EPA is saying that parked cargo tank vehicles (i.e., delivery trucks) containing product in a parking area (such as one that would be found at an oil company’s office) that is not located at a bulk plant is subject to the Spill Prevention, Control and Countermeasure (SPCC) Rule (40 CFR, Part 112) because a parked truck is considered to be a “non-transportation-related” facility when it is parked with product.
So if there is a reasonable expectation of a discharge into or upon navigable waters of the United States or adjoining shorelines (this includes most locations in Maine), an oil company that doesn’t have a bulk plant must prepare a SPCC Plan for their parked trucks. It is assumed that the truck has the capacity to hold more than 1,320 gallons – most delivery trucks contain between 2,700 and 4,400 gallons.
A comprehensive EPA template found in Appendix G to the SPCC Rule can often be used for Tier I Qualified Facilities. Tier II Qualified Facilities require a full SPCC Plan. Secondary containment, training, inspections, security, etc. are required at all facilities requiring SPCC Plan (self certified or otherwise).
If an oil company parks one or more delivery trucks with product at their office at night, then they are required to prepare a SPCC Plan. The plan can possibly be self-certified and an EPA template may be used in some circumstances. Regardless of whether the SPCC Plan template is used, the SPCC Plan is self-certified or the SPCC Plan is prepared and certified by a PE, the plan must comply with all aspects of the SPCC Rule such as secondary containment, training, inspections, security, etc.