If a facility moves (their address changes) is it assigned a new RMP Facility ID?
Yes. The facility is treated as a new facility and would be assigned a new number by EPA.
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Yes. The facility is treated as a new facility and would be assigned a new number by EPA.
No. EPA has defined environmental receptors as natural or state parks, forests, or monuments; officially designated wildlife sanctuaries, preserves, refuges, or areas; and Federal wilderness areas, that are easily identified on local U.S. Geological survey maps (40 CFR §68.3). Therefore, wetlands would not be reported in the hazard assessment under…
Can a facility submit a partial risk management plan (RMP) (e.g., using the predictive filing option) and then update the plan when all elements of the RMP can be implemented? No. Facilities should not attempt to submit partial risk management plans (the RMP*eSubmit software will not allow incomplete RMPs to…
If I have a large on-site incident, but no offsite impact, would I have to report it in the five-year accident history? It would depend on whether you have onsite deaths, injuries, or significant property damage. You could have a large accident without any of these consequences (e.g., a large…
Minor repair and maintenance activities are not subject to the requirements of the Lead Renovation, Repair, and Painting (RRP) Rule. For exterior renovations, minor repair and maintenance activities are those activities that disrupt 20 square feet or 29 less of painted surface, and do not use prohibited practices or involve…
Yes. SPCC regulations do not mandate design specifications, rather, they are performance based. Therefore, a containment wall may be of any construction type, material, or design, assuming it meets the performance standards and requirements of Part 112. Regional offices can help determine whether individual containment equipment meets the performance standards…
What is the qualifying criterion for the option for qualified oil-filled operational equipment? Equipment is eligible if the facility did not discharge from any oil-filled operational equipment (1) more than 1,000 U.S. gallons of oil in a single discharge to navigable waters, or (2) discharge more than 42 U.S. gallons…
Pursuant to 112.7(f)(1), the owner or operator of a facility subject to the SPCC regulations must train oil-handling personnel in the operation and maintenance of equipment, discharge procedure protocols, applicable pollution control laws, rules and regulations, general facility operations and the contents of the facility SPCC Plan. For the purposes…
In the 2008 Amendments to the SPCC Rule, EPA provided a template for the owner or operator of a Tier I qualified facility to create an SPCC Plan. Does EPA require a Tier I qualified facility to use the template in 40 CFR Part 112, Appendix G? Does EPA allow…
No. This is an alternative way to comply with the SPCC requirements. An owner or operator can choose to comply with the general requirements to provide secondary containment for each piece of oil-filled operational equipment.
Some facilities must meet the requirements of two or more federal agencies, because they engage in activities that fall under the jurisdiction of those agencies. These agencies include the U.S. Coast Guard, the Department of Transportation's (DOT) Office of Pipeline Safety, and EPA. A 1971 Memorandum of Understanding (MOU) between…
The SPCC general applicability in 40 CFR §112.1(b) refers to a discharge of oil in quantities that may be harmful, as described in Part 110. Part 110 is often referred to as the sheen rule. Does a product or substance have to create a sheen to be subject to SPCC…
Animal fat means a non-petroleum oil, fat, or grease of animal, fish, or marine mammal origin. Vegetable oil means a non-petroleum oil or fat of vegetable origin, including but not limited to oils and fats derived from plant seeds, nuts, fruits, and kernels.
Does a facility need to fill out Attachment C-II in 40 CFR Part 112, Appendix C if the facility is only subject to the SPCC regulations and is not subject to the Facility Response Plan (FRP) requirements? If the owner or operator of a facility determines that the facility is…
The exemption is for all milk and milk product containers, piping and appurtenances, but does not exempt containers that store other oils, such as petroleum oil at dairies, milk producers and milk product manufacturing facilities. These facilities will not have to account for, or address the exempt milk and milk…