EPA REVISES SPCC REQUIREMENTS

Do you need a new or updated SPCC plan? 

The US Environmental Protection Agency (EPA) requires facilities that use, manage and store oil to prepare and implement Spill Prevention, Control and Countermeasures (SPCC) Plans. The SPCC requirements apply to most facilities that have total aboveground oil storage capacity of 1,320 gallons or more.

On July 17, 2002 EPA announced over 100 pages of amendments to the existing SPCC rules. This final rule incorporates revisions proposed in 1991, 1993 and 1997. The amendments include expansion, modification, and clarification of the requirements for SPCC Plans and Facility Response Plans. As a result of these changes, facilities that have existing SPCC Plans must update them to comply with the new regulations by October 31, 2007. The updated SPCC Plans must be certified by a professional engineer (PE). The SPCC amendments require that facility management must review and approve the upgraded SPCC Plans, and provide a commitment of the manpower and equipment needed for implementation.

The EPA amendments are not limited to spill planning. Some facilities will be required to modify their petroleum storage and distribution equipment and spill control systems to comply with more stringent requirements under the amended SPCC regulations. Facility upgrades and other components of the updated SPCC Plans must be fully implemented by October 31, 2007.

 SPCC Amendments Summary

 Highlights of the amendments to the SPCC regulations include:

• Clarification of the criteria used to determine who must prepare an SPCC Plan.

• Expansion and clarification of requirements regarding both the content and format of SPCC Plans; acceptance of the Integrated Contingency Plan format.

• New requirement that aboveground storage tanks and underground piping must be periodically tested for integrity.

• Expansion and clarification of design, performance, and PE certification requirements for secondary containment systems.  For example, EPA has clarified that secondary containment is required not just for the storage tanks, but also for the loading and unloading areas.

• New requirements for corrosion protection of underground piping.

• Clarification of the requirement for some mobile facilities to have SPCC Plans.

• Modification of the stormwater management and recordkeeping requirements.

• Clarification and expansion of requirements for routine facility inspections and associated recordkeeping.

• Modification of the training requirements for employees that handle petroleum products.

• Modification of requirements for periodic SPCC Plan reviews and updates.

• Clarification and expansion of requirements for Professional Engineer’s role in SPCC Plan preparation and certification.

• Clarification of the owner’s responsibility for implementation of the SPCC Plan.

Compliance Deadlines 

Strict deadlines are fast approaching:

• Modified SPCC Plans for facilities that existed on August 16, 2002:  October 31, 2007.

• Plan implementation, including facility modifications and upgrades:  October 31, 2007.   

• SPCC Plans and implementation for new facilities:  October 31, 2007.

The above deadlines reflect extensions recently granted by EPA.  It is unlikely that EPA will extend the deadlines again. 

SPCC Plans and SCS Engineers

SCS Engineers is a nationwide environmental engineering and consulting firm, with over 400 employees and 35 offices throughout the US.  We have been providing petroleum management, planning, training, design, construction, and spill response services since the 1970s.  Our Professional Engineers have prepared and certified hundreds of SPCC Plans, including many under the new SPCC regulations.  Facilities have ranged from small service stations and repair shops to bulk petroleum storage and distribution facilities with capacities in excess of 100 million gallons.

SCS provides a host of related services, including preparation of Facility Response Plans, Oil Discharge Contingency Plans, Integrated Emergency Response Plans, design of petroleum storage and distribution systems, closure of existing systems, spill response and remediation, PE evaluation and certification of secondary containment systems, compliance assessments, permitting, and other regulatory assistance.

Please contact service@scsengineers.com, or call (800) 767-4727, for a referral to an SCS office near you.