August 6, 2010 In 2002 the U.S. EPA issued major revisions to the regulation for Oil Spill Prevention, Control, and Countermeasure (SPCC) Plans. Since then the EPA has passed additional changes and clarifications. The most recent amendments were effective January 14, 2010.

If you need an SPCC Plan and your facility was in operation on or before August 16, 2002, you must have a Plan in place now that at least follows the pre-2002 regulations. The Plan must be reviewed, and if necessary updated, every five years.

The EPA has a tentative deadline of November 2010 for updating the SPCC Plans to implement the 2002 revisions and subsequent amendments. This deadline also applies if your facility opened after August 16, 2002. Recently, the EPA proposed moving the deadline back one year to 2011 for most industrial facilities.

Oil SPCC Plans are required if a facility exceeds a threshold of 1,320 gallons of oil in aboveground containers and equipment.

  • When calculating the maximum oil capacity, the maximum container shell capacity must be used, not the actual oil volume.
  • Containers with capacity of less than 55 gallons are excluded from calculating the threshold.
  • Oil is broadly defined in this regulation to include fuel oil, synthetic oil, gasoline, mineral spirits, used oils, cutting oils and lubricants that are derived from petroleum; and oils that are derived from animals, vegetables or fish.

If you think you may have exceeded this threshold:

  • You will need an SPCC Plan that meets the requirements in 40 CFR Part 112 including secondary containment, training, inspections, and a detailed facility diagram.
  • Certain Plan elements must be consistent with good engineering practices and follow industry standards. A Professional Engineer (PE) normally must certify the Plan.
  • If you have less than or equal to 10,000 gallons of oil (total shell capacity in all containers) you may be eligible to self-certify the SPCC Plan.

Our staff includes experienced professional engineers that are qualified to prepare and certify your SPCC Plan. Please call us today at (847) 288-5355, to schedule an assessment of your need for an Oil SPCC Plan. Or e-mail me at Phil@admiralenv.com.

Philip A Twomey, P.E.

PS: For more information, the EPA web site for this is: http://www.epa.gov/emergencies/content/spcc/index.htm

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