SPCC Plans Required For Parked Trucks

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.

Self-Certified SPCC Plans
The oil company can prepare and self-certify (no Professional Engineer (PE) certification) an SPCC Plan if the facility:

  • is a Tier II Qualified Facility: has 10,000 gallons or less in aggregate aboveground oil storage capacity, or
  • is a Tier I Qualified Facility: has 10,000 gallons or less in aggregate aboveground oil storage capacity with no individual storage container greater than 5,000 gallons, and
  • has not had a single discharge of oil to navigable waters exceeding 1,000 U.S. gallons, or two discharges of oil to navigable waters each exceeding 42 U.S. gallons within any twelve-month period, in the three years prior to the SPCC Plan certification date, or since becoming subject to the SPCC Rule if the facility has been in operation for less than three years.

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).

Secondary Containment
Secondary containment is required for all above ground oil storage containers at facilities requiring SPCC Plans. This includes:

  • Parked Trucks: The method of secondary containment depends on what is determined to be the volume of the “most likely” release. Generally, drip pans and absorbents are sufficient (effective January 14, 2010, sized containment is no longer required).
  • Other oil storage containers: Other above ground oil storage containers potentially at the office such as a diesel tank for fleet fueling, a heating oil tank for the office or maintenance garage, and 55-gallon drums for motor or transmission oil need to be included in the SPCC Plan and consequently require secondary containment.

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.