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SAVAGE <br /> Section 2.5.2 of the guidance (see Attachment 2) delineates regulatory responsibility for railroad cars and <br /> is consistent with the 1971 memorandum referenced above. Section 2.5.2 states: <br /> "DOT regulates railroad cars used for the transport of oil in interstate or intrastate <br /> commerce and the related equipment and appurtenances. DOT jurisdiction includes <br /> railroad cars that are passing through a facility or are temporarily stopped on a normal <br /> route. EPA regulates railroad cars under the SPCC rule if they are operating exclusively <br /> within the confines of a non-transportation-related facility. EPA regulates both transfers <br /> to or from railroad cars and when the railroad cars serve as non-transportation-related <br /> storage at an SPCC-regulated facility. <br /> When the railcar is serving as non-transportation-related storage, if the railroad car has a <br /> storage capacity above the regulatory threshold amount of oil, and there is a reasonable <br /> expectation of discharge to navigable waters or adjoining shorelines, the railroad car itself <br /> may become a non-transportation-related facility, even if no other containers at the <br /> property would qualify it as an SPCC-regulated facility." <br /> Savage does not engage in non-transportation related storage of full railcars or trucks. Petroleum products <br /> passing through the site are never onsite longer than is necessary to coordinate the transfer of products <br /> and delivery of the product to customers. <br /> Furthermore, petroleum products located at a "U.S. Department of Transportation (US DOT) regulated <br /> transportation-related tank facility" are specifically exempt from the requirements of the California APSA <br /> under CA HSC Section 25270.2(a)(1)through (a)(8). <br /> CONCLUSIONS <br /> Savage believes that the petroleum transloading activities that take place at our Stockton facility serve a <br /> critical role in the transportation of petroleum products.We provide the final transfer in the supply chain <br /> that allows the petroleum products and other commodities to reach their local end user. We believe the <br /> transloading activities associated with the Operation are subject to DOT requirements and not the <br /> requirements of the federal SPCC rule or the State of California APSA. <br /> Should you agree with our assessment, please provide us with a written or emailed response for our <br /> records. Should you have any questions or concerns,we are happy to discuss further. <br /> Best regards, <br /> Li■ �J-1 ► J <br /> William Kaiser <br /> Environmental Director <br /> Savage Services Corporation 0 901 W. Legacy Center Way 0 Midvale, Utah 84047 0 801-944-6600 0 www.savageservices.com <br />