC Plan rule:

Loading/unloading rack means a fixed structure (such as a platform, gangway) necessary for loading or unloading a tank truck or tank car, which is located at a facility subject to the requirements of this part. A loading/unloading rack includes a loading or unloading arm, and may include any combination of the following: piping assemblages, valves, pumps, shut-off devices, overfill sensors, or personnel safety devices.

Transfer area means a transfer operation in which oil is moved from or into some form of transportation, storage, equipment, or other device, into or from some other or similar form of transportation, such as a pipeline, truck, tank car, or other storage, equipment, or device (67 FR 47130, July 17, 2002).

This is an important determination under the SPCC Plan rule because areas classified as loading/unloading racks require sized secondary containment. The secondary containment must be able to hold at least the maximum capacity of any single compartment of a tank car or tank truck loaded or unloaded at the facility. An interesting note, the SPCC rule does not require that secondary containment for loading/unloading racks be designed to include freeboard for precipitation as is required for tank sized secondary containment.

The freeboard discussion generally causes a lot of confusion as for the most part we are taught under the rule everything outside must account for precipitation. Where this conversation can get really blurry is when a rail rack that has numerous rail cars that are decoupled from the rail engine. What many don’t realize is these decoupled rail cars more than likely are now considered bulk storage tanks.

EPA views rail cars that are decoupled and positioned at an EPA regulated facility as bulk storage for the facility and not exempt by the Department of Transportation (DOT) exemptions. As most rail racks aren’t independent from the rail spur one would be looking at containment now for the largest rail car (click here to read what the EPA considers a containers volume) plus precipitation and would account for the entire area; thus, canceling out the less stringent requirement of the rack with regards to not having to account for precipitation. In this scenario, you should look for the more stringent requirement. If the rail car conversation raises an eyebrow then read more information here to learn more on this sensitive discussion.

On the other hand, transfer areas require general secondary containment. General secondary containment, unlike the sized containment noted above, must be based on the typical failure mode and most likely quantity of oil that would be discharged. To learn more about how to calculate general containment requirements, read my article on “Containment for Oil-Filled Operational Equipment.” General containment can be satisfied with active measures like sorbents and spill pads if they can contain the determined spill amount. You can also use static (passive) containment which is built to hold the typical failure mode and most likely quantity of oil that would be discharged. As you can see, there is a lot more flexibility at transfer areas and less containment requirements.

Note, some states like Louisiana under their Rule 33-Chapter 9, require sized containment for both activities, so be mindful of your state and local rules as you construct your facilities and develop your SPCC Plans. Most importantly, know the rules to ensure you construct proper facility controls and properly apply funds. Doing so will save money and possible issues with regulators.

For a complete listing of archived blogs and compliance insights, click here. Past blogs cover training requirements, clarification on additional confusing elements within the above rules, and much more.

We are here to help solve your compliance questions and challenges. Need some compliance assistance, or just have a question? Please email John K. Carroll III (jcarroll@wittobriens.com) Associate Managing Director – Compliance Services or call at +1 281-320-9796.

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