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CFR section 112.1(b)(3), SPCC regulations apply to "Any container that is used for standby storage, for seasonal storage, or for temporary storage, or not otherwise "permanently closed" as defined in § 112.2;" CFR section 112.8, which are the regulations for bulk storage containers, under subsection (c)(11) Position or locate mobile or portable oil storage containers to prevent a discharge as described in § 112.1(b). Except for mobile refuelers and other non-transportation-related tank trucks, you must furnish a secondary means of containment, such as a dike or catchment basin, sufficient to contain the capacity of the largest single compartment or container with sufficient freeboard to contain precipitation. Since the 55 gallon drums are bulk storage containers, per definition under CFR section 112.2 (...any container used to store oil. ...) the drums must meet the requirements of the SPCC regulations. The SPCC Guidance for Regional Inspectors from December 16, 2013.The document can be found here. Page 2-11 SPCC facilities include not only permanent facilities with fixed storage and equipment, but also those that have only standby, temporary, and seasonal storage as described under§112.1(b)(3), as well as construction facilities. Page 2-37 Under§112.1(b)(1)through (4),the rule is applicable to eligible facilities that have oil in aboveground containers; completely buried tanks; containers that are used for standby storage,for seasonal storage, or for temporary storage, or are not otherwise "permanently closed;" and "bunkered tanks" or"partially buried tanks" or containers in a vault. Containers include not only oil storage tanks, but also mobile or portable containers such as drums and totes, and oil-filled equipment such as electrical equipment (e.g., transformers, circuit breakers), manufacturing flow-through process equipment, and operational equipment. Under§112.1(d)(2)the rule limits the applicability to facilities with oil capacity above specific threshold amounts. FREE classes presented by NES Inc. are available to all San Joaquin County Hazardous Waste, Underground Storage Tank, and Aboveground Petroleum Storage Facility Business Owners and Operators. List and schedule of classes can be found here. Thank you, Cesar Ruvalcaba San Joaquin County Environmental Health Department Environmental Health Specialist 1868 East Hazelton Ave Stockton, CA 95205 2 (209) 953-62131 A (209) 464-01381 2 cruvalcaba@sicehd.com g W SAN JOAQUIN C0UNTY— r Greatness grows here. 4