Transfer Area vs. Loading/Unloading Rack Secondary Containment (SPCC Discussion)

Business has been very good this year at Witt O’Brien’s.  As a result, I’ve been traveling more and more. This week, due to severe weather in Houston and Louisiana, my schedule has been turned upside down with flight delays. That said, this week’s article is relatively short, as I’ve been limited on free time.

Do transfer areas and loading/unloading racks fall under the same secondary containment requirements?

First, here are their definitions under the Spill Prevention, Control, and Countermeasures (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).

Why is this such an important determination under the SPCC Plan rule?

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. 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. 

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.”

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.

Again, know the rules to ensure you construct proper facility controls and properly apply funds. Doing so will save money and possible issues with regulators.

Want to read more?  The current “bible” for all things to reference regarding SPCC regulations can be found in the EPA’s SPCC Guidance for Regional Inspectors website.

Need some compliance assistance with your SPCC Plan or just have a question? Email John Carroll ([email protected]), Associate Managing Director - Compliance Services at Witt O’Brien’s or reach him by phone at 281-320-9796.

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