SPCC Plans for Airports – Recent Lessons Learned on How to Account for Mobile Equipment and Above Ground Storage
In accordance with the Oil Pollution Prevention regulation (40 CFR Part 112), the United States Environmental Protection Agency (USEPA) requires certain facilities to prepare, amend, and implement Spill Prevention, Control, and Countermeasure (SPCC) Plans. SPCC Plans are required if a facility stores greater than 1,320 gallons of oil in above-ground storage in containers equal to or greater than 55 gallons in capacity or has 42,000 gallons of completely buried oil storage capacity and has a “reasonable expectation of an oil discharge” to waterway or adjoining shoreline.
EEC has completed numerous SPCC Plans at facilities across the country including military bases, oil refineries, and many other industrial settings. Recently when conducting SPCC compliance at airports across the United States we observed inconsistencies with regard to the reporting of mobile or ground support equipment (GSE) and the necessary inspection requirements of above ground storage tanks (ASTs).
Mobile Ground Support Equipment
Mobile or GSE equipment and tanks (bowsers) are moved throughout operating areas of airports and go in and out of service for maintenance on a as needed basis. Our review of prior SPCC Plans found that many practitioners have incorrectly assumed that mobile equipment is not SPCC regulated, mobile equipment out of service does not count towards your 1,320-gallon threshold, and/or mobile equipment does not require secondary containment. All these assumptions are inaccurate. Active and out of service mobile equipment with tank capacity equal to or greater than 55 gallons are SPCC regulated and should be accounted for in your SPCC Plan. In addition, mobile equipment must be located within applicable general secondary containment when not in use as defined by SPCC regulations. However, the general secondary containment does not have to account for the full capacity of the mobile equipment.
Above Ground Tank Inspection Requirements Review of previously prepared SPCC Plans also identified incorrect assumptions regarding AST inspection requirements, that can result in needless costs to an AST owner/operator. The fact is that not all ASTs are created equal and therefore do not require equal inspections. Inspection frequency and requirements significantly vary between different categories of ASTs. Most ASTs at airports are Category 1 which are shop-fabricated with spill control and continuous release detection methods (CRDMs) such as a release prevention barrier (RPB), double-walls or double-bottoms, elevated ASTs (with or without RPB), and/or secondary containment. For ASTs 5,000 gallons or less, this category only requires documented periodic monthly inspections conducted by the owner/operator and inspections after repairs are made to the AST.
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