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At the Connecticut Business and Industry Association’s (CBIA) 2018 Energy and Environment Conference, a panel of industry experts recommended several best practices and business strategies that companies should consider as part of their spill response preparation process beyond the mandatory Spill Prevention, Control, and Countermeasure (SPCC) requirements.
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?
Q. Would flavorings that contain small amounts of oil (for example, almond and hazelnut oil) count towards an inventory to determine Spill Prevention, Control, and Countermeasure (SPCC) applicability if they are stored in 55 gallon drums or greater?
Q. Is turpentine covered under Spill Prevention, Control, and Countermeasure (SPCC) and what are the spill containment requirements for AST of turpentine?
We treat our compressor condensate prior to discharge using this a crude oil water separator in a 55 gallon drum that has a 24 gallon oil storage compartment. Does the wastewater exemption apply? We are assuming that you are regulated under the federal Spill Prevention, Control and Countermeasure (SPCC) regulations, and that your facility meets […]
Q. Should oil mixed with absorbent (from spill cleanup) be included in a facility’s oil inventory for SPCC purposes? Would it be considered as oil during an inspection?
There is much confusion surrounding the applicability of SPCC requirements. A question that recently came across the desk of one environmental expert involved oil in flavorings. The person asked if flavorings that contain small amounts of oil (for example, almond and hazelnut oil) count towards an inventory to determine SPCC applicability if they are stored […]