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SPCC requirements for transfer areas associated with exempt USTs

Gas stations typically are not subject to the SPCC Rule because completely buried storage tanks subject to 40 CFR Part 280 or 281 are exempt per §112.1(d)(4). However, a gas station would be subject to the SPCC Rule if it has more than 1,320 gallons of oil in aggregate above ground storage capacity (e.g., aboveground storage tanks containing gasoline or used motor oil). If a gas station is subject to the SPCC Rule because of its aboveground storage capacity, what requirements, if any, must the fuel pumps or dispensers connected to underground storage tanks (USTs) meet to be in compliance with the SPCC Rule?

Transfer areas, such as areas containing dispensers or other oil transfer equipment, associated with exempted USTs at an otherwise regulated SPCC facility are subject to the secondary containment requirements in §112.7(c). A transfer operation is one in which oil is moved from or into some form of transportation, storage, equipment, or other device, into or from some other or similar form of transportation, such as a pipeline, truck, tank car, or other storage, equipment, or device. Areas where oil is transferred but no loading or unloading rack is present are subject to §112.7(c), and thus appropriate containment and/or diversionary structures are required, which may include active containment such as response action or sorbent deployment. EPA does not require specifically-sized containment for transfer areas; however, containment size must be based on good engineering practice (§112.3(d)).

Additional information regarding transfer areas and general containment requirements can be found in Chapter 4 of the SPCC Guidance for Regional Inspectors, available at the following URL: