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CALIF. ABOVEGROUND PETROLEUM CALIF. ABOVEGROUND PETROLEUM STORAGE ACT STORAGE ACT

SPILL PREVENTION, CONTROL & SPILL PREVENTION, CONTROL & COUNTERMEASURES (SPCC) PLANCOUNTERMEASURES (SPCC) PLANSan Bernardino County Fire DepartmentSan Bernardino County Fire Department

Business Assistance WorkshopBusiness Assistance WorkshopPresented byPresented by

Steven Lichten, REA, CPEASteven Lichten, REA, CPEAESCI EnviroServices, Inc.ESCI EnviroServices, Inc.4401 Atlantic Ave., Suite 2004401 Atlantic Ave., Suite 200

Long Beach, CA 90807Long Beach, CA 90807714714--322322--04700470

[email protected]@enviroservices.com

mailto:[email protected]

APSA & SPCC PLAN APSA & SPCC PLAN Business Assistance WorkshopBusiness Assistance Workshop

Sponsored and Coordinated bySponsored and Coordinated by

San Bernardino County San Bernardino County Fire DepartmentFire Department

Hazardous Materials Division Hazardous Materials Division

APSA/SPCC Plan Compliance PrimerAPSA/SPCC Plan Compliance Primer Slide Slide 33

Welcome and IntroductionsWelcome and Introductions

San Bernardino County Fire Department San Bernardino County Fire Department Hazardous Materials DivisionHazardous Materials Division

ESCI EnviroServices, Inc.ESCI EnviroServices, Inc.Steve LichtenSteve Lichten

YOU?YOU?SPCC PlansSPCC Plans…… have one? have one? ……need one? need one? ……unsure?unsure?

Oil Spill Prevention Oil Spill Prevention Staff Ready to ServeStaff Ready to Serve


HandoutsHandouts

PresentationPresentation

Sample SPCC Table of ContentsSample SPCC Table of Contents

Final SPCC Plan Template for Tier 1 Final SPCC Plan Template for Tier 1 Qualified FacilitiesQualified Facilities

Uncle SteveUncle Steve’’s Spinning Disk os Spinning Disk o’’KnowledgeKnowledge


Workshop GoalsWorkshop Goals

Provide you with information and Provide you with information and guidance to assist you to:guidance to assist you to:

Prepare or update an SPCC Plan or Plan Prepare or update an SPCC Plan or Plan Template:Template:•• Compliant with relevant regulationsCompliant with relevant regulations

•• Designed to be readily maintainableDesigned to be readily maintainable

•• Cost effective to prepare.Cost effective to prepare.

Implement an effective oil spill prevention Implement an effective oil spill prevention programprogram

Be in compliance with APSA and SPCC Be in compliance with APSA and SPCC regulations regulations


Topical OutlineTopical Outline

1.1. Calif. Aboveground Petroleum Storage Act Calif. Aboveground Petroleum Storage Act (APSA) Summary(APSA) Summary

2.2. Federal SPCC Rule Background Federal SPCC Rule Background 3.3. Applicability and Critical Definitions Applicability and Critical Definitions 4.4. SPCC Plan Basics (applicable to APSA tank SPCC Plan Basics (applicable to APSA tank

facilities)facilities)5.5. Secondary Containment and Secondary Containment and ‘‘ImpracticabilityImpracticability’’6.6. Inspection, Evaluation and Testing Inspection, Evaluation and Testing 7.7. Training and ProceduresTraining and Procedures8.8. Spill Planning, Notification & ResponseSpill Planning, Notification & Response9.9. Tools and ReferencesTools and References

Section 1Section 1

Calif. Aboveground Calif. Aboveground Petroleum Storage Act Petroleum Storage Act

(APSA) Summary(APSA) Summary


Calif. Aboveground Petroleum Storage Calif. Aboveground Petroleum Storage Act (APSA)Act (APSA) -- HSC HSC ChptChpt. 6.67. 6.67

