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How Can a P.E. Stamped SPCC Plan Be Bad For Your Business?
The United States Environmental Protection Agency, US-EPA, has issued revised rules pertaining to the preparation and implementation of Spill Prevention Control and Countermeasure (SPCC) plans. For those that follow the regulations, this is no big surprise! The last revision was finalized almost a year ago. The next challenge is to have those plans written and updated by a Professional Engineer before the August 2004 deadline. Most people are in the process of having their plans updated. It is a good business practice not to wait until the last minute to begin the updating process. Getting the plan written and updated early provides more time to plan and implement the changes called for in the revised plan. The necessary steps are to find a Professional Engineer, have them write a plan, get it stamped and put it on the shelf, ready for the EPA inspector, right? WRONG! The first step is the most critical. There are hundreds of thousands of Professional Engineers in the United States, any one of which can legally stamp the plan. Finding the least costly P.E. can result in a very costly-to-implement plan. The owner should take the necessary time to find a P.E. with extensive experience, not only in writing SPCC plans, but also implementing them. The real cost of an SPCC plan will not be involved in writing the plan, it will be in the implementation. The requirement outlined in the plan can either cost a fortune or save one. US-EPA has written 40 CFR 112 in such a way that a number of things are left to the plan writer to clarify. Such items as inspection procedures, training and emergency preparedness are left to be clarified in the plan. This is one of the main reason that the plans must be specifically written for each facility. One size cannot fit all! An example of how the plan can cost or save is in the 'integrity testing' requirement. The plan must specifically identify how the integrity testing must be implemented. If the P.E. is familiar with the various testing methods, along with their pros and cons, they are better suited to specify a method that will protect the environment, meet the regulations and minimize the cost of implementation. Incorrectly specified testing methods, which might include factory recommendations, may result in excessive downtime, high costs and uncertain results. Some testing methods that are ideal for the original shop manufacturer are almost prohibitive after the tank is placed into service. Some methods that are quite effective in the field, would not work well in the shop. The Professional Engineer's familiarity with both the legal requirements and the implementation methods can result in a well written plan. The plan must: 1. Protect the environment 2. Meet all the legal requirements in 40 CFR 112 3. Discuss and address all the specific issues 4. Be understandable by
the implementers Only an engineer familiar with both the requirements and the implementation procedures can provide the best plan. Cost should only play a secondary role in choosing a plan writer. Remember, the real cost of an SPCC plan will be in the long term implementation costs. Money saved in choosing the wrong Professional Engineer can be lost, ten fold, in annual implementation costs. Choose soon and choose wisely! |
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