SPCC Training requirement
Are you SPCC compliant with the recent regulatory requirements?

You’ve developed and implemented a Spill Prevention, Control, and Countermeasure (SPCC) Plan that meets all federal SPCC regulatory requirements. You’ve put into action an inspection program that is well documented in your Plan, and you’ve made sure that all secondary containment is sufficient to prevent an oil discharge to navigable waters and adjoining shorelines. It sounds like your facility is fully compliant with the SPCC regulations, right? But unless you have implemented a training program and are routinely training new and existing oil-handling personnel, you are not fully in compliance.

SPCC plans are a cornerstone of the U.S. Environmental Protection Agency’s (EPA) strategy to prevent oil spills from reaching U.S. waters. Unlike oil spill contingency plans that typically address spill cleanup measures after a spill has occurred, SPCC plans ensure that facilities put in place containment and other countermeasures that would prevent oil spills from reaching navigable waters. In order for spill prevention, containment, and countermeasures to work properly, employees must be trained to ensure the measures are installed, operated, and maintained.

Oil-handling Personnel

The SPCC regulations require that all oil-handling personnel at SPCC-regulated facilities be trained. “Oil-handling personnel” is interpreted according to industry standards, but includes employees engaged in the operation and maintenance of oil storage containers or the operation of equipment related to storage containers and emergency response personnel. Oil-handling contractors at a facility must be trained as well as permanent employees. 


Do you need a SPCC Plan?

While the Spill Containment, Control, and Countermeasure (SPCC) regulations have been in place for more than 20 years, the regulations have been amended—and extended—several times, and as recently as 2010. It’s, therefore, important to understand SPCC amendments for ongoing compliance.

One of the first steps in the SPCC plan process is to determine if your facility is actually required to prepare a plan based on types of operations, types and quantities of chemical usage, and applicability of certain exemptions. If you are not required to prepare a plan, documenting through a negative declaration to your files showing your assessment and calculations is an excellent exercise if questioned in the future.

After performing an assessment, a majority of facilities (approximately 66%) determine that a Tier II SPCC plan is required. Determining exactly what needs to be included in your plan requires a careful evaluation and collaboration by various departments, such as EHS, production, facilities, maintenance, and legal, is essential for plan development success.

EPA REVISES SPCC REQUIREMENTS

Do you need a new or updated SPCC plan?

NEW REGULATION HAVE GONE INTO EEFECT IN 2015

NOTE: Federal required SPCC Plans MUST be written or updated by November 10th, 2015

http://www.epa.gov/emergencies/content/spcc/
http://www.epa.gov/emergencies/content/spcc/compliance_dates.htm

The Federal 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, 2008 and continue to remain in compliance.

The upgraded SPCC Plans must be completed and certified by a licensed  PE (Professional Engineer).

The SPCC Federal 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 Federal 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 Federal and or State requirements under the amended SPCC regulations.

Facility upgrades must be fully implemented and kept up todate per Federal Regulatory Requirements.

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

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.
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.

Compliance Deadlines

Strict deadlines are fast approaching. IF YOUR PLAN NEEDS UPDATED, MODIFIED or WRITTEN... CALL US

Modified SPCC Plans for existing facilities was:  February 17, 2006.

Plan implementation, including facility modifications and upgrades was: August 18, 2006.

SPCC Plans and implementation for new facilities was: August 18, 2006.

The above deadlines reflect extensions recently granted by EPA. It is unlikely that EPA will extend the deadlines again.

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