New SPCC template for Tier 1 facilities

EPA has published an SPCC template for facilities that qualify as Tier I. These facilities do not need to get their SPCC plans certified by a Professional Engineer.

To meet the Tier I applicability criteria, the facility must have:

  1. a total aboveground oil storage capacity of 10,000 U.S. gallons or less;
  2. no aboveground oil storage containers with a capacity greater than 5,000 U.S. gallons; and
  3. in the 3 years prior to the date the SPCC Plan is certified, had no single discharge of oil to navigable waters or adjoining shorelines exceeding 1,000 U.S. gallons, or no two discharges of oil to navigable waters or adjoining shorelines each exceeding 42 U.S. gallons within any 12-month period.*

*Please note: this does not include discharges that are the result of natural disasters, acts of war, or terrorism. When determining the applicability of this SPCC reporting requirement, the gallon amount(s) specified (either 1,000 or 42) refers to the amount of oil that actually reaches navigable waters or adjoining shorelines not the total amount of oil spilled. EPA considers the entire volume of the discharge to be oil for the purposes of these reporting requirements.

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3 responses to “New SPCC template for Tier 1 facilities

  1. I see that bulk storage containers need to be inspected monthly. How often do oil filled electrical transformers, more than 55 gallons, need to be inspected and where is the chapter?

    • Jim,

      According to EPA Guide to SPCC Regional Inspectors, oil filled electrical transformers are classified as “oil-filled operational equipment”. The list includes hydraulic systems, lubricating systems (including lubricating systems for pumps, compressors, and other rotating equipment), gear boxes, machining coolant systems, heat transfer systems, transformers, other electrical equipment, and other systems containing oil to enable operation. I am not aware of any specific frequency of inspection for transformers. I believe EPA’s position is that the frequency should be set in accordance with good engineering practices and commonly accepted industrial standards. In 40 CFR 112.7(k)(2)(i), it says that the facility “must establish and document the facility procedures for inspections or a monitoring program to detect equipment failure and/or a discharge”.

      • Hello Norman,
        This information is extremely helpful.
        The EH&S group thinks that transformers must be inspected monthly.
        I read the same standard you quote years ago but could not locate it.
        Now I can use this information in the next meeting.
        Thank you for the quick response.
        Jim.

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