AB1130 (Laird, 2007)AB1130 (Laird, 2007)Updated the 1990 APSAUpdated the 1990 APSA

Transfers APSA administration and enforcement Transfers APSA administration and enforcement from SWRCB to CUPAsfrom SWRCB to CUPAs

Applies to Applies to ‘‘tank facilitiestank facilities’’ with with >> 1,320 gal. 1,320 gal. petroleum storage capacity petroleum storage capacity

•• Several tank, content and/or facilitySeveral tank, content and/or facility--type exemptions type exemptions

Write and implement SPCC Plan consistent with Write and implement SPCC Plan consistent with 40 CFR 112:40 CFR 112:

If a federal SPCC Plan is requiredIf a federal SPCC Plan is requiredIf If >> 1,320 gal. of aboveground petroleum 1,320 gal. of aboveground petroleum storage capacitystorage capacity


Calif. APSA Calif. APSA -- HSC HSC ChptChpt. 6.67. 6.67

‘‘Tank facilitiesTank facilities’’ to submit an annual to submit an annual ‘‘Tank Facility Tank Facility StatementStatement’’

Essentially a list of Essentially a list of ‘‘tankstanks’’ and some other infoand some other infoTank facilities subject to APSA program fees Tank facilities subject to APSA program fees beginning Jan. 1, 2010beginning Jan. 1, 2010

SBCFD HMD must inspect tank facilities with over SBCFD HMD must inspect tank facilities with over 10,000 gal. petroleum capacity at least every three 10,000 gal. petroleum capacity at least every three yearsyears

NO impact on US EPA inspections/enforcement NO impact on US EPA inspections/enforcement Inspectors must be trained & certified first (~ mid 2009)Inspectors must be trained & certified first (~ mid 2009)

<10,000 gallon capacity facilities may be inspected as part <10,000 gallon capacity facilities may be inspected as part of routine CUPA program surveillance inspectionsof routine CUPA program surveillance inspections


APSA Fact Sheets, Guidance and FAQsAPSA Fact Sheets, Guidance and FAQsAPSA Fact SheetsAPSA Fact Sheets

Several guidance Several guidance documents (Fact Sheets documents (Fact Sheets and Bulletins) postedand Bulletins) posted

From December 2007From December 2007

Covers both APSA and SPCCCovers both APSA and SPCC

Will be updated over the Spring Will be updated over the Spring and Summer 2009and Summer 2009

Links to US EPA Oil Spill Links to US EPA Oil Spill Prevention Program websitePrevention Program website

Your # 1 source for federal Your # 1 source for federal SPCC guidance and latest SPCC guidance and latest informationinformation

FAQ postedFAQ posted

http://http://www.calepa.ca.govwww.calepa.ca.gov/CUPA/Aboveground//CUPA/Aboveground/

http://www.calepa.ca.gov/CUPA/Aboveground/


MayMay be periodically be periodically updatedupdated

APSA Fact Sheets, Guidance and FAQsAPSA Fact Sheets, Guidance and FAQsFrequently Asked Questions (FAQ) DocumentFrequently Asked Questions (FAQ) Document


US EPA Oil Spill / SPCC WebsiteUS EPA Oil Spill / SPCC Website

Section 2Section 2

Federal SPCC Rule Federal SPCC Rule Background Background


SPCC? I Thought It Was Only APSA!SPCC? I Thought It Was Only APSA!

