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SPCC regulations apply to just about every type of oil and the tank and containers that store it, when thresholds are met. As a result, SPCC planning is highly detailed and requires a significant level of facility and site knowledge. For covered facilities (excluding oil drilling, production and workover), higher oil storage capacities also represent greater potential for discharges that can harm the environment and cause health-related issues in local communities.
So when it comes to SPCC inspections, recently revised guidance for regional inspectors offers owners and operators a look at exactly what inspectors will be looking for as they review SPCC Plans and facilities. Here a few tips based on that guidance to help facilities prepare.
1) Double check basic facility information to make sure every necessary item is provided, including:
- Latitude, longitude and GPS datum,
- Section/Township/Range, FRS #/Oil database ID, and ICIS number,
- Required contacts including facility contact and operator contact, and
- Types of oil stored.
Learn a detailed analysis of the SPCC regulations as they apply to aboveground storage tanks and much more during our in-depth webinar on March 12, 2014.
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2) If a SPCC Plan is certified by a Professional Engineer (PE), the following statements attesting to the following are required by Section 112.3(d):
- The PE is familiar with the requirements of 40 CFR part 112,
- The PE or agent has visited and examined the facility,
- The Plan is prepared in accordance with good engineering practice including consideration of applicable industry standards and the requirements,
- Procedures for required inspections and testing have been established, and
- The Plan is adequate for the facility.
3) When material changes have occurred at a facility that impact the potential for a discharge Section 112.5 requires that:
- The SPCC Plan be amended within six months
- The amendments (e.g., changes) be implemented within six months of the Plan amendment
- The five-year review and evaluation must be documented and include amendments made following that review to include more effective, field-proven prevention and control technology, and
- Technical changes made to PE-certified plans must also be certified by a PE.
4) Facility descriptions and diagrams required in Section 112.7(a)(3) must be prepared and available including:
- Diagrams showing all fixed, mobile and portable oil containers (including exempt underground tanks), transfer stations and connecting pipes,
- Type of oil and storage capacity for all fixed containers,
- Type of oil and storage capacity for all mobile or portable containers (or estimates of the same based on potential),
- Discharge prevention measures,
- Discharge or drainage controls,
- Countermeasures for discharge discovery, response and cleanup (both facility’s and contractor’s resources),
- Methods of legal disposal of recovered materials, and
- Contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with an agreement for response, and all federal, state, and local agencies who must be contacted in the case of a discharge.
Join us for an in-depth webinar on March 12 where our speaker, an experienced EHS professional who has helped many companies develop compliant SPCC plans, will provide participants with clear guidance on how to assure that their existing AST-related plans are compliant. She will also discuss the recent revised SPCC guidance for regional inspectors.
Training can be especially problematic (and often cited in enforcement actions) if personnel capabilities do not meet Plan requirements and facility needs. Section 112.7(f) covers personnel, training and oil discharge procedures including:
- Training of oil-handling personnel in the operation and maintenance of equipment to prevent discharges, discharge procedure protocols, applicable pollution control laws, rules, and regulations, general facility operations, and contents of the SPCC Plan,
- Identification of a person who is designated as accountable for discharge prevention at the facility and who reports to facility management, and
- Discharge prevention briefings conducted at least annually for oil-handling personnel to assure adequate understanding of the SPCC Plan. These briefings should include examination of known discharges as described in Section 112.1(b) or failures, malfunctioning components, and any recently developed precautionary measures undertaken at the facility.
It is easy to see from these examples that SPCC inspections literally follow the letter of the law and as a result, so should facility owners and operators. Tomorrow we will review enforcement actions against three facilities that did not take that advice to heart.