Compliance Just Got Easier: Stay ahead of regulatory changes with instant notifications on updates that matter.

FREE TRIAL UPGRADE!
Thank you for investing in EnvironmentalHazmatHuman ResourcesHuman Resources, Hazmat & Environmental related content. Click 'UPGRADE' to continue.
CANCEL
YOU'RE ALL SET!
Enjoy your limited-time access to the Compliance Network!
A confirmation welcome email has been sent to your email address from ComplianceNetwork@t.jjkellercompliancenetwork.com. Please check your spam/junk folder if you can't find it in your inbox.
YOU'RE ALL SET!
Thank you for your interest in EnvironmentalHazmatHuman ResourcesHuman Resources, Hazmat & Environmental related content.
WHOOPS!
You've reached your limit of free access, if you'd like more info, please contact us at 800-327-6868.
Loading/Unloading racks
  • Loading/Unloading rack means a fixed structure (such as a platform, gangway) necessary for loading or unloading a tank truck or tank car.
  • Section 112.7(h) applies to areas at regulated facilities where traditional loading/unloading racks for tank cars and tank trucks are located.

Loading/Unloading rack means a fixed structure (such as a platform, gangway) necessary for loading or unloading a tank truck or tank car. A loading/unloading rack includes a loading or unloading arm and may include any combination of the following: piping assemblages, valves, pumps, shut-off devices, overfill sensors, or personnel safety devices. If the equipment does not include a hose without a loading or unloading arm, then the equipment is not a loading/unloading rack, by definition.

Part 112.7(h) applies to areas at regulated facilities where traditional loading/unloading racks for tank cars and tank trucks are located. Environmental Protection Agency (EPA) inspectors may evaluate compliance with the requirements of 112.7(h) for equipment that meets the definition of “loading/unloading rack” as found in 112.2.

A loading/unloading arm is a critical component of a loading/unloading rack. A loading/unloading arm is typically a movable piping assembly that may include fixed piping or a combination of fixed and flexible piping, typically with at least one swivel joint (that is, at least two articulated parts that are connected in such a way that relative movement is feasible to transfer product via top or bottom loading/unloading to a tank truck or tank car). However, certain loading/unloading arm configurations present at loading racks may include a loading/unloading arm that is a combination of flexible piping (hoses) and rigid piping without a swivel joint. In this case, a swivel joint is not present on the loading arm because flexible piping is attached directly to the rigid piping of the loading arm and the flexible hose provides the movement needed to conduct loading or unloading operations in lieu of the swivel joint.

In developing the definition in 112.2, EPA considered existing definitions of the term “loading rack” and related terms, as found in industry, federal, state, or international references, and reviewed various types of equipment considered components of loading racks. This definition does not include simple loading or unloading configurations, but rather only includes the associated equipment and structures associated with loading/unloading arms as part of a rack. Equipment present at a loading/unloading area where a pipe stand connects to a tank car or tank truck via a flexible hose is not a loading/unloading rack because there is no loading or unloading arm. Because some top and bottom loading/unloading racks are made up of a combination of steel loading arms connected by flexible hosing, the presence of flexible hoses on oil transfer equipment should not be used as an indicator of whether the equipment meets the definition of loading/unloading rack.

Subparagraph 112.7(h)(1) requires a sized secondary containment system, which means the containment must hold at least the maximum capacity of any single compartment of a tank car or tank truck loaded or unloaded at the facility.

However, the spill prevention, control, and countermeasure (SPCC) rule does not require that secondary containment for loading/unloading racks be designed to include freeboard for precipitation. When drainage from the areas surrounding a loading/unloading rack do not flow into a catchment basin or treatment facility designed to handle discharges, facility owners and operators must use a quick drainage system (112.7(h)(1)). A “quick drainage system” is a device that drains oil away from the loading/unloading area to some means of secondary containment or returns the oil to the facility.

Loading and unloading activities that take place beyond the rack area are not subject to the requirements of 112.7(h), but are subject, where applicable, to the general secondary containment requirements of 112.7(c). Loading/unloading racks can be located at any type of facility; however, loading/unloading racks are not typically found at farms or oil production facilities. Oil transfers to or from oil storage containers at farms and oil production facilities where no loading rack is present are subject to the general secondary containment requirement.

For example, a facility may have two separate and distinct areas for transfer activities. One is a tank truck unloading area and the other includes a tank truck loading rack. The unloading area contains no rack structure, so the secondary containment requirements of 112.7(c) apply. The requirements of 112.7(h) apply to the area surrounding the loading rack. As highlighted by this example, the presence of a loading rack at one location of a facility does not subject other loading or unloading areas in a separate part of the facility to the requirements of 112.7(h).

However, if a facility has a tank truck loading rack and unloading area that are co-located, the more stringent secondary containment provision applies; therefore, the area is subject to the sized secondary containment requirements of 112.7(h)(1).

In certain situations, the sized secondary containment requirements of 112.7(h)(1) for loading/unloading racks may be impracticable due to geographic limitations, fire codes, etc. In these cases, the owner or operator may determine that secondary containment is impracticable as provided in 112.7(d). Under that provision, the SPCC Plan must clearly explain the reasons why secondary containment is not practicable and comply with the alternative regulatory requirements.