Federal Federal SPCCSPCC

Calif. Calif. APSAAPSA

•• No navigable No navigable water riskwater risk

•• Wastewater Wastewater systemssystems

•• NonNon--petroleum oilspetroleum oils

•• OilOil--filled electrical filled electrical equipmentequipment

•• Oil production tanksOil production tanks

•• Farms/logging sitesFarms/logging sites

•• Construction sitesConstruction sites

•• Haz. waste facilities Haz. waste facilities

Joint Joint applicabilityapplicability


Basic Goals of SPCC Plans & RegulationsBasic Goals of SPCC Plans & RegulationsPurpose & Authority of 40 CFR 112Purpose & Authority of 40 CFR 112

1.1. Prevent (but prepare for) Prevent (but prepare for) oil spills into navigable oil spills into navigable waters and adjoining waters and adjoining shorelinesshorelines

NOTE: In Calif. NOTE: In Calif. –– Navigable Navigable waters includes the storm waters includes the storm drain systemdrain system

2.2. Control oil spills getting Control oil spills getting into navigable watersinto navigable waters

3.3. CleanClean--up oil spills that up oil spills that got into navigable waters got into navigable waters (the countermeasures)(the countermeasures)


Regulations & PlansRegulations & PlansPurpose & Authority of 40 CFR 112Purpose & Authority of 40 CFR 112

Ensures Ensures proactiveproactive measures measures are used to prevent and are used to prevent and control an oil discharge to control an oil discharge to navigable watersnavigable waters……

Less emphasis on Less emphasis on afterafter--thethe--fact or reactivefact or reactive measuresmeasures

SPCC rules require facilities to SPCC rules require facilities to prepareprepare and and implementimplementa a sitesite--specificspecific SPCC Plan to address three areas:SPCC Plan to address three areas:

Operating procedures and other administrative Operating procedures and other administrative measuresmeasuresContainment and other control measures Containment and other control measures Countermeasures and clean up measuresCountermeasures and clean up measures


Current Federal SPCC Compliance DatesCurrent Federal SPCC Compliance Dates

A facility starting operation…

Must…

On or before 8/16/02Maintain existing SPCC Plan.Amend and implement updated Plan no later than 7/1/09

After 8/16/02 through 7/1/09

Prepare and implement SPCC Plan no later than 7/1/09

After 7/1/09Prepare and implement Plan before beginning operations


SPCC Rule HistorySPCC Rule History

Dec. 1973 SPCC RuleDec. 1973 SPCC RuleAmendments in 1994 & 2000 Amendments in 1994 & 2000 Major amendment in July 2002 Major amendment in July 2002

Various lawsuitsVarious lawsuits…… settled in March 2004 settled in March 2004 May 2004 Federal Register Notice re settlementsMay 2004 Federal Register Notice re settlements

Dec. 2006 Rule Amendment Dec. 2006 Rule Amendment May 2007 Rule Extension May 2007 Rule Extension Dec. 2008 Rule AmendmentDec. 2008 Rule Amendment

Effective April 4, 2009Effective April 4, 2009

Section 3Section 3

SPCC and APSA SPCC and APSA Applicability Applicability (& critical definitions)(& critical definitions)


Applicability Applicability (APSA Exemptions)(APSA Exemptions)

FacilityFacility types excluded from APSA:types excluded from APSA:Construction Construction sitessites, nurseries, farms and , nurseries, farms and logging siteslogging sites

< < 20K gal. per tank / 20K gal. per tank / << 100K gal. aggregate100K gal. aggregate

•• Tank Facility Statement and fees still applicableTank Facility Statement and fees still applicable•• Conditionally Conditionally APSAAPSA--excludedexcluded from SPCC Plan from SPCC Plan

requirementrequirementSTILL federally (US EPA) regulated! STILL federally (US EPA) regulated!

