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1) As with all aspects of SPCC compliance, inspectors want to ensure that OWS are consistent with good engineering practices as certified by a professional engineer (PE) or, for qualified facilities, by the owner/operator in the facility’s SPCC Plan.
2) Only OWS that are exempted as wastewater treatment OWS can be left out of the SPCC Plan, and all others must be included. Facility owners/operators should be aware that an inspector will verify that any exempt OWS is in fact used exclusively for wastewater treatment and is not being used to meet any requirements of Part 112 of the SPCC rule. Inspectors will also consider the flow-through capacity of the OWS, the nature of the oil to be separated and whether it is an emulsion, and the design specifications of the unit.
3) Any OWS used for secondary containment will also be carefully scrutinized during an inspection including SPCC elements detailing the separator’s design capacity, configuration, maintenance, operation, and drainage system aspects. Facilities using OWS to provide secondary containment for especially large drainage areas should be aware the EPA will want to make sure that the SPCC Plan adequately depicts the design of the unit (flow-rate and capacity) showing the ability of the OWS to handle potential precipitation and discharge volume. Inspectors will also want to know about routine monitoring and oil removal practices as provided in the facility’s SPCC Plan.
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Among the many specific topics an inspector may want to review concerning OWS used for secondary containment are:
- The presence and configuration of OWS outlets and the presence of other equipment to prevent the accidental release of oil,
- Routine visual inspection of the oil/water separator, its contents, and discharges of effluent,
- Preventive maintenance of facility equipment affecting discharge, including the removal of settled pollutants and collected oil,
- A drainage area that flows to the OWS and corresponding anticipated flow rate of the drainage system to the separator,
- Appropriate capacity of the OWS for oil, wastewater, and, if appropriate, precipitation,
- Provisions for adequate separate storage capacity (based on the containment sizing required by the rule) to contain oil recovered in the oil/water separator, and
- Documentation associated with the maintenance and inspection of OWS.
4) As noted yesterday, if an OWS is not an exempt wastewater treatment unit, its oil storage capacity must be included in the facility calculations.
5) Oil production facilities that use the alternative option for flow-through process vessels in lieu of sized secondary containment under Section 112.9(c)(5), EPA inspectors will need to verify that the facility’s SPCC Plan contains the required records for inspection and testing, corrective action/repairs, prompt removal of discharges.
It’s important to understand SPCC amendments for ongoing compliance. Are you in the know? Join us for an exclusive webinar on July 31 on SPCC Plan Writing for Tier II Facilities. Register now.
6) Facility owners/operators should always maintain the SPCC Plan so that it is adequate, correct and verifies the actual documented OWS uses at the facility. Inspectors will be looking for a range of problems related to SPCC Plans and day-to-day OWS operations including:
- Inadequate and/or inappropriate spill prevention measures,
- Documented uses that are incorrect or deviate from the use described in the SPCC Plan,
- OWS that are not maintained or operated according to the SPCC Plan, and
- OWS that appear to be malfunctioning or out of service.
When an inspector finds such problems or discrepancies, further actions may be taken by the EPA including requests for additional information or SPCC Plan amendments.
While the Spill Containment, Control, and Countermeasure (SPCC) regulations have been in place for more than 20 years, the regulations have been amended—and extended—several times, and as recently as 2010. It’s, therefore, important to understand SPCC amendments for ongoing compliance.
One of the first steps in the SPCC plan process is to determine if your facility is actually required to prepare a plan based on types of operations, types and quantities of chemical usage, and applicability of certain exemptions. If you are not required to prepare a plan, documenting through a negative declaration to your files showing your assessment and calculations is an excellent exercise if questioned in the future.
After performing an assessment, a majority of facilities (approximately 66%) determine that a Tier II SPCC plan is required. Determining exactly what needs to be included in your plan requires a careful evaluation and collaboration by various departments, such as EHS, production, facilities, maintenance, and legal, is essential for plan development success.
Join us for a live webinar on Thursday, July 31, 2014: SPCC Plan Writing for Tier II Facilities: Winning Strategies for Assuring Compliance and Ease of Implementation.
Your speaker, Laura Casey, is a dynamic consultant, presenter, leader and Certified Safety Professional with more than 17 successful years in the Environmental, Safety and Health field. Ms. Casey has provided workshops and training courses both nationally and internationally is highly adept at identifying gaps and or risk exposures in operations as well as developing and implementing strong systems of checks and balances.
Learn more about this upcoming webinar or register now.