By Megan Caffall
Aviation Division
Spill Prevention Control and Countermeasure (SPCC) Plan requirements were originally issued in 1973 by the U.S. Environmental Protection Agency (EPA) under the authority of the Clean Water Act. The SPCC Plan requirements include airports that have a storage capacity that exceeds 42,000 gallons in underground storage; 1,320 gallons in above ground storage (or greater than 660 gallons in a single container) or could reasonably be expected to discharge oil in harmful quantities into navigable U.S. waters or adjoining shorelines.
In July 2002, the EPA amended 40 CFR Part l 12 which governs the SPCC rules, and incorporated deadlines for amending current Plans and implementing changes. Additional amendments to 40 CFR Part l l 2 were issued in April 2003 and again in August 2004 further extending deadlines.
Currently, the Rule states a facility in operation on or before August 16, 2002, must maintain its SPCC Plan and amend it if necessary to ensure compliance with the new rules on or before February 17, 2006, and must implement the amended SPCC Plan as soon as possible, but no later than August 18, 2006. A facility that becomes operational between August 16, 2002, and August 18, 2006, must prepare and implement an SPCC Plan on or before August 18, 2006.
The EPA SPCC Rule requirements have always included provisions requiring secondary containment for mobile or portable oil storage containers and include aviation refueler trucks in their definition of mobile or portable storage containers. Because of the impracticability, safety concerns and expense of providing containment around aviation refueler trucks, the American Association of Airport Executives (AAAE), National Air Transportation Association (NATA) and other aviation groups have petitioned the EPA for clarification of requirements and extension of deadlines for meeting and implementing the necessary changes to airport SPCC Plans.
The SPCC Plan must be certified by a licensed professional engineer and is intended to be a user-friendly living document. The map and facility code are key elements that should enable anyone who discovers a spill to quickly locate the spill on the map, determine type of spill, the maximum volume of the spill, the capacity of secondary containment, the location of clean-up or containment materials, and reporting and record keeping requirements. The SPCC Plan is also an agreement among the owner, operator and regulators regarding proper oil storage and transfer activities that will be conducted to prevent harmful oil spills.
A complete description of the required elements of an SPCC can be found at the EPA Web site www.epa.gov/oilspill/spccmust.htm. Professional services for preparation, annual updates and education are eligible expenses under the Routine Airport Maintenance Program (RAMP) grant program. If you need assistance with your Plan or need to implement a Plan, contact Megan Caffall at 800/687-4568 or [email protected] for grant information.
