We discuss Tier I Self Certified SPCC Plans.
We get a lot of requests for information about SPCC Plans. Normally when people come to us for help, it's because they've either gotten in trouble, or are looking to stay a step ahead of the regulators. A Tier I plan is something small, easy, and relatively simple to understand, and not having an SPCC Plan can carry significant penalties.
Remember, these are inspected by the USEPA. These guys don't play around, and if they show up, and nail you for one thing, they usually get you on other environmental compliance issues.
It's great that people are looking to learn about them. They're a solid piece of insurance in case something bad happens on-site, and can help prevent injury to personnel and the surrounding environment. Having one can turn a potential disaster into an easily manageable problem.
So what is a self certified Tier I SPCC Plan?
It's a Spill Prevention, Control and Countermeasure Plan. It's basically a document that outlines what kinds of oils you have on-site, how much you have, and in case something unexpected were to happen, like a spill or leak, how you're going to go about taking care of it. Easy enough to understand, right?
So specifically, a Tier I Plan is what I like to call an entry-level plan. It covers a small facility with a relatively small amount of oil on site. The specifics of it are:
- You need to have at least 1,320 gallons of oil on site. This includes any oil container that's 55-gallons or greater, including 55-gallon drums, plastic totes, above ground tanks, mobile tanks, and any machinery with oil tanks in them such as generators.
- You can't have more than 10,000-gallons of oil on site. Over 10,000-gallons means you need a PE Certified Tier II SPCC Plan.
- You can't have any tanks larger than 5,000-gallons on site. A tank over 5,000-gallons automatically bumps you to a Tier 2 Self Certified SPCC Plan.
- No discharges of oil to navigable waters in the past 3 years. Specifically, a single discharge of over 1,000-gallons, or two discharges each of 42-gallons or more over the last 12 months. This does not include releases related to natural disasters, acts of war, or terrorism.
- Remember, consider oil only! Oil, gas, diesel, etc. I frequently see people include antifreeze of diesel exhaust fluid - don't do that.
So a Tier I SPCC is for a facility with no oil spills in the past three years that has at least 1,320-gallons of oil products on-site, with no tank over 5,000-gallons, and not exceeding 10,000-gallons in total.
If you think you may need an SPCC Plan, get one, no matter what kind you need. If you don't have one, and need one, it's a matter of time until you get in trouble with the USEPA. To reach out, feel free to shoot us an email at info@rmagreen.com, click here to contact us, or give us a call anytime at 888-RMA-0230 to learn how we can help.
