The spill plan law is now in effect. Do you have a plan? NHADA can assist in creating one if you don't!
If you store greater than 660 gallons of gasoline or have greater than 1,320 gallons of petroleum product (oil, used oil, brake fluid, ATF) on-site, you are required to register your site with the NH Department of Environmental Services (NHDES) and have a Spill Prevention Countermeasure & Control (SPCC) plan.
This past legislative session the law was changed, with NHADA support, allowing facilities that have less than 5,000 gallons of petroleum product, and less than 660 gallons of gasoline, to self-certify their plans as opposed to having an engineer perform this service. Self-certification has long been part of the EPA's program, and the NHDES believes it is appropriate. The EPA currently provides a template, but don’t be fooled, a great deal of work and knowledge of facility operations is required nonetheless.
NHADA has many resources dedicated to SPCC plans including our Loss Prevention staff who perform field audits of your on-site storage, working closely with the NHDES, as well as our bronze-level association partner, GeoInsight. Mike Dacy of GeoInsight – at 314-0820 or mfdacey@geoinc.com – stands ready to assist you with engineer-stamped spill plans and to provide expertise in assessing environmental regulatory and operational risks. He can find cost-effective solutions that protect the value of your business.
NHADA feels that pollution prevention and being prepared is your best course of action. Releases of regulated or hazardous substances are serious issues and ones that can be very costly and may plague your business for years to come. Many circumstances can arise requiring that an engineering firm help you in completing your SPCC plan. Still, there may be instances when self-certification of your SPCC plan is the best and most affordable course of action. Bottomline: It is not a compliance decision to be taken lightly.
If you have questions on environmental issues such as self-certification, SPCC plans, or what option is best for you, let us assist you. Contact me by email at dbennett@nhada.com or feel free to call at 800-852-3372.