ISSUE 1: Oil Spill / SPCC Plans
Background:
In July 2002, the United States Environmental Protection Agency (USEPA) issued a final rule which amended and attempted to clarify the existing Spill Prevention Control and Countermeasures (SPCC) requirements in 40 CFR Part 112. Since that time, these controversial amendments have been the subject of numerous comments and lawsuits by affected industry, and the implementation dates have been extended several times.
Current Status:
On December 2, 2005, EPA released the "SPCC Guidance for Regional Inspectors", which is useful to facilities preparing SPCC plans. In February 2006, USEPA published a final rule that extends the date for compliance with the 2002 SPCC revisions until October 31, 2007. However, facilities subject to 40 CFR 112 (ie: storing greater than 1,320 gallons of vegetable or petroleum oils) are still required to have SPCC plans in place now.
Ongoing Issues:
A 12 December 2005 proposed amendment would remove the P.E. requirement for certain facilities storing less than 10,000 gallons.
For more information, please contact Ronald A. Rosner, Director of Environmental Consulting, at (314) 880-2787.