Wednesday, February 11, 2009

Do I Need an SPCC Plan? SPCC Threshold Criteria Overview

The requirement for a formal Spill Prevention, Control and Countermeasure (SPCC) Plan comes from a federal regulation - 40 CFR 112 ("SPCC Rule"). Certain States may have their own requirements for spill prevention and response, which are in addition to the SPCC Rule.

Whether or not a site needs to prepare and implement and SPCC Plan will depend on oil storage capacity at the site. If the capacity to storage oils exceeds 1,320 gallons, then an SPCC Plan may be required.

Some key considerations include:

  • Oils regulated are not limited to petroleum and fuels - other types of oils, including food oils, hydraulic fluids, etc. may be regulated under SPCC Rules.

  • All containers greater than 55-gallons need to be included (which includes 55-gal drum containers)

  • Although underground storage tanks may be excluded, the types of oil storage goes well beyond fixed abovegound storage tanks; containers regulated under SPCC Rules can include oil-filled equipment (e.g., gear boxes, reservoirs), oil-filled electrical equipment, and mobile tanks.

Compliance with SPCC Rules begins with careful consideration of 40 CFR 112, and an in-depth inventory of regulated materials and containers.

[Read more about recent changes to SPCC Rules]

[Read more about State-specific SPCC Plan Templates]

Caltha LLP provides expert technical support to clients nationwide needing to comply with SPCC Rules and State spill prevention and response planning requirements.

For further information contact Caltha LLP at
Caltha LLP Website

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