Ask the Expert, EHS Career Trends/Certification, Q&A

SPCC: PE Certified Revision Required

Q. Does replacing a 1000 gallon UST with an 8000 gallon UST in the same location require a PE-certified revision to the SPCC Plan if nothing else has changed at the site?

A. If both USTs, the one being replaced and the new one being installed, are subject to all of the technical requirements of the federal UST regulations at 40 CFR 280, or all of the technical requirements of a State program approved under 40 CFR 281, or they supply emergency diesel generators at a nuclear power generation facility licensed by the Nuclear Regulatory Commission, the USTs would be exempt from the SPCC rule.
However, these USTs must be included in the facility diagram and marked “exempt” if the facility is otherwise subject to the SPCC rule.

Replacement of the 1,000-gallon UST with a larger tank would require a change in the facility diagram. However, changes to the facility diagram are considered administrative in nature and do not require PE certification.

If the USTs are not exempt from the SPCC rule because they don’t meet the exemption requirements, then replacing the 1,000-gallon UST with a larger tank would increase the oil storage capacity at the facility and would therefore require a technical amendment to the plan and require PE certification.