Are You Ready for an SPCC Plan Inspection?
Posted on Fri, Aug 27, 2010
Spill Prevention Control and Countermeasure (SPCC) and Facility Response Plan (FRP) inspections are conducted to fulfill the Oil Pollution Prevention Regulation of the Clean Water Act as amended by the Oil Pollution Act of 1990. The EPA has conducted such inspections since 1973 in an effort to minimize oil spills from reaching our nation’s waters.
Owners and operators of facility from which a spill could reasonably be expected to discharge oil into navigable waters, must possess a professional engineer certified SPCC plan if their facility has more than a 1,320 gallon capacity aboveground storage tanks and/or more than 42,000 gallons capacity in underground storage tanks.
According to the EPA’s "What To Expect During an SPCC/FRP Inspection", the inspections have two purposes:
- To ensure that oil storage facilities, refineries, electrical utilities, and oil production fields, among other subject industries, are in compliance with 40 Code of Federal Regulations (CFR) part 112.
- To give U.S. Environmental Protection Agency (EPA) representatives the opportunity to educate owners and operators about the regulations and ways to ensure compliance.
Regional EPA representative(s) conduct both announced and unannounced inspections at facilities. A copy of the facility’s SPCC Plan should be available for inspector(s) to review at all times. Any other relevant documentation of your operating procedures, spill prevention measures, personnel training, inspection procedures, drainage discharges, and spill incidents should be provided to inspector(s), as well as, site plans for tankage, diversionary structures, and drainage patterns.
The inspector(s) will evaluate:
- Storage tanks, and other equipment containing oil
- Diversionary structures
- Truck loading/unloading areas
- Facility design
- Drainage patterns
- Operating procedures
- SPCC measures and their ability to prevent the release of oil to storm drains (onsite or offsite), creeks, streams, ditches, rivers, bays, or other waterways
The inspector(s) familiarize themselves with the facility’s SPCC plan and current operations, including aboveground and underground equipment (i.e., tanks, pipelines, oil-water separators, etc.). After the opening review, the inspector(s) conducts a walk-through of your facility, possibly taking photographs as proof of SPCC implementation. The SPCC measures discussed in your Plan must have been implemented throughout the facility in order to be in compliance with the regulations.
Usually, a debriefing meeting concludes the inspection. Observations are discussed with those accompanying personnel who are familiar with your facility’s SPCC measures, diversionary structures, and standard operating procedures. By having key individuals present, questions can be answered by both parties and ensure that correct information is provided. The inspection and evaluation may be summarized in a letter or a more detailed report containing photographs.
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