Conduct a survey of randomly selected bulk aboveground storage containers storing gasoline or
other NFPA 704 flammability rating of 3 or higher at terminals in high risk locations (such as
near population centers or sensitive environments) that are already subject to the Spill
Prevention, Control and Countermeasure (SPCC) and/or Facility Response Plan (FRP) rules to
determine:
a) The nature of the safety management systems in place to prevent overfilling a
storage tank during loading operations. Analysis of the safety management
systems should include equipment, training, staffing, operating procedures and
preventative maintenance programs.
b) The extent to which terminals use independent high level alarms, automated
shutoff/diversion systems, redundant level alarms or other technical means to
prevent overfilling a tank
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c) The history of overfilling incidents at the facilities, with or without consequence
d) Whether additional reporting requirements are needed to understand the types of
incidents leading to overfilling spills that breach secondary containment and have
the potential to impact the environment and/or the public, as well as the number
of safeguards needed to prevent them.