The SPCC regulations entail numerous requirements for the storage of oil. The intent of this paper is to summarize several of the complex requirements associated with oil storage at a facility subject to the SPCC regulations.
The Spill Prevention, Control, and Countermeasure (SPCC) regulations are far reaching requirements promulgated by the Environmental Protection Agency under Section 311 of the Clean Water Act (CWA). The purpose of these regulations is to prevent the discharge of harmful quantities of oil/petroleum to waters of the United States. Originally issued in 1973, the regulations have recently been revised to clarify the regulatory language, provide flexibility in complying with the regulations by incorporating industry standards, and incorporate provisions to decrease the regulatory burden on many facility owner/operators. However, with this revision, compliance with many aspects of the regulations has become significantly more complex. As a result, revisions to these regulations continue as of this writing due to the complex and burdensome requirements stipulated in the regulations. Further, the EPA has issued regulatory
guidance for its regional inspectors1 to assist in enforcing this complex set of regulations.
Integral to the SPCC regulations are provisions regarding the storage of oil. This includes the storage of oil in bulk as well as oil “in-use” such as electrical transformers or hydraulic systems. The provisions cover primary and secondary containment materials, measures for monitoring tanks, inspection requirements, and tank integrity testing.