Quest Consultants & Associates, Inc.
EPA REVISES SPCC REQUIREMENTS
Do you need a new or updated SPCC plan?
NOTE: SPCC Plans MUST be written or updated by November 10th, 2010
http://www.epa.gov/emergencies/content/spcc/
http://www.epa.gov/emergencies/content/spcc/compliance_dates.htm
The US Environmental Protection Agency (EPA) requires facilities that use, manage and store oil to prepare and implement Spill Prevention, Control and Countermeasures (SPCC) Plans.
On July 17, 2002 EPA announced over 100 pages of amendments to the existing SPCC rules. This final rule incorporates revisions proposed in 1991, 1993 and 1997. The amendments include expansion, modification, and clarification of the requirements for SPCC Plans and Facility Response Plans.
As a result of these changes, facilities that have existing SPCC Plans must update them to comply with the new regulations by February 17, 2006.
The upgraded SPCC Plans must be completed and certified by a licensed PE (Professional Engineer).
The SPCC amendments require that facility management must review and approve the upgraded SPCC Plans, and provide a commitment of the manpower and equipment needed for implementation.
The EPA amendments are not limited to spill planning. Some facilities will be required to modify their petroleum storage and distribution equipment and spill control systems to comply with more stringent requirements under the amended SPCC regulations.
Facility upgrades must be fully implemented by August 18, 2006.
SPCC Amendments Summary
Highlights of the amendments to the SPCC regulations include:
Clarification of the criteria used to determine who must prepare an SPCC Plan.
Expansion and clarification of requirements regarding both the content and format of SPCC Plans; acceptance of the Integrated Contingency Plan format.
New requirement that aboveground storage tanks and underground piping must be periodically tested for integrity.
Expansion and clarification of design, performance, and PE certification requirements for secondary containment systems. For example, the EPA has clarified that secondary containment is required not just for the storage tanks, but also for the loading and unloading areas.
New requirements for corrosion protection of underground piping.
Clarification of the requirement for some mobile facilities to have SPCC Plans. EPA REVISES SPCC REQUIREMENTS
Do you need a new or updated SPCC plan?
The US Environmental Protection Agency (EPA) requires facilities that use, manage and store oil to prepare and implement Spill Prevention, Control and Countermeasures (SPCC) Plans.
The SPCC requirements apply to most facilities that have total aboveground oil storage capacity of 1,320 gallons or more.
On July 17, 2002 EPA announced over 100 pages of amendments to the existing SPCC rules. This final rule incorporates revisions proposed in 1991, 1993 and 1997. The amendments include expansion, modification, and clarification of the requirements for SPCC Plans and Facility Response Plans.
As a result of these changes, facilities that have existing SPCC Plans must update them to comply with the new regulations by February 17, 2006.
The upgraded SPCC Plans must be completed and certified by a PE (professional engineer).
The SPCC amendments require that facility management must review and approve the upgraded SPCC Plans, and provide a commitment of the manpower and equipment needed for implementation.
The EPA amendments are not limited to spill planning. Some facilities will be required to modify their petroleum storage and distribution equipment and spill control systems to comply with more stringent requirements under the amended SPCC regulations.
Facility upgrades must be fully implemented by August 18, 2006.
SPCC Amendments Summary
Highlights of the amendments to the SPCC regulations include:
Clarification of the criteria used to determine who must prepare an SPCC Plan.
Expansion and clarification of requirements regarding both the content and format of SPCC Plans; acceptance of the Integrated Contingency Plan format.
New requirement that aboveground storage tanks and underground piping must be periodically tested for integrity.
Expansion and clarification of design, performance, and PE certification requirements for secondary containment systems. For example, the EPA has clarified that secondary containment is required not just for the storage tanks, but also for the loading and unloading areas.
New requirements for corrosion protection of underground piping.
Clarification of the requirement for some mobile facilities to have SPCC Plans.
Modification of the stormwater management and recordkeeping requirements.
Clarification and expansion of requirements for routine facility inspections and associated recordkeeping.
Modification of the training requirements for employees that handle petroleum products.
Modification of requirements for periodic SPCC Plan reviews and updates.
Clarification and expansion of requirements for Professional Engineer’s role in SPCC Plan preparation and certification.
Clarification of the owner’s responsibility for implementation of the SPCC Plan.
Compliance Deadlines
Strict deadlines are fast approaching.
Modified SPCC Plans for existing facilities: February 17, 2006.
Plan implementation, including facility modifications and upgrades: August 18, 2006.
SPCC Plans and implementation for new facilities: August 18, 2006.
The above deadlines reflect extensions recently granted by EPA. It is unlikely that EPA will extend the deadlines again.
SPCC Plans and Quest Consultants
Quest Consultants & Associates, Inc.
Quest is an environmental engineering and consulting firm, with employees and six (6) offices throughout the US and growing.
Our engineers have been providing management, planning, training, design, construction, and spill response services since the 1980s.
Our Professional Engineers have prepared and certified SPCC Plans since the begining, including many under the new SPCC regulations. Facilities have ranged from small service stations and repair shops to bulk petroleum storage and distribution facilities with capacities in excess of ten million gallons.
Quest provides a host of related services, including preparation of Facility Response Plans, Oil Discharge Contingency Plans, Integrated Emergency Response Plans, design of petroleum storage and distribution systems, closure of existing systems, spill response and remediation, PE evaluation and certification of secondary containment systems, compliance assessments, permitting, and other regulatory assistance such as Federal Stormwater sampling and reporting, PTI/PTO permits, WWTP Operation Personnel and management.
Please contact Quest at Quest@QuestInc2.com or 888-730-4646 for any assistance in our service areas, or for a referral to our professional colleagues elsewhere in the US. We may also be reached by E-Mail at Quest@QuestInc2.com or QCAI@comcast.net
888-730-4646