Must conduct daily inspectionsMust conduct daily inspectionsMust allow CUPA to inspect Must allow CUPA to inspect Secondary containment may be required by Secondary containment may be required by CUPACUPA


Applicability Applicability (APSA Exemptions)(APSA Exemptions)

TankTank types excluded from APSA:types excluded from APSA:•• These tanks are not CUPA regulated under These tanks are not CUPA regulated under

APSAAPSADo not count for 1,320 gal. facility capacity Do not count for 1,320 gal. facility capacity thresholdthresholdCUPA does not inspect under APSA (except to CUPA does not inspect under APSA (except to verify)verify)

•• but ARE still US EPA regulatedbut ARE still US EPA regulatedCUPACUPA--regulated USTs regulated USTs Most oilMost oil--filled electrical equipmentfilled electrical equipmentCrude oil production tanksCrude oil production tanksBoilers & pressure vesselsBoilers & pressure vesselsWaste oil tanks covered under PBR Tiered Permit Waste oil tanks covered under PBR Tiered Permit and at DTSC permitted hazardous waste facilitiesand at DTSC permitted hazardous waste facilities


Underground Storage TanksUnderground Storage Tanks

SBCFDSBCFD--regulated USTsregulated USTsExempt from APSAExempt from APSA

US EPA SPCC exempt US EPA SPCC exempt onlyonlyif if ‘‘completely buriedcompletely buried’’


OilOil--Filled Electrical EquipmentFilled Electrical EquipmentAPSA exempt (conditionally)APSA exempt (conditionally)

Still US EPA SPCC regulatedStill US EPA SPCC regulated

Includes:Includes:Transformers, circuit breakers, or capacitorsTransformers, circuit breakers, or capacitors

APSA exempt if the oilAPSA exempt if the oil--filled electrical equipment meets filled electrical equipment meets either of the following conditions:either of the following conditions:

Contains Contains << 10,000 gallons of dielectric fluid10,000 gallons of dielectric fluid

Contains Contains >> 10,000 gallons of dielectric fluid, and10,000 gallons of dielectric fluid, and•• PCB concentration is < 50 PPM PCB PCB concentration is < 50 PPM PCB •• Appropriate containment or diversionary structures or Appropriate containment or diversionary structures or

equipment are employed, and equipment are employed, and •• The electrical equipment is visually inspected in The electrical equipment is visually inspected in

accordance with the owner/operatoraccordance with the owner/operator’’s usual routine s usual routine maintenance procedures maintenance procedures


Same contentsSame contents

OilOil--Filled Electrical Filled Electrical EquipmentEquipment


Applicability Applicability (APSA)(APSA)

1.1. Federally regulated SPCC facilitiesFederally regulated SPCC facilities…… unless:unless:APSA exempt or excludedAPSA exempt or excluded<< 1,320 gallons of petroleum storage capacity1,320 gallons of petroleum storage capacity

2.2. ‘‘NonNon--transportationtransportation’’ facilitiesfacilities storing, transferring, storing, transferring, refining, distributing, processing, consuming or refining, distributing, processing, consuming or using using petroleumpetroleum…… and and combined storage combined storage capacitycapacity of of >> 1,320 gallons above ground1,320 gallons above ground

•• Even temporarilyEven temporarily

In tanks In tanks >> 55 gal55 gal•• ““TanksTanks”” includes tanks, totes, containers, oilincludes tanks, totes, containers, oil--

filled operational and manufacturing equipment, filled operational and manufacturing equipment, and nonand non--transportation tank truckstransportation tank trucks


APSA Oil: PetroleumAPSA Oil: Petroleum

Aviation gasoline and Aviation gasoline and additives additives Jet fuel and additives Jet fuel and additives Motor gasoline and additives Motor gasoline and additives (NOT (NOT purepure biofuels) biofuels) Diesel fuel and additives,Diesel fuel and additives,Gas turbine fuel oils;Gas turbine fuel oils;Lubricating oils (including Lubricating oils (including waste oils);waste oils);Mineral oilsMineral oilsHeating and illuminating oils Heating and illuminating oils (fuel oils, kerosene); (fuel oils, kerosene);

Petroleum solventsPetroleum solventsPetroleum and mineral spirits Petroleum and mineral spirits HighHigh--flash aromatic flash aromatic naphthasnaphthasVM&P and high flash VM&P and high flash naphthasnaphthasPetroleum extender oilsPetroleum extender oilsGreasesGreasesPetroleum containing soluble Petroleum containing soluble cutting & metalworking fluidscutting & metalworking fluidsLPG & natural gas is NOT LPG & natural gas is NOT includedincluded

