In one of BLR®’s latest webinars, a national expert on oil spill prevention debunks 5 common myths about the Environmental Protection Agency’s standards for storing large quantities of oil.
Todd McIntyre, Senior Environmental Compliance Manager, E-Recycling Services at SourceAmerica
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Todd McIntyre used to be a really busy guy. When he was program manager for Leidos, the fourth largest American defense contractor in the United States as of 2012, Todd created at least 15 different oil spill prevention and response plans for military sites as required by federal Spill Prevention, Control and Countermeasure (SPCC) regulations.
The SPCC rule mandates that companies properly store and dispose of oil stored for use in operations near navigable waters—meaning Todd here was responsible for everything from picking the right oil containers to designing secondary containment plans and much, much more.
Since Todd is now a senior environmental compliance advisor based in Maryland, we at BLR recruited him to sort fact from fiction for you in regards to federal SPCC regulations (we’ll post the webinar as soon as it’s live).
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Myth #1: Gasoline, biofuel and diesel fuel aren’t considered “oil” under SPCC.
Totally False: All three types of fuel are derived from petroleum products and therefore are regulated as oil products and subject to the SPCC Rule, Todd says.
Half-Truth: Strictly according to the regulation, Todd explains, any facility storing more than 1320 gallons needs to be fenced. There may be situations where it is impracticable to fence the facility, in which case you will need to work with your cognizant regulatory agency to determine an exemption or environmentally equivalent approach.
Half-Truth: Heating oil containers (except for single-family residences) would be included under the SPCC Rule for determining if you need an SPCC Plan if they hold more than 1,320 gallons of oil or oil product, according to Todd.
Half-Truth: If you are strictly in the transportation business, your tanker trucks would be subject to Department of Transportation rules, not the EPA’s SPCC regulations, Todd says. However, if you keep product in the tanker trucks while they are parked on your facility, or store oil products in your property (such as for fueling your trucks) you may be subject to the SPCC Rule.
Myth #5: Having an SPCC Plan is only required in certain states.
Totally False: Todd confirms there are no regional exemptions for the SPCC Rule–only categorical exemptions for certain types of facilities, such as wastewater treatment plants.
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If your facility is SPCC-regulated, Todd recommends training your oil-handling employees to comply with SPCC regulations. That may include using and keeping record of inspection checklists for your storage tanks and oil-containing machinery to stay in compliance with the EPA. [TRAC360] –Angela Hunt