printreg,June,2004SPCC Applicability

printreg, June, 2004
SPCC Applicability


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From: Curt Schmidt(
curt.c.schmidt@thomson.com)
Date: Wed, 2 Jun 2004 08:25:04 -0500
Does anyone have any experience with SPCC requirements in Texas (especially the Dallas area)? We have a data center facility near Dallas that has a generator and a 2500 gallon diesel fuel tan. From what I gather, possible SPCC applicability for the site will hinge on how "navigable waters" are defined and whether such waters exist in the Dallas area. I have a fuel vendor contact in that area who seems pretty knowledgeable regarding SPCC requirements and he insists that Dallas is far from any "navigable waters" and thus SPCC is not applicable. Furthermore, he is unaware of ANY company in the Dallas area with an SPCC Plan. But I know that EPA and the Courts have defined "navigable waters" somewhat broadly. We'll prepare a plan if we have to but I want to ensure it is a legitimate requirement. I would appreciate any information / clarification / opinions.

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