The revised SPCC Rule (40 CFR 112) clarified a few points in regards to mobile tanks. First, the Rule clarified that tanks on vehicles used to hold fuels and operating fluids required to operate the vehicle are not intended to be included under the SPCC requirements. Typical mobile refueling equipment would have two types of fuel storage –a fuel tank for operation of the engine, and a storage tank used to move fuel around the facility. Under the revised Rule, the engine’s fuel tank (i.e., “motive fuel container”) would not be included under an SPCC Plan; however, the bulk fuel tank the vehicle carries would be included.
The bulk fuel tank on the refueling vehicle would normally require the same spill protections that other containers need. However, the revised SPCC Rule clarified that these refueling vehicles are exempted from some SPCC requirements. Specifically, the revision exempts mobile refueling vehicles from the requirements to have a sized secondary containment structure.
However, when this equipment (included towed equipment) is placed or stored in a designated area of the site, that area must have the required secondary containment.
Caltha LLP provides expert technical support to facilities and/or consulting engineers on compliance with SPCC Rules. Caltha maintains a library of SPCC Plan templates to match site-specific needs.
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