EPA recently finalized changes to the SPCC regulations.  Most colleges and universities are required to have SPCC plans because they have aboveground oil storage capacity of greater than 1,320 gallons.  In 2006, EPA amended the regulations to allow facilities with aboveground oil storage capacity of 10,000 gallons or less to self-certify their SPCC plans in lieu of certification by a professional engineer.  The 2009 changes streamline the SPCC plan requirements even further for qualified Tier I facilities (aboveground oil storage capacity of 10,000 gallons or less and maximum individual aboveground oil container capacity of 5,000 gallons or less) by giving them the option to complete a self-certified SPCC plan template instead of a full SPCC plan.  The template is provided in an appendix to the regulations and cannot be used by facilities that employ alternative compliance methods outlined in the regulations, such as the determination that secondary containment is impracticable for certain tanks on campus.
 
The amendments also include minor changes to other sections of the regulations that may be relevant to colleges and universities including an amended definition of facility (clarifying that contiguous or non-contiguous buildings, properties, parcels, leases, structures, installations, pipes or pipelines may be considered separate facilities), amended facility diagram requirements, amended general secondary containment requirements, and amended integrity testing requirements for containers that store animal fats and vegetable oils.
 
In most cases the latest amendments reduce the regulatory burden imposed by the SPCC regulations.  These changes go into affect on January 14, 2010.  More information on the amendments finalized on November 13, 2009 may be found at the EPA website at: http://www.epa.gov/OEM/content/spcc/index.htm.  
 
Of course, Halloran & Sage is always available to assist with any environmental compliance issues on your campus.