Q: What should I do if an EPA or engineer’s inspection finds deficiencies in loading or unloading containments that should be addressed by the SPCC Plan?
A: A common deficiency at petroleum distributor storage facilities is inadequate or deficient truck loading or unloading containment. This deficiency may be identified by an EPA inspection but more frequently, it is recognized by the SPCC engineer. This condition must be addressed under the federal SPCC rules quickly by completing a written review and evaluation of the existing SPCC plan. Within the next six months, the SPCC plan must be amended. After that, the required upgrades must be accomplished within the following six months. In addition, the operator typically needs to be advised by the SPCC engineer on how to correct this deficiency, for example, by designing and constructing such containment and working with the operator to assure these upgrades are implemented within the allowed one year.
Clearly it is beneficial to identify and address such deficiencies before an EPA inspection that will almost certainly lead to costly penalties, imposed environmental projects, legal and engineering fees, other costs and related disruptions. All of these costs will be in addition to the upgrades. A negative EPA inspection can also lead to subsequent EPA scrutiny of the operator’s compliance with other environmental regulations.
Q: Do design, construction, operation, or maintenance changes at a petroleum storage facility require an SPCC Plan update?
A: Yes, some changes materially affect its potential for a discharge and require a SPCC Plan to be updated and PE certified. Such changes include:
- Repairs to a tank farm, such as increasing the containment wall height or sealing cracks in the concrete.
- Addition of the filling of lubricant totes, drums and 5-gal cans to the operation.
- Addition of the filling racing gas 5-gal cans to the operation. (5-gal cans are otherwise exempt but the transfer of racing gas subjects the operation is subject to SPCC rules.)
- Changes to loading or unloading equipment or procedures, e.g., switching from top to bottom loading of trucks.
- Moving of loading or unloading areas.
- Installation, replacement or reconstruction of piping system
However, the SPCC Plan does not need to be updated nor PE certified if the changes do not materially affect its potential for a discharge or are exempt. Such changes include:
- Changes to propane storage (however, propane storage tanks must be shown on the site plan drawing (facility diagram)).
- Changes to or the addition of USTs (underground storage tanks) (USTs should be indicated on site plan drawing and marked as “Exempt”.)
- Revision of maintenance procedures.
- Replacement of piping system in a tank farm with no change in piping arrangement.