IN GENERAL, WHO NEEDS AN SPCC PLAN?
Federal SPCC regulations require an SPCC Plan to be implemented for a facility if:
~the facility could reasonably be expected to discharge oil into navigable waters,
the facility has more than 1,320 gallons capacity of aboveground storage,
the facility has more than 42,000 gallons capacity of underground storage.
~SPCC Plans must be certified by a Professional Engineer.
* Under the amendment dated December 26, 2006, farms with aboveground capacities of 10,000 gallons or less may self-certify their SPCC Plan.
WHAT IS THE DEADLINE FOR COMPLYING WITH THE SPCC REGULATION?
~Facilities in operation on or before August 16, 2002 must amend their SPCC Plan as necessary to comply with current regulations, no later than November 10, 2010.
~Facilities that became operational after August 16, 2002 through November 10, 2010, an SPCC Plan in compliance with the current rule must be developed and implemented no later than November 10, 2010.
~Facilities that become operational after November 10, 2010, an SPCC Plan must be developed and implemented prior to operation.
* Under the amendment dated December 26, 2006, the EPA is extending the SPCC compliance dates for farms. Contact GLEC for more details.
WHAT IS THE PENALTY FOR NOT COMPLYING WITH THE SPCC REGULATION?
~Owners or operators that are subject to the regulation but violate the requirements of Part 112 by failing or refusing to comply are liable for civil penalties in accordance with the Clean Water Act (CWA), as amended by the Oil Pollution Act (OPA) of 1990. Penalties could be as high as $25,000 per day of violation.
GLEC begins the preparation of a SPCC Plan with a general inventory of the site that includes oil storage capacities, site layout, run-off patterns and drainage features. Interviews with key site personnel as well as local emergency officials help to coordinate a SPCC Plan. Following the facility overview, a comprehensive plan is created to lay the foundation for a facility to respond to an oil release in a timely and effective manner. This Plan provides the facility manager with guidelines on how to advise employees on safe and correct procedures of handling oil products and provides checklists for everything from training, maintenance, daily and monthly observations, facility operations pertaining to SPCC Plans and emergency contacts in case of a petroleum release.
SPPC Plans are required to be reviewed every 5 years. If any significant changes to operational procedures, oil handling structures or features, designated facility personnel are apparent changes must be implemented and within 6 months of the review.
GLEC has completed SPCC plans for facilities as large as 10 acres, but has the ability to create the SPCC Plan according to a range of oil storage capacities and facility sizes.
For the complete Federal SPCC rules and requirements, see Title 40 of the Code of Federal Regulations, Part 112 on-line at http://www.epa.gov/oilspill/spcc.htm.