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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br /> WASHINGTON, D.C. 20460 <br /> PAW' <br /> OFFICE OF <br /> SOLID WASTE AND EMERGENCY RESPONSE <br /> MEMORANDUM <br /> SUBJECT: Use of Alternative Secondary Containment Measures at Facilities Regulated <br /> under the Oil Pollution Prevention Regulation (40 CFR Part 112) <br /> FROM: <br /> Assistant Administrator <br /> TO: Director, Environmental Services Division <br /> Regions I, VI, VII <br /> Director, Emergency and Remedial Response Division <br /> Region II <br /> Director, Hazardous Waste Management Division <br /> Regions III, IX <br /> Director, Hazardous Waste Division <br /> Region X <br /> PURPOSE <br /> This memorandum addresses the U.S. Environmental Protections Agency's (EPA) <br /> interpretation of the term"secondary containment" as it is used in section 112.7 (c) of the <br /> Oil Pollution Prevention regulation (40 CFR Part 112), also known as the Spill <br /> Prevention Control and Countermeasures (SPCC)regulation. It also addresses <br /> technologies that may be used to provide secondary containment for smaller, shop- <br /> fabricated aboveground storage tanks (ASTs) consistent with 40 CFR Part 112.7 (c). <br /> BACKGROUND <br /> Since 1973, the SPCC regulation has included the following provision addressing <br /> secondary containment and the allowance for equivalent preventive systems. Section <br /> 112.7 (c) states: <br /> Appropriate containment and/or diversionary structures or equipment to prevent <br /> discharged oil from reaching a navigable watercourse should be provided. One of <br /> the following preventive systems or its equivalent should be used as a minimum: <br />