4 More Things Trainers Should Know About SPCC

Our sister publication, Environmental Daily Advisor, reports from the 2013 National Institute for Storage Tank Management’s (NISTM) recent storage tank conference that the U.S. Environmental Protection Agency (EPA) gave a really detailed, 3-hour review of Spill Prevention, Control, and Countermeasure (SPCC) regulations and best practices.

Here are 4 more things I picked up that I bet you didn’t know about the SPCC.

7.  Underground storage tanks (USTs) can be exempted from SPCC regulations. Any UST that is regulated by 40 CFR 280 and 281 does not fall under SPCC regulations. However, for facilities that are otherwise regulated, exempted USTs must be identified on the facility diagram of the SPCC Plan.

8.  Requests for extensions are allowed but probably not a good idea. Any facility can submit a written request for more time to prepare, implement, and/or amend its SPCC Plan; however, it raises a huge red flag to the EPA that your facility is out of compliance. If you insist on requesting an extension, proceed with caution.

 9.  Your facility diagram doesn’t have to be fancy. Your SPCC Plan is required to have a facility diagram (or sometimes also called a facility map), but there are no requirements around the format. Your diagram can be as simple as a hand drawing or as complicated as a computer-aided design (CAD).

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10.  Most facilities require a Tier II plan. According to the EPA, 66 percent of the more than 650,000 regulated facilities are Tier II facilities and are eligible to more streamlined SPCC requirements. The big difference here is that Tier II facilities have to write a full-blown SPCC Plan, BUT do not have to have it certified by a licensed professional engineer (PE) and may self-certify their Plan.

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