TEAM
Consultants
SPCC
Plan Update – Are You Ready?
On
July 17, 2002 the United States Environmental Protection Agency (US EPA)
updated the Oil Pollution and Response; Non-Transportation-Related Onshore and
Offshore Facilities rules. The Spill
Prevention Control and Countermeasures (SPCC)
requirements were originally promulgated on December 11, 1973.
The last time the plan was revised was July 1, 1994, when the Facility
Response Plan (FRP) was added.
The
latest update to the plan requires the owner / operator to revise their
existing SPCC plans to comply with the new rule.
The original deadline for updating the plan was February 17, 2003. The
revised SPCC plan was to be implemented by August 18, 2003.
On August 1, 2004, EPA published a revised SPCC Rule. This revision extends both the revision and implementation dates by eighteen months. The new SPCC Plan revision deadline is February 17, 2006 and the plan implementation date is August 18, 2006.
|
|
Rule |
Brief Description |
Exist
Plan |
|
1.
|
112.1(c)(2)(ii) |
The facility must maintain at least 1,320 gallons of oil in containers larger than 55 gallons. (If the answer is NO the SPCC rule does not apply. Stop here!) |
|
|
2.
|
112.3(e)(1) |
The plan is maintained at facility |
|
|
3.
|
112.5(c) |
The plan must be stamped by a Registered Professional Engineer. |
|
|
4.
|
112.7(a)(3) |
Describe and discuss physical layout, including plot plan, storage tank locations, piping location and drainage direction |
|
|
5.
|
112.7(a)(3)(i) |
Discuss type of oil and storage capacity |
|
|
6.
|
112.7(a)(3)(ii) |
Describe discharge prevention measures |
|
|
7.
|
112.7(a)(3)(iii) |
Describe discharge or drainage controls |
|
|
8.
|
112.7(a)(3)(iv) |
Discuss countermeasures for discovery, response & cleanup |
|
|
9.
|
112.7(a)(3)(v) |
Discuss methods of disposal |
|
|
10.
|
112.7(a)(3)(vi) |
Contact list |
|
|
11.
|
112.7(a)(4) |
Describe discharge reporting information, including discharge estimates |
|
|
12.
|
112.7(a)(5) |
Organize plan for ease of use in an emergency |
|
|
13.
|
112.7(b) |
Prediction of potential discharges, including quantity, direction of flows and discharge rates. |
|
|
14.
|
112.7(c) |
Discuss and provide appropriate containment |
|
|
15.
|
112.7(e) |
Discussion and samples of inspections and test records (signed and maintained for three years) |
|
|
16.
|
112.7(f) |
Discussion of personnel training and discharge prevention procedures |
|
|
17.
|
112.7(g) |
Discussion of facility security |
|
|
18.
|
112.7(h)(1) |
Discussion of truck loading and unloading containment capacity |
|
|
19.
|
112.7(h)(2) |
Discussion of interlock system to prevent vehicle from departing until all loading and unloading hoses are disconnected |
|
|
20.
|
112.7(h)(3) |
Discussion and documentation of inspection of vehicle for leaks prior to departure |
|
|
21.
|
112.8(b)(4) |
Discuss and install drainage system, from undiked areas with a potential for discharge, to prevent uncontrolled discharge from leaving facility. |
|
|
22.
|
112.8(c)(2) |
Discussion of tank secondary containment system. (requires sufficiently impervious, 100% capacity of largest tank plus sufficient freeboard to contain precipitation) |
|
|
23.
|
112.8(c)(3) |
Discussion of storm water management |
|
|
24.
|
112.8(c)(6) |
Discuss, test and document aboveground tank containment system |
|
|
25.
|
112.8(c)(8) |
Discussion of engineering level controls |
|
|
26.
|
112.8(c)(9) |
Discussion and documentation of facility effluent |
|
|
27.
|
112.8(d)(4) |
Discussion and documentation of regular piping, valve and appurtenance inspection |
|
|
28.
|
App.
C of |
Discussion of facilities "Substantial Harm Criteria" |
|
For
further information on the US EPA's SPCC rule, see their internet web page:
http://www.epa.gov/oilspill
or contact David Nickl, P.E.
Tank
Engineering and Management Consultants, Inc.
at dlnickl@tankteam.com or
813-620-2022