Double-Walled Tanks and SPCC/OPA90 Plan Secondary Containment
CFR received an interesting call from one of our air clients regarding a U.S. EPA SPCC inspection at one of the company’s rail car biodiesel off-loading stations. The company off-loads rail cars into two portable “frac” tanks, each with a 10,000-gallon capacity. The company had hired a local consultant to prepare a SPCC Plan for this operation. The local consultant did not believe that the double-walled frac tanks met the secondary containment requirements of 40 CFR Part 112.