COMPLIANCE INFO_2022 - Laserfiche WebLink

Home Browse Search

SAVAGE office where order paperwork is processed and they are directed to the designated railcar for transfer of the material, or (2) if the nature of the product being transloaded does not require a light/tare weight (e.g.fuels that are metered into trucks instead of weighed into trucks)the driver reports to Savage's office where order paperwork is processed and they are directed to the designated railcar for transfer of the material. Savage team members meet the truck driver at the designated railcar for the transfer, confirm the order and quantity, and complete the transfer of the product from the railcar to the trailer using a mobile rack (See Figure 3). At the conclusion of the transfer, the trailer is weighed for gross and net weights (if applicable), the driver is issued a bill of lading, and they depart to their destination to deliver the product to the customer. The actual transfer of a single truckload of a bulk product from a railcar to a truck takes on average about one hour. Savage currently transfers an average of ten truckloads of bulk products per day (total truckloads for all products combined), however, we see this increasing in the months ahead. REGULATORY DISCUSSION Savage's position is that the railcars and trucks involved in the transportation of petroleum products that pass through our facility are solely regulated by the DOT. Following are some references that support this position: 1971 Memorandum of Understanding between DOT and EPA - Federal Register, Volume 36, No. 244 12/18/1971 (See Attachment 1) This document distinguishes between "non-transportation—related onshore and offshore facilities" and "transportation-related onshore and offshore facilities." Non-transportation related facilities that exceed the SPCC storage threshold are generally subject to SPCC regulations while transportation related facilities are not. Section II(2)(D) defines "transportation related onshore and offshore facilities" as: "highway vehicles and railroad cars which are used for the transport of oil in Interstate or intrastate commerce and rites-of-way on which they operate. Excluded are highway vehicles and railroad cars and motive power used exclusively within the confines of a non transportation related facility or terminal facility and which are not intended for use in Interstate or intrastate commerce." Savage considers the Stockton facility as a transportation related facility that provides a transportation related service that transfers petroleum products from a regional mode of transport(rail)to a local mode of transportation for delivery to the end user(trucks). SPCC Guidance for Regional Inspectors, EPA Office of Emergency Management—December of 2013 This document provides guidance to EPA inspectors, to owners and operators of facilities that may be subject to the requirements of the SPCC rule (40 CFR Part 112), and to the general public on how EPA intends the SPCC rule to be implemented. The guidance is designed to facilitate nationally-consistent implementation of the SPCC rule. Savage Services Corporation 0 901 W. Legacy Center Way 0 Midvale, Utah 84047 0 801-944-6600 0 www.savageservices.com