( ) SPCC Plan has been prepared in accordance with good engineering practices (40 CFR 112.7).
( ) The SPCC Plan has been certified by a PE or self-certified (40 CFR 112.3(d)).
( ) The SPCC Plan has the full approval of management at a level of authority to commit the necessary resources to fully implement the provisions of the plan (40 CFR 112.7).
( ) The SPCC Plan has been prepared in writing (40 CFR 112.7).
( ) The details of installation and operational start-up are discussed if the Plan calls for additional facilities or procedures, methods, or equipment that are not yet fully operational (40 CFR 112.7).
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( ) A facility diagram that shows physical layout of the facility has been prepared that marks the location and contents of each fixed oil storage container (40 CFR 112.7(a)(3)).
( ) The location of completely buried tanks that are otherwise exempted from SPCC requirements are also shown on the diagram (40 CFR 112.7(a)(3)).
( ) The facility diagram also includes all transfer stations and connecting pipes (40 CFR 112.7(a)(3)).
( ) The Plan also outlines the type of oil in each fixed container and its storage capacity (40 CFR 112.7(a)(3)(i)).
( ) Discharge prevention measures, including procedures for the routine handling of products, e.g., loading, unloading, and facility transfers, are included (40 CFR 112.7(a)(3)(ii)).
( ) A discussion of discharge or drainage controls, such as secondary containment around containers and other structures, equipment, and procedures, is included in the Plan (40 CFR 112.7(a)(3)(iii)).
( ) Countermeasures for discharge discovery, response, and cleanup (both the facility’s capability and those that might be required of a contractor) are discussed (40 CFR 112.7(a)(3)(iv)).
( ) The Plan discusses methods of disposal of recovered materials in accordance with applicable legal requirements (40 CFR 112.7(a)(3)(v)).
( ) The Plan includes a contact list and phone numbers for the facility response coordinator, NRC, cleanup contractors with whom you have an agreement for response, and all appropriate federal, state, and local agencies that must be contacted in case of a discharge (40 CFR 112.7(a)(3)(vi)).
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( ) Information and procedures are included in the Plan to enable a person reporting a discharge to relate information about:
- The exact address or location and phone number of the facility
- The date and time of the discharge
- The type of material discharged
- Estimates of the total quantity discharged
- Estimates of the quantity discharged that affects public health or the environment
- The source of the discharge
- A description of all affected media
- The cause of the discharge
- Any damages or injuries caused by the discharge
- Actions being used to stop, remove, and mitigate the effects of the discharge
- Whether an evacuation may be needed
- The names of individuals and/or organizations that have also been contacted (40 CFR 112.7(a)(4))
See tomorrow’s Advisor for the rest of the SPCC planning checklist.
Estimates of the total quantity discharged