Analysis: EPA and Mobile Refuelers

Meeting the challenge of mobile fuel truck spill containment requires careful consideration in order to develop a system that is cost-effective and suitable for the current and future operations of a facility.

Section 112.7(h)(1) of the final SPCC rule requires that containment for a facility tank car and tank truck loading/unloading rack (excluding off-shore facilities) must be designed to hold at least the maximum capacity of any single compartment of a tank car or tank truck loaded or unloaded at the facility. For a single tank, installing spill containment would be cost-prohibitive and unnecessary - not to mention the absence of a load rack.

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