Crude oil, or any fraction thereof, which is Crude oil, or any fraction thereof, which is liquid at 60liquid at 60ooF & normal atmospheric pressureF & normal atmospheric pressure


ApplicabilityApplicability (Federal)(Federal)……

1.1. ‘‘NonNon--transportationtransportation’’ facilitiesfacilities producing, storing, producing, storing, transferring, refining, distributing, processing, transferring, refining, distributing, processing, consuming or using consuming or using oil or oil productsoil or oil products…… andand

2.2. Combined storage Combined storage capacitycapacity of > 1,320 gallons of > 1,320 gallons above groundabove ground…… andand

In systems/equipment/tanks/containers In systems/equipment/tanks/containers >> 55 gal55 galCompletely buried, state compliant USTs Completely buried, state compliant USTs exempted (but must be identified on site map)exempted (but must be identified on site map)

3.3. Might reasonably be expected to discharge oil in Might reasonably be expected to discharge oil in ‘‘harmful quantitiesharmful quantities’’ into into navigable watersnavigable waters•• Storm drain = Storm drain = NavNav WaterWater


A Few Quick Important DefinitionsA Few Quick Important Definitions

Petroleum vs. oilPetroleum vs. oil

FacilityFacility

Transportation vs. nonTransportation vs. non--transportationtransportation

CapacityCapacity

Permanently closedPermanently closed

Tanks, containers, & equipmentTanks, containers, & equipment


US EPA Oil Broader than APSA PetroleumUS EPA Oil Broader than APSA Petroleum

APSA: Petroleum onlyAPSA: Petroleum only

US EPA (federal) SPCC US EPA (federal) SPCC Oil:Oil: Oil of any kindOil of any kind……including petroleum, including petroleum, mineral, synthetic, animal, mineral, synthetic, animal, vegetable, fatsvegetable, fats


APSA APSA ‘‘FacilityFacility’’FacilityFacility

APSA definition of APSA definition of Tank Facility: Tank Facility: •• more specific than US EPAmore specific than US EPA’’ss

•• Own Own OROR operate operate >>1,320 gal. petroleum 1,320 gal. petroleum storage capacity at a storage capacity at a single sitesingle site

In tanks/containers In tanks/containers >> 55 55 gal. capacitygal. capacity

•• Different owners or Different owners or operators could result operators could result in multiple regulated in multiple regulated ‘‘tank facilitiestank facilities’’ on one on one sitesite


Transportation vs. NonTransportation vs. Non--Transportation?Transportation?

Facilities are divided into three categories:Facilities are divided into three categories:•• Established through series of Executive Orders (EOs) and MemoranEstablished through series of Executive Orders (EOs) and Memoranda da

of Understanding (MOUs) among EPA & DOTof Understanding (MOUs) among EPA & DOT

1.1. TransportationTransportation--related facilities related facilities 2.2. NonNon--transportationtransportation--related facilitiesrelated facilities3.3. Complexes (both elements at one facility)Complexes (both elements at one facility)

Look at it (mostly) by equipment and Look at it (mostly) by equipment and activity performed by that equipmentactivity performed by that equipment…… notnotwhole whole ‘‘facilityfacility’’•• Impact: A) what counts toward the 1,320 gal. facility Impact: A) what counts toward the 1,320 gal. facility

capacity threshold, B) what equipment is regulated by capacity threshold, B) what equipment is regulated by APSA, and C) what equipment must be included in the APSA, and C) what equipment must be included in the SPCC PlanSPCC Plan


Transportation Related Transportation Related (DOT regulated(DOT regulated…… not APSA or US EPA)not APSA or US EPA)

Transportation Related Transportation Related (DOT)(DOT)

