SPCC Plans - State Spill Prevention - Preparedness Requirements

Caltha LLP provides technical support to facilities nationwide to comply with US EPA Spill Prevention, Control & Countermeasure (SPCC) Rules (40 CFR 112) and State-specific spill prevention, spill preparedness and release reporting requirements. Caltha specializes in preparing SPCC Plans, including using the new SPCC Template Plan format.

[Read more about the benefits of SPCC Template Plan format]

Caltha provides SPCC Plan services in a number of flexible formats, ranging from turn-key services where we provide a complete SPCC Plan, to ad hoc technical guidance to facility or corporate staff as they prepare Plans and compliance programs. Caltha also provides technical support in developing and implementing SPCC Inspection programs, and in developing and presenting annual SPCC Training.

To request further information on SPCC services for individual States, click on a State below:

[See a map showing States where Caltha LLP worked in 2008]

Alabama SPCC Plan - SPCC Template Plan
Alaska SPCC Plan - SPCC Template Plan
Arkansas SPCC Plan - SPCC Template Plan
California SPCC Plan - SPCC Template Plan
Connecticut SPCC Plan - SPCC Template Plan
Florida SPCC Plan - SPCC Template Plan
Georgia SPCC Plan - SPCC Template Plan
Illinois SPCC Plan - SPCC Template Plan
Indiana SPCC Plan - SPCC Template Plan
Iowa SPCC Plan - SPCC Template Plan
Kansas SPCC Plan - SPCC Template Plan
Kentucky SPCC Plan - SPCC Template Plan
Louisiana SPCC Plan - SPCC Template Plan
Maine SPCC Plan - SPCC Template Plan
Massachusetts SPCC Plan - SPCC Template Plan
Michigan SPCC Plan - SPCC Template Plan
Minnesota SPCC Plan - SPCC Template Plan
Mississippi SPCC Plan - SPCC Template Plan
Nebraska SPCC Plan - SPCC Template Plan
Nevada SPCC Plan - SPCC Template Plan
New Jersey SPCC Plan - SPCC Template Plan
New York SPCC Plan - SPCC Template Plan
North Carolina SPCC Plan - SPCC Template Plan
North Dakota SPCC Plan - SPCC Template Plan
Ohio SPCC Plan - SPCC Template Plan
Oklahoma SPCC Plan - SPCC Template Plan
Oregon SPCC Plan - SPCC Template Plan
Pennsylvania SPCC Plan - SPCC Template Plan
South Carolina SPCC Plan - SPCC Template Plan
South Dakota SPCC Plan - SPCC Template Plan
Tennessee SPCC Plan - SPCC Template Plan
Texas SPCC Plan - SPCC Template Plan
Utah SPCC Plan - SPCC Template Plan
Virginia SPCC Plan - SPCC Template Plan
Washington SPCC Plan - SPCC Template Plan
Wisconsin SPCC Plan - SPCC Template Plan

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Self Certification of SPCC Template Plans – What Is Required?

The SPCC Rule (40 CFR 112) now allows SPCC Plans to be self-certified (no PE certification required) by facilities, if they meet a few qualifications:

• On-site oil storage capacity must be less than 10,000 gallons;
• Over the past three years, no single spill greater than 1,000 gallons, and no more than two spills greater than 42 gallons have occurred;
• The SPCC meets all SPCC Rule (40 CFR 112) requirements, without the use of “environmentally equivalent” or “impracticality” determinations.

For Tier I Qualifying facilities, the facility must also certify that it meets all the requirements necessary to use the SPCC Template Plan format. All "self-certified" SPCC Plans, including those using the SPCC Template Plan format, will still need to be signed by a responsible person on behalf of the facility. By signing the SPCC Plan, that person certifies that he/she is:

• Familiar with SPCC requirements,
• Has visited and reviewed the facility,
• The Plan was prepared in accordance with accepted and sound industry practices,
• Procedures for inspections and testing have been established,
• The Plan is fully implemented, and
• The facility meets all the requirements to qualify for self certification.

[Request information on State-specific SPCC Plans and Template Plans]

Caltha LLP offers expert technical and regulatory support to develop "self-certified" facility Spill Prevention, Control & Countermeasure (SPCC) plans, including several low cost options for SPCC Plans using the new SPCC Template Plan format. Caltha also develops the required SPCC training and SPCC inspection programs to comply with 40 CFR 112 requirements. For futher information on SPCC services, go to:
SPCC - 40 CFR 112 Compliance Services

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

40 CFR 112 SPCC Rule Compliance Deadline Extension

EPA is extending the compliance dates for all facilities and establishing new compliance dates for farms and production facilities subject to the Spill Prevention, Control, and Countermeasure (SPCC) rule. This amendment extends the dates by which the owner or operator of any SPCC-regulated facility must prepare or amend and implement its SPCC Plan. It also establishes the dates by which the owner or operator of a farm must prepare or amend and implement its SPCC Plan.

For all facilities subject to the recent amendments, the compliance deadline was extended to November 20, 2009. For farm and production facilities, the deadline for compliance with amended SPCC Rule requirement will be either November 20, 2009, or November 20, 2013, depending on whether or not the facility meets some specific criteria.

