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Spill Prevention, Control and Countermeasure (SPCC) Plan Q&A
Q: What federal and state regulations apply to ASTs? A: Unlike USTs, ASTs are not regulated under any comprehensive federal program. However, a
number of separate federal and state laws do provide some regulatory coverage for ASTs. The Clean Water Act (CWA), the California Aboveground Petroleum Storage Act and the Oil Pollution Act of 1990 impose oil spill planning
requirements on a wide range of onshore and offshore facilities involved in the handling and transport of oil. Q: A:
The California Aboveground Petroleum Storage Act defines petroleum as "crude oil, or any fraction thereof, which is liquid at 60 degrees Fahrenheit temperature and 14.7 pounds per square inch absolute pressure." Obviously,
this includes most uses of petroleum. Q: A: California's AST Act covers all ASTs storing petroleum products (not hazardous
waste). The AST Act is intended to ensure compliance with CWA, specifically, the proper development and implementation of SPCC plans. Note that the AST Act does not cover AST construction, permitting, or other
technical requirements – those are usually
determined by local fire departments. Implementation of the AST Act has been assigned to RWQCBs which, in turn, assigned implementation of AST regulations to local CUPAs. A facility is subject to AST regulation if it has at least one AST with capacity greater than 660 gallons, or cumulative aboveground storage capacity of more than 1,320 gallons,
AND because of its location can reasonably be expected to discharge oil in "harmful quantities" into navigable waters or adjoining shorelands OR it has a cumulative storage capacity of 10,000 gallons or more.
Q: A: "Harmful quantities" is defined as discharges of oil that violate applicable water quality
standards, or cause a film or sheen upon or discoloration of the surface of the water, or deposit a sludge or emulsion beneath the surface of the water. Q: A: AST facilities that have a capacity greater than 1,320 gallons (where each tank has a capacity greater than 660 gallons) and that, due to their location, pose a threat to
navigable waters are required by the CWA to meet the following basic requirements:
In addition, all SPCC plans must contain the following information:
Q: Where should I keep my SPCC plan? A: SPCC plans must be kept at the main facility if it is staffed at least eight hours a
day. If not, the SPCC plan must be kept at the nearest field office. Q: A: SPCC plans must be reviewed and evaluated at least every
three years. SPCC plans must also be amended as follows:
Q: What requirements apply to ASTs storing hazardous wastes? A:
RCRA requires that ASTs storing hazardous wastes to be equipped with corrosion protection, secondary containment, and spill/overflow protection. DTSC and your local CUPA enforce these requirements. Q:
A: You must prepare an SPCC plan that meets the federal standards already described and submit biennial storage statements and fees to
SWRCB. Storage statements must identify the name and address of your facility, a contact person, the total storage capacity of all ASTs at the facility, and the location, size, age and contents of each AST that exceeds 10,000
gallons in capacity and that holds a substance containing at least five percent petroleum. The AST fee is calculated on the basis of total storage capacity, as follows:
Q: What do I do if I discover a leak or spill from my AST? A: You must notify your county, city and CUPA immediately if you discover a spill of petroleum of 42 gallons or more. You must also report to the state OES at
1-800-852-7550 or (916) 262-1621. Q: A: The SPCC and facility response plan requirements are only two of the many emergency
planning requirements imposed on facilities that handle petroleum products or other hazardous substances. Agencies and regulated entities have worked for years to attempt to create integrated plans that will comply with all,
or at least most, of the many planning requirements. In June, 1996, the National Response Team (NRT), which oversees emergency responses under the CWA, Oil Pollution Act of 1990(OPA), and Superfund, released Integrated
Contingency Plan Guidance (61 Federal Register 28642; June 5, 1996 – call 1-800-424-9346 to request a copy) which NRT intends facilities to follow in order to comply in a single document with the following requirements:
The NRT developed this guidance following its own incident command system and approaches developed as part of its own responsibilities. The Integrated Contingency Plan also is designed to be able to incorporate
additional federal, state and local planning requirements, though the NRT has no direct control over other agencies.
October, 1998 Above Ground Storage Tanks (ASTs) & Spill Prevention, Control and Countermeasure (SPCC) Plans Many CSRMA members have replaced their underground storage tanks (USTs) with above ground storage tanks (ASTs) in response to the UST retrofit or replace deadline of December, 1998. However, like USTs, there are several regulatory requirements involving the management of ASTs. One of which is the completion of a Spill Prevention, Control and Countermeasure Plan (SPCC) if the tank, its contents and its location meet certain criteria. Even if a member determines they are not legally required to prepare a SPCC plan, it is good risk management to prepare one, anyway. Not only does it demonstrate due diligence in the event of a release and provide for more effective spill mitigation, but it will also significantly lower the risk of a release from occurring in the first place. This Bulletin addresses some of the most common questions regarding ASTs and SPCC plans. If you or your staff should have any questions or would like to receive additional information, please contact: David Patzer Risk Control Advisor (415) 983-512 Visit the CSRMA Web Site at: For Additional Loss Control and General Information
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