Spill Prevention Control And Countermeasure Plans
The National Oil Spill Prevention, Control, and Countermeasures (SPCC) Program was implemented when its regulations became effective on January 10, 1974, under the authority of the 1970 Federal Water Pollution Control Act. Its constitutional authority dates back to the Commerce Clause, which vesting the United States Congress the power to regulate commerce with foreign nations and among the states, most of which was waterborne in the 18th and 19th centuries. The original Program was intended to protect “navigable waters” from petroleum discharges in “harmful quantities”.
The definition of harmful quantities was and still is an amount which violates an applicable water quality standard, or that causes a film or sheen. Thus, a very small discharge could be considered harmful. The definition of navigable waters has continuously expanded, to the current definition that includes all surface water bodies, regardless of size or navigability.
On July 17, 2002, U. S. Environmental Protection Agency (USEPA) quietly proposed a direct final rule completely rewriting 40 CFR 112 and significantly revising the SPCC Plan requirements. All facilities with gasoline, oil or solvent storage capacity greater than 1,320 gallons will be affected by this rule and must update and fully implement their SPCC Plan by July 1, 2009. The new rule removes many of the “shoulds” of the old rule and replaced them with “musts”. These include requirements to conduct tank integrity testing and provide secondary containment for delivery tankers or rail cars at loading/unloading racks. Relief from the rule is also available for small facilities, oil-filled operating equipment, and other certain classes of storage and containers.
Resolve’s registered Professional Engineers have developed, implemented and certified SPCC Plans at dozens of facilities, including major petroleum tanks farms and oil distribution terminals, airports, military installations, rail terminals and marinas. Our professional stay current on SPCC Rule amendments, industry tank design and inspection standards, including API, STI and NFPA standards. We have designed secondary containment systems for highly corrosive, toxic, and mobile chemicals. Our SPCC Plans are designed for ease of implementation, and can be coordinated with other required response plans into an Integrated Contingency Plan.