Saturday, November 8, 2008

Revised SPCC Rules - Connection with Stormwater Permit Compliance

Stormwater discharge permits commonly reference other regulatory requirements. Possibly the most common regulatory reference is that permitted facilities must be in compliance with SPCC Rules (40 CFR 112). Since 2002, the SPCC Rules have been evolving; the result of these changes has been that many more facilities are now subject to SPCC requirements. However, a significant number of facilities are not aware of changes to the SPCC Rule and that they are now subject to this regulation.

The most significant change has been the threshold on oil storage capacity that makes a facility subject to SPCC Rules. Although the threshold for total facility oil storage capacity increased to 1320 gallons, the size of containers which must be included in the calculation decreased to 55 gallons. Now, a facility must add the oil storage capacity for all containers 55 gallons or greater; if the total exceeds 1,320 gallons, the facility is subject to SPCC Rules. Facilities that include a significant drum storage of oil can easily exceed this threshold.

Many of the revisions to the SPCC requirements streamlined compliance requirements and ultimately reduce the complexity and costs associated with compliance. US EPA believed that reducing the overall complexity of the program will improve compliance, especially with small to mid-sized facilities that are affected.

Specifically, the types of facilities that benefited were:

  • Facilities with total oil storage capacity between 1,320 and 10,000 gallons
  • Facilities with certain types of regulated oil-filled equipment
  • Facilities with mobile refueling vehicles

For further information contact Caltha LLP at
Caltha LLP Website

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