Hazardous Materials/Hazardous Wastes Compliance

Citadel EHS delivers trusted hazardous materials and hazardous waste compliance services that help organizations safely manage regulated substances, reduce liability, and maintain full compliance with federal, state, and local regulations.

Our team supports chemical inventory development, ISO 14001 auditing and reporting, and comprehensive environmental permitting and regulatory reviews. We provide expert support for hazardous waste identification and characterization — evaluating waste streams, developing sampling plans, performing representative sampling per EPA and state requirements, and interpreting laboratory results to support proper storage, labeling, transportation, and disposal decisions. We deliver end-to-end CUPA Hazardous Materials Business Plan (HMBP) services, EPCRA reporting, and hazardous waste permitting and compliance, develop and implement SPCC Plans, and support UST and AST permitting, removal, and compliance.

Our practical, compliance-focused approach keeps facilities audit-ready, prevents enforcement actions, and protects employees, communities, and the environment.

SPCC plan requirements

Who needs an SPCC plan

Under 40 CFR Part 112, a non-transportation facility needs a Spill Prevention, Control, and Countermeasure (SPCC) plan if it stores more than 1,320 gallons of oil above ground (counting containers of 55 gallons or more) or more than 42,000 gallons in completely buried tanks, and could reasonably discharge oil to navigable waters or shorelines. The rule covers oil of any kind, including fuel, lubricants, hydraulic oil, and vegetable oils.

What an SPCC plan contains

• A facility diagram and oil storage inventory
• Discharge prevention measures and secondary containment for tanks, drums, and transfer areas
• Inspection, testing, and record-keeping procedures
• Personnel training, security, and spill response procedures
• Professional Engineer certification, or self-certification for qualified facilities storing 10,000 gallons or less

How often an SPCC plan must be reviewed

Facilities must review and evaluate their SPCC plan at least once every five years, and amend it within six months of any change that affects discharge potential, such as new tanks, piping, or a change in operations. Technical amendments must be re-certified by a Professional Engineer. Citadel EHS prepares new plans, completes five-year reviews and amendments, evaluates secondary containment, and trains facility staff.

Hazardous materials business plan (HMBP)

In California, businesses that handle hazardous materials at or above 55 gallons of liquid, 500 pounds of solid, or 200 cubic feet of compressed gas at any one time must file a Hazardous Materials Business Plan with their CUPA through the California Environmental Reporting System (CERS), and review and certify it every year by March 1. Citadel EHS builds chemical inventories, site maps, and emergency response and training plans, and handles annual HMBP filing and CUPA inspection support.