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SPCC Planning and Regulatory Compliance Inspections

Posted on Thu, Oct 16, 2014

The challenge of managing and ensuring compliance of Spill Prevention, Control and Countermeasure (SPCC) plans for multiple facilities can be complex. Detailed government inspections, enforcement mandates, costly non-compliance fines, and negative publicity may result from the lack of implemented, site-specific, and up-to-date plans. By utilizing available technology to manage multiple SPCC plans, companies can verify compliance through a cohesive, yet site-specific, standardization of best practices.

For facilities with aboveground storage tank capacities exceeding 1,320 gallons or underground tanks with capacities above 42,000 gallons, Environmental Protection Agency (EPA) compliance requires accurate and up-to-date SPCC plans. A professional engineer must certify SPCC plans if your facilities have more than 10,000 gallons of aboveground oil storage capacity.

Maintaining SPCC compliance requires preparing plans that outline facility-specific spill prevention procedures, associated equipment to prevent spills from occurring, and countermeasures to address the effects of potential oil spills on sensitive environments. For organizations that have many facilities, web-based response planning provides seamless integration of approved enterprise-wide procedures and policies with site-specific, SPCC required information. This optimizes the potential for every location to remain in compliance with SPCC regulations.

Since 1973, the EPA has conducted scheduled or unannounced facility inspections to ensure that facilities identify site-specific practices related to the storage and management of oil and oil tanks, and response procedures in the event of an oil spill. According to the EPA, the SPCC Inspections serve two primary functions:

  1. 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.
  2. To give U.S. Environmental Protection Agency representatives the opportunity to educate owners and operators about the regulations and ways to ensure compliance.

SPCC TRP Corp

In order to meet SPCC regulatory requirements, every applicable facility in your organization is required to regularly update and maintain SPCC plans per EPA regulation 40 CFR 112.20. The following is an abbreviated checklist of SPCC associated planning elements that EPA representatives may evaluate during facility inspections:

  • Storage tanks and other equipment containing oil
  • Storage tank integrity testing requirements
  • Truck loading/unloading areas
  • Transfer procedures and equipment (including piping)
  • Facility layout and diagram
  • Drainage patterns and oil discharge predictions
  • Secondary containment or diversionary structures and their ability to contain a release of oil
  • Site security measures
  • Operating procedures
  • Personnel training and oil discharge prevention briefings
  • Plan certification (by a Professional Engineer (PE) or in certain cases by the facility owner/operator)
  • Recordkeeping

Since the prevention and countermeasures identified in SPCC plans must be implemented throughout the facility in order to be in compliance with regulations, a copy of your SPCC plans must be available to inspectors for reference at all times. In addition, it is essential to provide inspectors with relevant documentation of all operating and inspection procedures, spill prevention measures, training records and other compliance verification information.

With a comprehensive, web-based, database-driven SPCC plan management system, emergency managers and health, environmental, and safety departments can:

  1. Simplify audits
  2. Easily identify required information
  3. Verify accuracy of plan contents through secured access
  4. Revise information in real-time, as necessary
  5. Identify regulatory compliance gaps
  6. Account for necessary mitigation endeavors
  7. Ease maintenance and administrative efforts
  8. Provide electronic copies of plans to government agencies

Proactive responsive, procedural, and preparedness measures, in conjunction with innovative planning system technologies can maximize compliance efforts and minimize accidents and catastrophes. Transitioning to a web-based system to maintain SPCC plans can enhance accessibility, portability, and redundancy, potentially easing communication barriers with responders and regulatory audits.

For a free download entitled, "The Facility Response Plan and the Spill Prevention, Control, and Countermeasure Plan", click here or the image below:

TRP - SPCC and FRP

Tags: SPCC, EPA, Regulatory Compliance, Facility Management, Emergency Management Program