The client stores cottonseed oil for use in production at its facility in a shop fabricated bulk aboveground storage tank (AST) with a name plate capacity of 10,150 gallons and a shop fabricated reserve AST of approximately 1,100 gallons. The amount stored in above ground containers exceeded the threshold quantity of 1,320 gallons, which required that the facility prepare an SPCC Plan in accordance with the Environmental Protection Agency (EPA) regulations (40 CFR 112). The client is under contract with its natural gas provider to use only natural gas at its facility.
In addition to the above referenced ASTs, the client maintains a single wall 20,000 gallon underground storage tank (UST) as a backup fuel supply, which was installed in or around 1986 during a facility expansion project. The Massachusetts Board of Fire Prevention Regulations sets forth regulations applicable to ASTs and USTs which may be applicable to this facility.
CAPACCIO submitted a request for a copy of SPCC-related information, including training records, tank testing records, bulk oil storage quantities and locations, oil transfer practices, spill history, location of oil-filled operational equipment, facility plans, and other general operational information from the client. CAPACCIO reviewed topographic and aerial photographic information provided by the client and from available on-line sources for the facility and the surrounding area in preparation for a site visit. CAPACCIO conducted a site visit to the facility to review activities regulated under the SPCC Plan requirements and, in particular, reviewed facility operations where oil was stored, transferred, and used to assess the SPCC requirements for each activity.
CAPACCIO prepared an SPCC Plan based on information provided by the client and information collected during the site visit. The client reviewed the plan and was responsible for addressing SPCC Plan deficiencies including building modifications to provide containment, alternative storage locations, procedural modifications to address spill response, and providing requested information for existing equipment. Upon receipt of comments and completion of facility upgrades, CAPACCIO issued a final SPCC Plan for the facility. The SPCC Plan was prepared and certified in accordance with the revised Section 112.3 (d), which was published in the Federal Register on July 17, 2002. The SPCC Plan addressed the areas required by 40 CFR 112 and specified in the Environmental Protection Agency (EPA) Guidelines under Section 112.7 of the regulations.