Is groundwater “navigable waters” under SPCC?

You have to prepared a SPCC plan if you have more than 1320 gallons in shell capacity AND the potential to impact navigable waters of the United States.

Many people ask the question” “Is groundwater included in the definition of navigable waters under the Spill Prevention Control Countermeasures regulation?”

The short answer is NO.

However, keep in mind that groundwater could act as a conduit for spilled oil to reach navigable waters of the U.S.

Here is what EPA stated in its SPCC Inspection Guide: Facilities should consider “certain underground features (e.g., power or cable lines, or groundwater), (that) could facilitate the transport of discharged oil off-site to navigable waters.”

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