SPCC - Rail Rack Specific Containment
SPCC - Rail Rack Specific Containment
(OP)
I'm searching for a definitive answer to an issue surrounding rail car loading racks and secondary containment. Short story is this: a facility has a permanent rail car loading rack system. Below the tracks is gravel that is sloped toward a drainage ditch. The ditch leads to an oil water separator and the total capacity of the ditch/pipe network and OWS system is greater than the largest rail car. The gravel is on top of what I would deem a "sufficiently impervious" clay layer. But of course the grave itself is not sufficiently impervious.
Question is, does this meet the specific secondary containment required by the SPCC reg 112.7(h). I understand that drip pans and a basin/tank would've been ideal but the yard is built and a retrofit would be massive capital outlay.
Question is, does this meet the specific secondary containment required by the SPCC reg 112.7(h). I understand that drip pans and a basin/tank would've been ideal but the yard is built and a retrofit would be massive capital outlay.





RE: SPCC - Rail Rack Specific Containment
This is discussed on page 4-22. "In summary, any of the owner/operator's determinations specifying whether secondary containment structures are capable of containing oil until it is cleaned up ("sufficiently impervious") should be made based on good engineering practice and may consider site-specific factors."
Section 112.7(c) states that the entire secondary containment system, "including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system ... will not escape containment before cleanup occurs." With respect to bulk storage containers at onshore facilities (except production facilities), §§112.8(c)(2) and 112.12(c)(2) state that diked areas must be "sufficiently impervious to contain oil." The purpose of the secondary containment requirement is to prevent discharges as described in §112.1(b); therefore, effective secondary containment methods must be able to contain oil until the oil is cleaned up. EPA does not specify permeability or retention time performance criteria for these provisions.
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SPCC regulations do not mandate design specifications, rather, they are performance based. Therefore, a containment wall may be of any construction type, material, or design, assuming it meets the performance standards and requirements of Part 112. Regional offices can help determine whether individual containment equipment meets the performance standards of Part 112.
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RE: SPCC - Rail Rack Specific Containment
What does your SPCC plan state?
RE: SPCC - Rail Rack Specific Containment
RE: SPCC - Rail Rack Specific Containment
RE: SPCC - Rail Rack Specific Containment
Not that expensive and clean up should be relatively easy!!
A dollar now - ten dollars later!!!