A non-transporatation site is subject to EPA regulations contained in 40 CFR 112 (oil pollution prevention) if:
- the total above ground storage capacity of “oil” exceeds 1,320 gallons (excluding tanks, containers, and oil-filled equipment below 55 gallons in capacity; permanently closed containers; motive power containers; or storage containers used exclusively for wastewater treatment); or
- the aggregate underground capacity exceeds 42,000 gallons (excluding those that are currently subject to all of the technical requirements of 40 CFR 280/281, containers less than 55 gallon, or
- storage containers used exclusively for wastewater treatment); and if, due to its location, the facility or property could reasonably be expected to discharge oil into or upon the navigable waters or adjoining shorelines of the United States.
If one or more of the above criteria are met, a Spill Prevention, Control, and Countermeasures (SPCC) Plan is required. The purpose of an SPCC Plan is to form a comprehensive oil spill prevention program that minimizes the potential for discharges. In addition to preparation and implementation, an SPCC Plan must be updated at least every five years or as necessary due to changes in site operation.
Cox-Colvin has prepared and updated numerous SPCC Plans for a wide range of industrial sites, including those with limited oil storage capacity and straightforward operations, to those with significant oil storage capacity and complex operations. Additionally, to save the Owner significant expense and ensure consistency of implementation, Cox-Colvin has prepared comprehensive/master SPCC Plans that are intended to cover numerous sites of similar operation. In order for an SPCC Plan to be both compliant and effective, it is critical to understand the various nuances associated with 40 CFR 112 regulations. The following are some of the services Cox-Colvin can provide during preparation or update of SPCC Plans:
- Identify which chemicals are considered to be or contain an “oil”
- Determine the difference between a bulk storage container and oil-filled equipment (the
difference is not always easily apparent and the regulatory requirements of each
- Confirm adequately sized and constructed secondary containment
- Perform secondary containment impracticability determinations
- Identify regulatory exemptions and environmental equivalence
- Establish a baseline or assess the current structural integrity of a bulk storage container
- Develop applicable points for routine inspection that are consistent with industry standards