Highway vehicles and railroad cars that Highway vehicles and railroad cars that are being used are being used for the transportfor the transport of petroleumof petroleum

Interstate and intrastate onshore and offshore Interstate and intrastate onshore and offshore pipeline systems (regulated by DOT)pipeline systems (regulated by DOT)

Operations and equipment Operations and equipment actively engaged in actively engaged in transportation related activitiestransportation related activities


Transportation vs. NonTransportation vs. Non--TransportationTransportation

NonNon--TransportationTransportationAPSA/SPCC regulatedAPSA/SPCC regulated

•• Loading racks, transfer hoses, loading Loading racks, transfer hoses, loading arms, and other equipment used to arms, and other equipment used to transfer petroleum in bulk transfer petroleum in bulk to or fromto or fromhighway vehicles or railroad carshighway vehicles or railroad cars

TransportationTransportationNotNot APSA/SPCC regulated APSA/SPCC regulated

•• The vehicles or cars themselves (The vehicles or cars themselves (unlessunlessparked & not loading/unloading)parked & not loading/unloading)

Bulk Loading RacksBulk Loading Racks


Transportation and NonTransportation and Non--TransportationTransportation

NonNon--transportationtransportation•• Loading areas, transfer hoses, Loading areas, transfer hoses,

associated tanks and equipment associated tanks and equipment used to transfer petroleum in bulk used to transfer petroleum in bulk to or fromto or from highway vehicles or highway vehicles or railroad carsrailroad cars

TransportationTransportation•• The vehicles or cars themselves The vehicles or cars themselves

((unlessunless parked & not loading or parked & not loading or unloading)unloading)

Loading areas and loading Loading areas and loading racks racks AREARE regulated under regulated under APSA APSA •• But loading But loading ‘‘racksracks’’ and loading and loading

‘‘areasareas’’ have different secondary have different secondary containment criteria containment criteria (more on this (more on this later)later)

Bulk Loading AreasBulk Loading Areas


NonNon--Transportation Related Transportation Related (APSA and US EPA regulated)(APSA and US EPA regulated)

NonNon--Transportation RelatedTransportation RelatedVehicles, railroad cars, and Vehicles, railroad cars, and pipelines used to transport or pipelines used to transport or handle petroleum primarily handle petroleum primarily within within the facilitythe facility

NonNon--transportation: e.g. petroleum tanker transportation: e.g. petroleum tanker trucks or tank cars staged or parked trucks or tank cars staged or parked overnight at the site or when used overnight at the site or when used primarily for onprimarily for on--site storage or transfer site storage or transfer activities activities


1,320 Gal. Aggregate Facility Capacity1,320 Gal. Aggregate Facility Capacity55 Gal. per Container Storage Capacity55 Gal. per Container Storage Capacity

Petroleum Storage CapacityPetroleum Storage Capacity•• Remember Remember >> 1,320 gallons aggregate facility 1,320 gallons aggregate facility

capacity counting 55 gal & larger containers?capacity counting 55 gal & larger containers?

Count the Count the shellshell capacity of a tank or capacity of a tank or containercontainer•• Does not matter the actual volume being storedDoes not matter the actual volume being storedShell capacity is rated design capacity rather than Shell capacity is rated design capacity rather than the working/operational capacitythe working/operational capacity•• e.g. e.g. ‘‘54 gal.54 gal.’’ drum drum

will hold up to 60 gal.will hold up to 60 gal.

