U.S. EPA ISSUES FINAL SPCC REVISIONS,

PROPOSES EXTENSION OF COMPLIANCE DEADLINE:

The U.S. EPA last week published long awaited revisions to its Spill Prevention Control and Countermeasure (SPCC) plan requirements for bulk plants. The agency adopted most of the recommendations offered by PTSA in written comments submitted earlier this year. The revisions are good news for petroleum marketers because they significantly streamline SPCC plan development and implementation for small tanks. Under the revisions, SPCC plans for bulk plants with a storage capacity of 10,000 gallons or less require no involvement of a professional engineer. This means that bulk plant operators may write and certify SPCC plans themselves, which allows significant savings in compliance costs. The U.S. EPA estimates that SPCC plan development and certification by a professional engineer would cost over $2,000 per site. The savings will be particularly significant for marketers with multiple portable tanks because SPCC plan templates can be used for similar tanks. The revisions also eliminate the secondary containment requirement for mobile refueling vehicles that operate solely within a non-transportation facility, such as airports and rail yards, removes animal fats and vegetable oils from SPCC requirements and exempts motive power containers, such as vehicle fuel tanks from the 1320-gallon minimum threshold calculation that determines whether the regulations apply. In a separate rulemaking, the U.S. EPA proposed to extend the SPCC compliance date from October 31, 2007 to July 1, 2009. The U.S. EPA is planning additional revisions to SPCC regulations due out in 2007 that would provide ultra-streamlined SPCC plan preparation for tanks with a capacity between 1320 and 5000 gallons. The U.S. EPA is considering a “check-off” list for these tanks in lieu of a formal SPCC plan. (PTSA Weekly Update) As additional information becomes available the OPMCA will notify members.  

Editor’s note: While the new rulings may seem to relieve tank owners of the time crunch and cost burden of creating an SPCC plan, there is more to think about than this apparent windfall.  Owners still have the responsibility to create and implement a valid plan, regardless of whom is its preparer.  So, experienced Professional Engineers might be able to save you the trouble and liability of home-crafting this potentially tricky document.  Read what John Dzwonczyk wrote in October 2005 on this matter.