Does a construction site that operates under a stormwater discharge permit and has a Stormwater Pollution Prevention Plan (SWPPP) also need a Spill Prevention Control and Countermeasure (SPCC) Plan?
The answer is POSSIBLY; the requirements for a stormwater discharge permit and for a SPCC Plan are independent of each other. Not all construction sites that need a stormwater permit also need an SPCC Plan - and some construction sites that do not need a stormwater permit may need an SPCC Plan.
Whether or not a given construction site needs an SPCC Plan will depend on the oil storage capacity on site, even if storage tanks, mobile tanks, oil-filled equipment, etc are only on-site temporarily. [Read more about SPCC requirements] Individual State programs may also have additional requirements for notification, registration or permitting of above ground storage tanks at construction sites.
Even construction sites that do not exceed the thresholds requiring an SPCC Plan need to have spill prevention and control measures. In most cases this requirement is contained in the site stormwater discharge permit, or in State general duty provisions to prevent and control spills, and to clean up spilled materials.
Caltha LLP offers some very cost effective options for construction sites needing to prepare SPCC Plans, SWPPPs, or to develop spill prevention and response procedures. Click here to request more information on construction site SPCC/SWPPP Services.
For further information contact Caltha LLP atinfo@calthacompany.com
orCaltha LLP Website
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