< 55 gal.?< 55 gal.?Not included Not included in SPCC Planin SPCC Plan


Permanently Closed vs. EmptyPermanently Closed vs. EmptyDo you count it (and include it in the SPCC Plan) if it is emptyDo you count it (and include it in the SPCC Plan) if it is empty? ? Yes.. Unless Yes.. Unless ‘‘permanently closedpermanently closed’’

Permanently ClosedPermanently ClosedRemove all liquid and sludge from each container Remove all liquid and sludge from each container and connecting line and connecting line Disconnect and blank off all connecting lines and Disconnect and blank off all connecting lines and piping piping Close and lock all valves (except ventilation valves)Close and lock all valves (except ventilation valves)Post a conspicuous sign on each container stating it Post a conspicuous sign on each container stating it is permanently closed with the date of closingis permanently closed with the date of closing

Tanks can remain on site, but they are not Tanks can remain on site, but they are not included in the total storage capacity or the included in the total storage capacity or the SPCC PlanSPCC Plan


Permanently Closed Permanently Closed Containers?Containers?


Tanks & Containers & Equipment, Oh My!Tanks & Containers & Equipment, Oh My!

US EPAUS EPA’’s SPCC rules uses s SPCC rules uses the term the term ‘‘containercontainer’’ very very broadly broadly –– can mean tanks can mean tanks or containers (drums)or containers (drums)

Separate terms for oilSeparate terms for oil--filled filled equipmentequipment

APSA uses the term APSA uses the term ‘‘tanktank’’very broadly very broadly –– can mean can mean tanks, containers and oiltanks, containers and oil--filled equipmentfilled equipment

Important to understand types of Important to understand types of ‘‘tankstanks’’::Specific SPCC requirements for secondary Specific SPCC requirements for secondary containment or discharge prevention, and integrity containment or discharge prevention, and integrity testing vary by testing vary by ‘‘tanktank’’ typetype


Tanks & Containers & Equipment Regulated by APSA & Tanks & Containers & Equipment Regulated by APSA & US EPA SPCC RuleUS EPA SPCC Rule

Bulk tanks & containers Bulk tanks & containers –– fixed (nonfixed (non--portable)portable)Field constructedField constructedShop fabricatedShop fabricated

Bulk tanks and containers Bulk tanks and containers –– portable/mobileportable/mobileOil filled equipmentOil filled equipment

Oil filled operational equipmentOil filled operational equipmentOil filled manufacturing equipmentOil filled manufacturing equipmentOil filled electrical equipmentOil filled electrical equipment•• Oil filled electrical equipment conditionally APSA excluded Oil filled electrical equipment conditionally APSA excluded

Mobile refuelers and other nonMobile refuelers and other non--transportation transportation related tank trucksrelated tank trucksOil handling areasOil handling areas

Loading areas, handing areas, piping, etc.Loading areas, handing areas, piping, etc.


Bulk Tanks & Bulk Tanks & Containers (fixed)Containers (fixed)


Bulk Tanks & Containers Bulk Tanks & Containers (fixed)(fixed)


Bulk Tanks & Containers Bulk Tanks & Containers (mobile/portable)(mobile/portable)


OilOil--Filled Operational & Manufacturing Filled Operational & Manufacturing EquipmentEquipment…… are APSA are APSA ‘‘tankstanks’’

Examples of oil filled operational Examples of oil filled operational equipmentequipment

Hydraulic systems, lubricating systems, gear Hydraulic systems, lubricating systems, gear boxes, machining coolant systems, heat boxes, machining coolant systems, heat transfer systems, flowtransfer systems, flow--through processthrough processvesselsvessels

Examples of oil filled manufacturing Examples of oil filled manufacturing equipmentequipment

Reaction vessels, Reaction vessels, fermentorsfermentors, high pressure , high pressure vessels, mixing tanks, dryers, heat vessels, mixing tanks, dryers, heat exchangers, and distillation columnsexchangers, and distillation columns


OilOil--Filled Operational & Filled Operational & Manufacturing EquipmentManufacturing Equipment


Wastewater Systems: Fed. SPCC excluded Wastewater Systems: Fed. SPCC excluded but IN APSA!but IN APSA!


Mobile Refuelers & Other NonMobile Refuelers & Other Non--Transportation Transportation Related Tank TrucksRelated Tank Trucks

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