Here is a reminder that the Spill Prevention and Control Countermeasure (SPCC) plan is applicable to “owners and operators” of onshore and offshore facilities that exceed the threshold of 1320 gallons of oil. 40 CFR 112.3(a) is very clear on that. What that means is that if you are not the owner or operator of a unit that contains oil, you do not need to count that oil against the threshold.
For example, if you have transformer stations that hold hundreds of gallons of oil within your facility boundary and yet you have no operational control or ownership of the transformers (the local utility owns them), you do not have to count the transformer fluid.
The simple questions to ask are: “Do I have access to these tranformers?” , “Do I own them?” and “Am I responsible for making sure they work and maintaining them?” If the answer is no, you are neither the owner nor operator.
Many facilities make the mistake of including the oil in these transformers towards the 1320 threshold and end up preparing an SPCC when they don’t really need to.