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Excerpt from "Under SPCC regulations, is secondary containment required for 55-gallon containers? "
I have a facility in Denver, CO that requires an SPCC plan and today they asked me if they require secondary containment for 55 gallon containers. I re-read the federal definition of "bulk storage' and saw no reference to 55-gallons as a cutoff for bulk storage, however, my consultant tells me that 55-gallon is the cutoff for bulk storage. In addition I noticed that in VT, the agency there has a fact sheet defining bulk storage as 55-gallons or greater. Can you please provide a citation in the rule that will clarify this at the federal and state level?

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