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Are mobile refuelers exempt from integrity testing requirements?

Pursuant to 40 CFR §112.8(c)(2), mobile refuelers are exempt from the secondary containment requirements for bulk storage containers.  Are mobile refuelers also exempt from the requirements for integrity testing in §112.8(c)(6)?

Since mobile refuelers are mobile or portable bulk storage containers, the other provisions of §112.8(c) still apply.  Therefore, mobile refuelers are still subject to the integrity testing requirements in §112.8(c)(6).  While EPA does not require the use of a specific method for conducting integrity testing of bulk storage containers and allows facilities to rely on industry standards and good engineering practice, the facility owner or operator should reference in the Plan the standard used to test the mobile refueler.  For example, the United States Department of Transportation (DOT) regulates containers used to transport hazardous materials, including oil products, and requires certain construction and continuing qualification and maintenance requirements.  These DOT requirements may be used as references of good engineering practice for assessing the fitness for service of mobile or portable containers.  Although mobile refuelers are not subject to the secondary containment requirements of §112.8(c)(2) for bulk storage containers, they remain subject to the general secondary containment requirements of §112.7(c) and therefore must have appropriate containment and/or diversionary structures to prevent a discharge to navigable waters or adjoining shorelines.