Can qualified facilities also use the alternative requirements for qualified oil-filled operational equipment?
Yes. Facilities that meet the criteria for qualified facilities and qualified oil-filled operational equipment may benefit from both of the alternative approaches. Since an impracticability determination is not necessary for qualified oil-filled operational equipment, the owner/operator can self-certify the SPCC Plan and is not required to have a PE develop the alternative measures to secondary containment for qualified oil-filled operational equipment.