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How do federal Oil Pollution Prevention regulations apply to my data center?
Federal regulations (40 CFR 112) apply to facilities that store oil in amounts greater than 1,320 gallons aggregate aboveground storage capacity and that store oil underground in amounts greater than 42,000 gallons (not subject to 40 CFR Part 280 or all the technical requirements of a State program approved under 40 CFR Part 281). Because data centers have transformers and day tanks for generators containing oil and diesel fuel above these thresholds, they are required to have a Spill Prevention, Control, and Countermeasure (SPCC) Plan on site. Not having a compliant SPCC Plan could result in large federal fines and penalties.
Environmental Quality Management, Inc. (EQ) has prepared SPCC Plans for numerous data centers located across the United States. The first step in preparing the SPCC Plan is to conduct a thorough site inspection of the data center. During the site inspection, all oil-containing tanks, drums, transformers, and generators are inventoried. Site drainage and best management practices pertaining to the oil units are identified. In addition, data center critical facility management staff are interviewed for site details. Following the site inspection and data gathering phase, this information is compiled and an SPCC Plan with detailed scaled site drawings is prepared. In accordance with federal regulations, a registered professional engineer (P.E.) must review and certify the SPCC Plan. Hard copies of the final P.E.-certified SPCC Plan are submitted to the data center for required management review and certification. The SPCC Plan must be kept on site and made readily available to U.S. EPA. Changes at the facility, such as modification of the site drainage or increases and decreases of the number and type of oil storage containers, trigger a requirement to revise the plan and have it recertified by a P.E. within 6 months of the change. The SPCC Plan must be reviewed at least every 5 years and updated as necessary.
For additional information about Oil Pollution Prevention regulations, please contact:
Jill Binzer
Environmental Quality Management, Inc.
(513) 543-1063 (cell)
(513) 742-7268 (office)
jbinzer@eqm.com
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