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EPA has not historically required the submittal of an SPCC plan to it (see 40 CPR Part 112.3(e) - ".. , shall maintain a complete copy of the Plan at such facility if the facility is normally attended at least 8 hours per day, or at the nearest field office if the facility is not so attended, and shall make such Plan available to the Regional Administrator for on-site review during normal working hours.'. EPA does require an SPCC plan to be certified by a professional engineer. A recommended method for applicants and operators to demonstrate compliance with C.R.S. 34- 32-116(7)(g), and 34-32.5-116(4)(1[) that store oils and fuels in regulated quantities (e.g., more than 1320 gallons of oil or fuel In containers with a capacity of at least SS gallons) within the permit boundary area at a mine or area encompassed by a Notice of Intent (NOI), is to submit documentation, in a form acceptable to the Office, that they have a SPCC plan and that plan has or will be implemented prior to storage of fuel or oil products. It is not necessary to provide the Division a copy of the SPCC plan, but it must be available for review at the facility or the nearest field office during an inspection conducted during nortal business hours. The operator must submit a letter to the Division, on company letterhead, affirmatively stating that the plan has been implemented. Applications and Permit Revisions: If the submittal and site implementation of an SPCC plan is the applicanUoperatorschnice to demonstrate compliance with 1 t6('n(g) or 116(4)(h), as related to protection of ground water quality, changes to the containment structure(s) that affect its function will be addressed in an update to the SPCC plan as necessary within the timefrante specified (e.g., six months per 40 CFR Part 112.5(a)) by the applicable federal or state regulations. An acceptable alternative to the submittal of an SPCC plan would be to provide containment dimensions adequate to enable bond release calculations and containment details sufficient to demonstrate protection of ground water. The Division is making the connection that if the SPCC plan is protective of surface water quality; it likely protects ground water quality. In some instances the addition of an SPCC facility may require a permit revision, in other instances simply a modification to the existing reclamation bond will be all that is necessary. - - -- Examples of instances where a permit revision maybe required include: - - - • The addition of an SPCC facility to an existing permit where an SPCC facility does not exist. • Moving an SPCC facility from an affected area within a permitted site to a site not presently permitted as affected area. • Moving an SPCC facility from an area of no ground water quality impacts to a site where ground water quality maybe affected due to product spill. An example of an instance where a permit revision may not be required: • If an SPCC plan is required for the protection of surface water quality, and the operator demonstrates that no ground water impacts are anticipated at a mine site due to loss of containment, and that there will be no changes to the approved reclamation plan, then changes to an SPCC facility may only requve a surety increase.