EMERGENCY RESPONSE PLANNING BLOG

SPCC Plan Compliance Deadline Approaching for Some: November 10, 2010

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BLOG UPDATE: On October 7, 2010,the EPA maintained the November 10, 2010 compliance date for drilling, production or workover facilities that are offshore or that have an offshore component, and for onshore facilities required to have and submit Facility Response Plans (FRPs). However, the EPA extended the compliance date an additional year for all other facilities to amend or develop a SPCC Plan until November 10, 2011.

Facilities were informed in 2008 of clarifying amendments to SPCC (Spill Prevention Countermeasure Compliance) Plans that describe equipment, workforce, procedures, and training to prevent, control, and provide adequate countermeasures to a discharge of oil.  Those amendments were meant to increase clarity and streamline certain requirements.

The changes were as follows:

• Exempt hot-mix asphalt and hot-mix asphalt containers
• Exempt pesticide application equipment and related mix containers
• Exempt USTs deferred under 40 CFR 280 and vaulted tanks at nuclear power generation stations. The Nuclear Regulatory Commission set the criteria.
• Exempt residential heating oil containers at single-family residences or farms
• Clarify applicability of mobile refueler requirements to farm nurse tanks
• Amend the definition of "facility". The owner/operator has discretion as to identifying the components of the facility.
• Revise facility diagram requirement to provide additional flexibility
• Clarity of loading/unloading rack to mean a fixed structure (such as a platform, gangway, arm) necessary for loading or unloading a tank truck or tank car
• Modify secondary containment requirement language at §112.7(c) to provide more clarity
• Exempt non-transportation-related tank trucks from the sized secondary containment requirements
• Simplify security requirements 
  
• Amend the integrity testing requirements to allow greater flexibility
• Amend integrity testing requirements for animal fat and vegetable oil containers that meet certain criteria
• Amend definition of "production facility" to include oil condensate
• Clarify that drilling and work over activities are not subject to provisions at 112.9
• Exempt certain intra-facility gathering lines at oil production facilities that are subject to the DOT regulatory requirements at 49 CFR parts 192 or 195
• Provide more prescriptive requirements for all flow lines/intra-facility gathering lines
• Provide alternate compliance option for flow-through process vessels to comply with secondary containment
• Provide alternate compliance option to sized secondary containment for produced water containers
• Provide an alternative compliance option for flow lines/intra-facility gathering lines in lieu of secondary containment
• Define "produced water container"
• Clarify definition of "permanently closed"
• Clarify applicability of the rule to man-made structures and wind turbines

Owners/operators of SPCC mandated facilities are required to implement post-2002 SPCC requirements by November 10, 2010.

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