SPCC - Rail Rack Specific Containment 1

[hhes]

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.

 

[bimr]

You can make the case for your proposal. However, should you have a spill, note that the Act requires that residual substances be removed, within 15 days, from the ground or affected waters. So cleanup costs may be excessive.

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.

http://www.epa.gov/oem/docs/oil/spcc/guidance/4_SecondaryContainment_Impracticability.pdf

http://emergencymanagement.supportp...nt-wall-be-constructed-out-of-concrete-blocks

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.

http://emergencymanagement.supportportal.com/link/portal/23002/23016/Article/19898/

 

[chicopee]

what would the expected type and volume of a release be? If an oil release, the clay and gravel can be removed for treatment. If a lighter component such as gasoline or solvents, the composition of the ditch may not be enough to contain the spill and would need to be made impervious with a liner or concrete coated with a sealing compound compatible with the release.
What does your SPCC plan state?

 

[hhes]

The SPCC is being revised. The previous plan didn't really take these issues into consideration. This location moves a lot of different chemicals. No gasoline, but it does handle ethanol.

 

[chicopee]

How is the material unloading from the railroad cars?

 

[MiketheEngineer]

For the health and welfare of all concerned - including me - please make the catch basin and containment IMPERVIOUS.

Not that expensive and clean up should be relatively easy!!

A dollar now - ten dollars later!!!