Special Topics in Environmental Management

SPCC Q&As: Part I

Will a PE certification be required if active secondary containment measures are utilized instead of permanent measures?

In general, the answer is “no,” but there are a couple of caveats. For secondary containment for permanent storage containers, such as bulk storage containers like tanks, you do have to have permanent secondary containment for those kinds of bulk storage containers; and if you don’t, you have to have a professional engineer (PE) certified that you have an alternative method that is adequate. For other SPCC subject items that require secondary containment, like oil-filled equipment, transfer operations, pipelines, things of that nature, then you can propose active measures to control releases from those kinds of containers that do not have to be certified by a PE.

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Does all oil-containing piping have to be shown on the facility diagrams in SPCC plans?

Yes, and it can be a challenge. Oil transfer piping needs to be shown on the diagram. Again, this may mean that if you have a large or complex facility, you may not be able to put it all on one piece of paper. Your diagram may be more than one sheet.

Under the self-certified plan, what’s the minimum capacity on the containers you must list on your inventory table?

Containers that are 55 gal and greater must be in the plan, so if you have a 54-gal container, it doesn’t have to be in the plan. Most oil products are available for sale in 40-gal or 30-gal containers, I think, in part, motivated by that threshold.

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We have a marina on a public lake. At that marina, there’s a 4,000-gal tank that is double walled. There is no containment wall around that tank, I guess because it is double walled, and we need an SPCC plan?

OK, first of all, you’re double walled. The double-walled tank counts as having secondary containment, point one. Point two: If you have more than 1,320 gal of oil in aboveground containers, you need to have an SPCC plan, so the answer, I would say, is “yes,” you need an SPCC plan.

So a facility can’t relieve itself from SPCC regulation if volume gets down, right? I mean, you’ve still got a tank that can hold all that.

No, the threshold is based on oil storage capacity, not actual oil volume. That hasn’t changed. That’s been true ever since the beginning with the SPCC rule.

See tomorrow’s issue of the Advisor for more Q & As from this popular webinar.