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Q. My client has their 5-year review of their Spill Prevention, Control, and Countermeasure (SPCC) plan due this year. If they find shortcomings, can they still do the 5-year review/certification of the SPCC to be in compliance, if they program and budget in the project to address the shortcoming?
The EPA has issued its first biannual update of its work on a proposal for a final rule that would subject facilities holding hazardous substances to the same requirements applying to facilities holding threshold amounts of oil. The update indicates that the proposal is still in its early stages, and therefore, any views on what […]
Q. In doing calculations for the size of containment, can you include the equilibrium volume of the inside of the storage tank as part of the containment volume? How often should a tank have integrity test done?
Q. If there is a spill of 50 gallons during delivery, do we need to add that in the spill history in the Spill Prevention, Control, and Countermeasure (SPCC) Plan?