Oil SPCC Plans for Non-Industrial Facilities Part 1: Compliance

As an owner/operator of a non-industrial facility, it may be surprising that an oil pollution prevention rule (40 CFR 112) of the U.S. Environmental Protection Agency (USEPA) may apply to your facility. There are two reasons that this is so:

1. The USEPA changed the regulations under 40 CFR 112 about a decade ago to include not only oils in “storage” but also oils “in use.” This change meant that equipment such as hydraulic units and facility-owned, oil-filled electrical transformers were included.
2. There has been a significant increase in the installation of emergency electrical generators using diesel fuel to back up critical equipment, particularly for IT systems.

The oil pollution prevention regulations and its required Oil Spill Prevention, Control, and Countermeasure (SPCC) Plan will apply to a facility if the following condition is met: Counting only those containers that have a capacity of 55 gallons or more, the total oil capacity is 1,320 gallons or more. A facility that has an elevator operated by a large hydraulic unit, a few ground-mounted, electrical transformers, and one or two diesel-powered electrical generators could easily have more than 1,320 gallons of oil capacity.

Check back next week for part 2 of this article, in which we discuss the types of Oil SPCC plans and what must be included in any Oil SPCC plan, regardless of type.

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