When do you have to revise your SPCC?

The regulations say that you must revise your SPCC plan if there are “material changes” in your operation. What exactly is “material change”?

If the petroleum product  you store on site changes from diesel to gasoline, you have made a material change in your operation. You have gone from a combustible product to a flammable product. You must revise your plan. If you change your grade of gasoline from one octane to another, that would not be considered to be a material change.

Another point to remember about SPCC is that it refers to the amount of petroleum product you have onsite at any given time. So you are a marketer of gasoline and you purchase 5500 gallons at one time and then you deliver smaller quantities to your customers over the year until you have 500 gallons left onsite. You are still required to have a SPCC plan since you have more than 1320 gallons during the year.

We discuss SPCC requirements at our 2-day environmental seminars.

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5 responses to “When do you have to revise your SPCC?

  1. I thought the SPCC requirement was based on storage capacity and not how much you have on-site at one time. The Tier II reporting is based on quantity and not volume. Comments?

    • Dale, you are correct. It is the total shell capacity of containers that are equal to or greater than 55 gallons, including oil-filled operating equipment such as transformers and hydraulic systems. There is also no de minimis quantities of “oil.” Thus, any amount of oil or any concentration of “oil” in a mixture triggers the counting of of the covered container. I am not aware of any annual criteria applying to the need for a plan. I will have to take a look at that.

  2. Yes – the regulation refers to the shell capacity. In the example I gave, the shell capacity is the same as the actual capacity and both exceed 1320 gallons at a given time.

  3. What if you have process water ponds that contain oil that leaks in from equipment? Would the entire process pond (99.5% water) be considered a bulk oil storage container?

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