O'Brien & Gere was retained by the Buffalo Sewer Authority (BSA) to prepare a Storm Water Pollution Prevention Plan (SWPPP) and a Spill Prevention Control and Countermeasures Plan (SPCC) for the Bird Island Wastewater Treatment Plant. At the request of BSA, O'Brien & Gere confirmed with the New York State Department of Environmental Conservation (NYSDEC) that the facility’s storm water discharges were required to be permitted under the General Permit for Storm Water Discharges Associated with Industrial Activity (Permit No. GP-98-03). The facility also utilizes various petroleum products on-site, which are stored in aboveground storage tanks (ASTs), 55-gallon drums, transformers, and smaller containers. The four ASTs have a total combined capacity of 309,000 gallons. Based on the oil storage capacity at the plant, and the reasonable likelihood for the discharge of oil into navigable waters of the United States, a SPCC Plan was required.