Analysis: EPA and Mobile Refuelers

Sarah Smith
Created: June 3, 2005

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.

One Alternative: Modular Containment

Modular Containment, a system offered through aviation consulting firm Madison Environmental Group, offers what it calls a cost-effective solution to secondary containment at airports. The Modular Containment system is installed into the existing ground surface (ramps, parking areas, swales, etc.) on the low side of the mobile fuel truck parking area - creating a spill containment zone.

The system includes removable panels that are constructed from materials which are fuel-resistant, weather-resistant, and flexible to withstand moderate impact from ramp operations like snow plowing. The panels are easily installed by a two-person crew and may be removed or relocated, if necessary, according to the company. The system is quick to install and adaptable to most areas. System options include high-visibility paint and reflective surfaces to increase visibility of the system in poor weather conditions, high traffic zones, or during nighttime operations.