Contributed by Holden Volentine, Project Manager, PPM Consultants
There have been many discussions and guidance regarding Spill Prevention Control & Countermeasures (SPCC) Plans required by 40 CFR Part 112. However, not much light has been shined on the Louisiana state required Spill Prevention and Control (SPC) Plan.
The SPC Plan is required by LAC 33:IX Chapter 9 of the Louisiana state regulations. The purpose of the SPC plan is to:
- Identify potential sources of spills from your facility which may reasonably be expected to affect waters of the state.
- Describe and ensure implementation of practices and procedures which you will use to reduce or minimize spills being discharged from you facility; and
- Document the facility procedures in the event of a spill.
With regard to oil storage triggering regulatory applicability, the federal requirement (40 CFR Part 112) and Louisiana’s state requirement (LAC 33:IX Chapter 9) mirror one another. This includes the following main points:
- Minimum aggregate aboveground storage capacity of oil is 1,320 gallons or greater
- For the purposes of this aggregate quantity, only containers with a capacity of 55 gallons or greater are counted
- Oil is defined as any kind or form of oil, including but not limited to: fats, oils, or greases from animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and other oils and greases including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, and oil mixed with waste other than dredged spoil.
Where the federal and state regulations mainly differ is in regard to the inclusion of on-site chemicals. The federal regulations do not include any verbiage or requirements regarding stored chemicals at a facility, while the state regulations define the applicability for inclusion of stored chemicals in the SPC plan.
LAC 33:IX Chapter 9 states that all liquids (at standard temperatures and pressures) that have a reportable quantity that are listed in the Notification Regulations and Procedures for Unauthorized Discharges (LAC 33:I.3931) and that have a minimum aboveground storage capacity of 1,320 gallons for two or more individual containers in aggregate within a common storage area, or 660 gallons for an individual container. For the purposes of this aggregate quantity, all containers greater than one gallon are counted.
Other differences between SPCC & SPC plans include the following:
- Process or conveyance equipment need to be counted and included in SPCC plans, while you are allowed to exempt process or conveyance equipment from SPC plans as long as drainage from the process area is routed to a Louisiana Pollutant Discharge Elimination System (LPDES) permitted outfall.
- Site security, personnel training, and site inspections are required for a SPCC plan while all are only recommended for SPC plans.
- Plans must be kept on site if the facility is manned for 8 hours based upon SPC, and 4 hours based upon SPCC.
- A Professional Engineer (PE) certification is not required for SPC plans.
A Louisiana facility applicable to both SPCC and SPC is allowed to prepare one plan that encompasses both the state and federal requirements. Remember that SPCC requirements are generally more stringent; however, SPC regulations cover substances other than oil.
If you have any questions regarding SPC or SPCC requirements or would like our team to help you in any way, please reach out to me at holden.volentine@ppmco.com.