The EPA’s Oil Pollution Prevention regulations require certain facilities to have a Spill Prevention, Control, and Countermeasure (SPCC) Plan. In general, any facility with at least 1,390 gallons of petroleum stored in aboveground containers needs to comply with a specific set of rules. Many solar facilities fall within the purview of these regulations, and understanding these rules now can head off complicated compliance issues later.
Why do solar facilities fall under these regulations in the first place? On-site transformers contain oil as part of their functioning, and it’s easy to cross the regulatory threshold due to the sheer volume of transformers that a solar site requires.
SPCC Plans must contain a wide array of information that includes:
- The number, size, types, and location of all containers storing oil at the facility.
- The location of potential discharge areas to nearby surface waters. Simply put, if there’s an oil leak, where is it going to go?
- Detailed response actions to be followed if there’s a leak or spill, that will both limit the overall scope of the spill and keep you in compliance.
- Measures to be taken to minimize the chances of releases during the transfer of oils into or out of storage containers.
- A description of any methods deployed to contain spill and releases.
- A description of the periodic inspections that must be completed and documented.
SPCC plans are reviewed and updated every five years, and it often pays to check them on a more frequent basis, especially if you’re expanding your site, adding new equipment, or otherwise changing how much you’re responsible for.
As a first step, research both federal and state regulations, and determine how much oil you have on site. That will help you get a sense of the scope of your SPCC Plan, and make sure your facility is compliant before it comes online. Consider using the SPCC as a starting point for a broader plan to manage issues at your facility, as well. As the climate changes and new challenges emerge, being ready for them ensures you get the most from your investment.