Caltha LLP assists companies in addressing their requirements under Federal SPCC rules. Caltha specializes in developing cost effective SPCC Plans for facilities nationwide using the new SPCC Template Plan format. Click here to request further information on SPCC and SWPPP Services.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Do Construction Sites Need SPCC Plan In Addition To SWPPP?

Does a construction site that operates under a stormwater discharge permit and has a Stormwater Pollution Prevention Plan (SWPPP) also need a Spill Prevention Control and Countermeasure (SPCC) Plan?

The answer is POSSIBLY; the requirements for a stormwater discharge permit and for a SPCC Plan are independent of each other. Not all construction sites that need a stormwater permit also need an SPCC Plan - and some construction sites that do not need a stormwater permit may need an SPCC Plan.

Whether or not a given construction site needs an SPCC Plan will depend on the oil storage capacity on site, even if storage tanks, mobile tanks, oil-filled equipment, etc are only on-site temporarily. [Read more about SPCC requirements] Individual State programs may also have additional requirements for notification, registration or permitting of above ground storage tanks at construction sites.

Even construction sites that do not exceed the thresholds requiring an SPCC Plan need to have spill prevention and control measures. In most cases this requirement is contained in the site stormwater discharge permit, or in State general duty provisions to prevent and control spills, and to clean up spilled materials.

Caltha LLP offers some very cost effective options for construction sites needing to prepare SPCC Plans, SWPPPs, or to develop spill prevention and response procedures. Click here to request more information on construction site SPCC/SWPPP Services.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Spill Prevention Control & Countermeasures - Requirements for Farm Operations

On December 5, 2008, EPA amended the SPCC rule to tailor certain requirements for agricultural facilities, including farms. These amendments complement the December 2006 amendments to the SPCC rule, which streamlined the requirements for most farms subject to SPCC requirements. The recent amendment clarified three primary areas relevant to farm operations.

First, the final rule exempts all pesticide application equipment and related mix containers, regardless of ownership or where used, from SPCC requirements. The capacity of these pesticide application equipment and related mix containers are not counted toward the facility’s oil storage capacity calculation. However, containers that store oil prior to mixing with a pesticide, or containers used to store pesticides that contain oil, may continue to be regulated under the SPCC rule.

Second, the SPCC amendment also clarified application of the Rule to mobile refuelers (including “nurse tanks”), common at many farm operations. Mobile refuelers are exempt from the sized secondary containment requirements of the SPCC rule, but are still subject to the general secondary containment requirements.

Finally, farms are exempt from the loading/unloading rack requirements because agricultural oil and fuel transfers at farms are generally not associated with loading/unloading racks. However, oil transfer areas, such as loading/unloading areas at farms are subject to the SPCC rule and require general secondary containment.

Caltha LLP assists facilities that exceed the SPCC storage threshold to comply with SPCC Rules, including preparation SPCC Plans and SPCC Template Plans, and conducting SPCC Training.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

SPCC Rule 40 CFR 112 - Regulation of Mobile Tanks and Tankers

The recently revised SPCC Rule (40 CFR 112) clarified a few points in regards to mobile tanks.

First, the Rule clarified that tanks on vehicles used to hold fuels and operating fluids required to operate the vehicle are not intended to be regulated under the SPCC requirements. Typical mobile refueling equipment would have two types of fuel storage –a fuel tank for operation of the engine, and a storage tank used to move fuel around the facility. Under the revised Rule, the engine’s fuel tank (i.e., “motive fuel container”) would not be included under an SPCC Plan.

The bulk fuel tank on the refueling vehicle would normally require the same spill protections that other containers need. However, the revised SPCC Rule clarified that these refueling vehicles are exempted from some SPCC requirements.

Caltha LLP provides expert technical support to facilities and/or consulting engineers on compliance with SPCC Rules. Caltha maintains a library of SPCC Plan templates to match site-specific needs. For futher information on SPCC services, go to:
SPCC - 40 CFR 112 Compliance Services

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Revised SPCC Rules - Connection with Stormwater Permit Compliance

Stormwater discharge permits commonly reference other regulatory requirements. Possibly the most common regulatory reference is that permitted facilities must be in compliance with SPCC Rules (40 CFR 112). Since 2002, the SPCC Rules have been evolving; the result of these changes has been that many more facilities are now subject to SPCC requirements. However, a significant number of facilities are not aware of changes to the SPCC Rule and that they are now subject to this regulation.

The most significant change has been the threshold on oil storage capacity that makes a facility subject to SPCC Rules. Although the threshold for total facility oil storage capacity increased to 1320 gallons, the size of containers which must be included in the calculation decreased to 55 gallons. Now, a facility must add the oil storage capacity for all containers 55 gallons or greater; if the total exceeds 1,320 gallons, the facility is subject to SPCC Rules. Facilities that include a significant drum storage of oil can easily exceed this threshold.

Many of the revisions to the SPCC requirements streamlined compliance requirements and ultimately reduce the complexity and costs associated with compliance. US EPA believed that reducing the overall complexity of the program will improve compliance, especially with small to mid-sized facilities that are affected.

Specifically, the types of facilities that benefited were:

• Facilities with total oil storage capacity between 1,320 and 10,000 gallons
• Facilities with certain types of regulated oil-filled equipment
• Facilities with mobile refueling vehicles
  

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website