How might determining impracticability under §112.7(d) affect a facility's FRP requirements under Part 112 Subpart D?
Pursuant to 40 CFR §112.7(d), if a facility owner or operator finds that secondary containment methods are not practicable, the SPCC Rule allows for alternative modes of protection to prevent and contain oil discharges if additional requirements are met. How might determining impracticability under §112.7(d) affect a facility’s FRP requirements…