SPCC FAQ

Before a facility is subject to the SPCC rule, it must meet three criteria:

1. It must be non-transportation-related;
2. It must have an aggregate aboveground storage capacity greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons; and
3. There must be a reasonable expectation of a discharge into or upon navigable waters of the United States or adjoining shorelines.

SPCC applies to a farm that:

• • • stores, transfers, uses or consumes oil or oil products, such as diesel fuel, gasoline, lube oil, hydraulic oil, adjuvant oil, crop oil, vegetable oil or animal fat; and
    • stores more than 1,320 US gallons in total of all aboveground containers (only count containers with 55 gallons or greater storage capacity) or more than 42,000 gallons in completely buried containers; and
    • could reasonably be expected to discharge oil to navigable waters of the US or adjoining shorelines, such as lakes, rivers and streams.

Yes, you should include fuel tanks mounted on trailers, fuel trucks used exclusively on the farm and tanks in pickups toward the overall threshold of 1,320 gallons. Also, count 55-gallon drums, but don’t count any container smaller than that.

Depending on the concentration yes crop or adjuvant oils, used to increase the efficiency of pesticides is regulated.

Yes, it does-manifolded tanks are considered one tank-so instead of two 10,000 gallon tanks you now have one 20,000 gallon tank. The secondary containment must address 20,000 gallons not 10,000 gallons.

Yes, it is true. Don’t get flustered it is not as complicated as you may think. A 500 gallon tank fits nicely into a 600 gallon livestock trough. Earthen berms are acceptable IF it will hold liquid long enough to be discovered and cleaned up.

All facilities having greater than 10,000 gallons of oil storage capacity, with an above ground storage capacity greater than 1,320 gallons; or any facility with underground tank storage capacity greater than 42,000 gallons must have their Plans SEALED by a PE.

If a facility has 10,000 gallons or less in aggregate aboveground oil storage capacity with no individual aboveground oil storage container greater than 5,000 gallons, and meets the oil discharge criteria*, then an owner/operator of a facility may prepare a Self-Certified Tier I Plan instead of one prepared and sealed by a Professional Engineer (PE). In addition, if the facility has a container greater than 5,000 gallons, then it may prepare a Self-Certified Plan with all applicable requirements of §112.7 and Subparts B and C of the Rule in lieu of a PE-Certified Plan.

• • 1. * The facility must not have had a single discharge of oil to navigable waters exceeding 1,000 US gallons; or two discharges of oil to navigable waters each exceeding 42 US gallons within any twelve-month period (in the three years prior to the SPCC Plan certification date), or since becoming subject to 40 CFR Part 112 if facility has been in operation for less than three years.
       

Fines are normally assessed in proportion to the size of the facility. In 2009, fines administered by EPA for SPCC violations related to the Clean Water Act have ranged from $500 – $200,000. EPA has published a guidance document “SPCC Guidance for Regional Inspectors” to assist EPA inspectors in their review of an SPCC facility.

Underground storage tanks are exempt from SPCC requirements if they are subject to 40 CFR Parts 280 or 281. They must, however, be shown on the facility diagram. The SPCC requirements also do not apply to:

• • • Containers with a storage capacity less than 55 US gallons of oil.
    • Permanently closed containers.
    • Motive power containers.
    • Wastewater treatment facilities.
    • Hot-mix asphalt and hot-mix asphalt containers.
    • Residential heating oil containers at single family residences.
    • Pesticide application equipment and related mix containers.
    • Completely buried storage tanks subject to all the technical requirements of the underground storage tank regulations.
    • Intra-facility gathering lines subject to US Department of Transportation’s pipeline regulations.
    • Underground oil storage tanks at nuclear power generation facilities.

The SPCC regulations are part of The Clean Water Act which is intended to protect navigable waters. The EPA relies on a list of oils maintained by the coast guard. The list is informal and is not all inclusive. CLICK HERE to access the list.

The former standard was 110% of the largest container within the secondary containment. Today the standard begins with 110% rule and also addresses precipitation. The additional rule of thumb is the secondary containment must hold the largest tank plus precipitation of a 25 year 24 hour rainfall.

Depending on the condition of your shop you might already have secondary containment. The building itself serves as secondary containment. If a spill cannot go down a drain or exit the building, then the building can act as adequate secondary containment. Remember you are only concerned with containing the single largest container which is the 300 gallon tote.

No, it is not CRDM (USING is the critical term). The double walled tank by itself meets the requirements of CRDM, because the tank operator must visually detect a release. It is the operation of relying on a sensor for leak detection that excludes the “practice or operation” from meeting the CRDM requirements. If a tank operator has a double walled tank with a sensor, they must visually inspect the interstitial space periodically to qualify the system/practice as meeting CRDM.

CONTINUOUS RELEASE DETECTION METHOD (CRDM) – A means of detecting a release of liquid through inherent design. CRDM is passive because it does not require sensors or power to operate. Liquid releases are visually detected by facility operators (See Appendix A for additional information).