Special Topics in Environmental Management

SPCC Plan FAQ Roundup

My facility is required to have a SPCC plan. I am a P.E. and was wondering if I can write and certify my plan.

If you are licensed as a professional engineer, you may write and certify your facility’s SPCC plan. You do not need to be certified in the state in which the facility is located. However, if the state has more restrictive requirements, you must be in accordance with state law.

The SPCC self-certification requirements apply to qualified facilities, giving such facilities the option of using an SPCC plan template to fulfill SPCC plan requirements rather than having a P.E. write and certify the plan. A “qualified facility” is a facility having an aggregate storage capacity of 10,000 gallons or less and, in the last 3-year period, having no single discharge exceeding 1,000 gallons and no two single discharges greater than 42 gallons each in a 1-year period.

Therefore, if your facility meets the requirements to self-certify as a “qualified facility”, you may certify your plan as a P.E. or a non-P.E. If it does not meet such requirements, you may write and certify your plan as a P.E., even though you the plan is for your facility.

In the SPCC regulations, does the piping associated with bulk storage containers require more than general secondary containment?

The SPCC regulations do not specifically address what is required for piping associated with a bulk storage container. However, the EPA guidance for Regional Inspectors states that bulk storage container installations must be constructed so that a secondary means of containment is provided for the entire capacity of the largest single container and sufficient freeboard is provided to contain precipitation. Further, specific sized container requirements are based on a major container failure in which the entire capacity of the container is discharged.

Therefore, because the piping may be considered as part of the bulk storage “installation”, and because a failure of the piping would cause a major container failure in which the entire capacity of the container may be discharged, the piping should have specific sized secondary containment, rather than general secondary containment.