iSi to Discuss SPCC's Substantial Harm Criteria at Environmental Conference
iSi's Rohn Hamilton, P.E.
⚡ In short: iSi’s Rohn Hamilton, P.E. presented “Ramifications of Triggering ‘Substantial Harm’ Within the SPCC Plan” at the Midwest Environmental Compliance Conference. Most facilities that store oil don’t know if they meet EPA’s substantial harm criteria — a misclassification can trigger major compliance gaps.
The Presentation
iSi’s Rohn Hamilton, P.E. presented on the ramifications of triggering “substantial harm” within the SPCC Plan at the Midwest Environmental Compliance Conference.
SPCC Plans, or Spill Prevention, Control, and Countermeasures Plans, are EPA-required plans that are implemented at sites in order to prevent the discharge of oil into navigable waters or adjoining shorelines. SPCC Plans outline the procedures that will be used to cleanup a spill should it reach a navigable water and the measures to be implemented to prevent spills from occurring in the future.
Why this matters: Facilities that meet EPA’s substantial harm criteria must develop additional Facility Response Plans. Missing this classification can trigger enforcement action and massive liability if a spill occurs.
Substantial Harm Status
Companies who need SPCC Plans need to further identify whether or not their company additionally qualifies as a substantial harm facility. Facilities which meet any of the substantial harm criteria are then required to develop Facility Response Plans in addition to the SPCC Plans.
Rohn covered how to determine if your facility needs an SPCC Plan and how to tell whether or not your facility additionally meets the substantial harm criteria.
About Rohn Hamilton
Rohn is a professional engineer providing environmental engineering compliance (spill, stormwater prevention, facility response plans) for iSi. He’s a retired Air Force Colonel, who served as the 184 Intelligence Wing’s (McConnell AFB, KS) Chief Bioenvironmental Engineer (environmental, industrial hygiene) and Medical Group Commander. He is also an Airbus 320 Captain for American Airlines.
Conference Details
This year’s Midwest Environmental Compliance Conference was held April 11-12 in downtown Kansas City. iSi was a Silver Sponsor for the event and exhibited as well.
Does your facility meet SPCC’s Substantial Harm Criteria? iSi can help you determine that. We assess your facility’s storage volumes, location relative to navigable waters, and potential impact to determine your classification and required compliance structure. Get a scoped SPCC assessment →
Frequently Asked Questions
Q: What is an SPCC Plan and which facilities require one?
A Spill Prevention, Control, and Countermeasures (SPCC) Plan is an EPA-required plan that facilities must implement to prevent the discharge of oil into navigable waters or adjoining shorelines. SPCC Plans outline cleanup procedures for spills that reach waterways and preventive measures to stop spills from occurring, and are required for facilities that store or handle oil.
Q: What is a substantial harm facility and why does it matter?
Facilities meeting EPA substantial harm criteria must develop Facility Response Plans in addition to SPCC Plans. Substantial harm designation depends on specific criteria related to facility location, oil storage capacity, and proximity to navigable waters, and requires enhanced planning and response procedures.
Q: What is the difference between an SPCC Plan and a Facility Response Plan?
An SPCC Plan addresses spill prevention and cleanup within a facility and its immediate vicinity, while a Facility Response Plan is required for facilities meeting substantial harm criteria and outlines detailed response procedures for large-scale oil discharges into navigable waters. Both are EPA regulatory requirements for qualifying facilities in Kansas City and other locations.
Q: How do I know if my facility qualifies as a substantial harm facility?
Determination of substantial harm status depends on EPA criteria including facility location relative to navigable waters, oil storage volumes, and the potential for significant environmental impact. iSi Environmental provides professional engineering services to evaluate your facility’s SPCC compliance requirements and substantial harm status.
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