Question: If you have double-walled tanks, are you exempt from Spill Control and Countermeasures (SPCC) planning? What is the maximum amount of oil you can have onsite and still be able to self-certify your plan? When you’re up for the 5-year review, can anyone do that, or does a professional engineer (PE) have to re-certify your plan?
Answer: Having double-walled tanks or other devices that could prevent a release — such as man-made berms, dikes and barriers — does not exempt a facility from needing an SPCC plan [40 CFR 112.1(d)(1)(i)].
An owner or operator of a facility can self-certify and their SPCC plan if they qualify as a Tier I or Tier II facility. A facility is considered Tier I or Tier II if the site’s total above ground oil storage capacity is 10,000 gallons or less. Tier I and Tier II facility owners and operators can also re-certify their SPCC plan, which must be done every 5 years.
There are other factors, which can be found in “SPCC Qualified Facilities Applicability,” to take into consideration, however, like if the facility has had oil spill to a navigable waterways and adjoining shorelines.
If at any point a facility increases their aboveground oil storage capacity to more than 10,000 gallons, they will no longer be able to self-certify their SPCC plan and must have the plan certified by a PE within 6 months of the change.
Before considering whether you can self-certify your plan, however, it’s important to understand what an SPCC plan is and who should have one.
A non-transportation-related facility (i.e. does not move oil between) is required by the Environmental Protection Agency (EPA) to have an SPCC plan if more than 1,320 gallons of aboveground oil or 42,000 gallons of underground oil are stored, used, produced, drilled, refined or transferred. The facility must also “reasonably be expected to discharge oil” into U.S. waters.
An SPCC plan should outline a facility’s oil handling operations, spill prevention practices, discharge or drainage controls and the equipment and resources on-hand to prevent oil spills from reaching navigable waterways and adjoining shorelines.
The EPA offers an SPCC plan template for Tier I facilities. There is no template for Tier II facilities. The owner or operator of a Tier II facility should follow 40 CFR 112.7 and subparts B or C to create an SPCC plan.
All other facilities that require an SPCC plan must also prepare one based on 40 CFR 112.7 and subparts B or C and have it certified by a PE.
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