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Are you in compliance with the USEPA's SPCC Rule?

oil tankThe U.S. Environmental Protection Agency (USEPA) requires a Spill Prevention, Control, and Countermeasure (SPCC) Plan for all facilities, including municipalities, that store oil in volumes above the limits defined by the SPCC Rule. An SPCC Plan is a preventive measure to assure that an oil spill will be contained and prevented from reaching navigable waters, such as streams, creeks, lakes or other waterways, and their adjacent shorelines. Multiple types of oil are covered under the USEPA’s requirement, including: petroleum; fuel oil; sludge; oil refuse; oil mixed with wastes other than dredged spoil; fats, oils or greases of animal, fish, or marine mammal origin; vegetable oils, including oil from seeds, nuts, fruits, or kernels; and other oils and greases, including synthetic oils and mineral oils.

The USEPA revised its requirements for SPCC Plans with a new compliance date of November 2011, but many municipalities may not be aware that they are not in compliance. AE2S Engineer Ben Julson, PE, says, “I’ve worked with several clients who did not know that the revised requirements applied to them. For example, depending on storage volumes, municipalities are required to implement an SPCC Plan for items such as fuel tanks, oil drums, heating oil tanks, waste oil tanks, and emergency generator fuel tanks, just to name a few of the more common oil storage items.” The USEPA requires facilities that have an aboveground oil storage capacity greater than 1,320 gallons, or a completely buried storage capacity greater than 42,000 gallons, to implement a SPCC Plan if there is a reasonable chance that oil could be discharged into navigable waters.  

SPCC Plans must be certified by a Professional Engineer (PE). In lieu of PE certification, an SPCC Plan can be self-certified if the facility meets volume and spill limits as defined by the SPCC Rule. “It’s not difficult to develop an individualized SPCC Plan, and some clients can self-certify their SPCC Plan. It’s prudent to get the plan implemented sooner, rather than later, to avoid penalties for non-compliance,” says Julson.   

Industrial, commercial, agricultural, or public facilities using or storing oil, and certain waste treatment facilities, must develop a SPCC Plan. Other facilities that must comply include onshore and offshore oil well drilling facilities, oil refining or storage facilities, tanker trucks and railroad cars used to transport oil exclusively within the confines of a facility, and pipeline systems used to transport oil exclusively within the confines of a facility. “An SPCC Plan helps facilities prevent oil spills by defining safe operations and ensures a secondary containment. In the event of a spill, the Plan identifies spill containment measures, cleanup procedures, and contact information for emergency response personnel,” says Julson. It’s important to note that oil transported between facilities by rail car or tanker truck, interstate or inter-facility oil pipeline systems, and oil transported via ships or barges are typically not subject to the SPCC Plan requirement. 

The USEPA says facilities with aboveground storage tanks that are operated more than four hours per day are required to keep a copy of the SPCC Plan on site. For those that are operated less than four hours per day, the Plan can be kept at the nearest field office. 

To access additional USEPA information about SPCC Plans, click here, or contact Ben Julson at Ben.Julson@ae2s.com, or AE2S Engineer Dustin Dale, PE, at Dustin.Dale@ae2s.com. Both of them can be reached by phone at 218-299-5610.

 

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If you have any questions concerning the content of this newsletter,
please contact Heather Syverson at 701-364-9111 or Heather.Syverson@ae2s.com.
 
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