|
Spill Prevention Control and Countermeasure Plans
SPCC PLANS
The Federal Environmental Protection Agency (EPA) has required SPCC Plans since 1973. The last major modification was in August 2002. The EPA amended 40 CFR 112 – making significant changes. For highlights of the changes click here: 40 CFR 112. These changes must be incorporated into the plans by February 17, 2006 and implemented by August 18, 2006. On December 12, 2005, the EPA proposed extending both deadlines to October 31, 2007. See the proposed changes at
http://www.epa.gov/oilspill/nprm.htm#WhatDoesRuleSay.
The EPA has announced greater enforcement of the SPCC regulations and is planning to levy fines for non-compliance. Historically, the greatest areas of non-compliance resulting in violation are the lack of employee training on the plan and lack of record keeping.
Many companies produce SPCC Plans. Although most plans meet the requirements of the EPA, few plans note the exceptions to the regulations and do not provide the AST owner advice on the improvements necessary. Several exceptions can be corrected while we are conducting our site visit. Presently, there are few companies that assist the owner with employee training or with the environmental record keeping requirement. Williams & Company not only provides an excellent SPCC plan but also has available means for employee training and record keeping addressing the most common EPA violations. In addition, we stand behind our plans. If the EPA issues you a violation for an exception we did not note in the plan – we will reimburse you the amount of the fine up to the cost for your SPCC plan. (For details see our sample agreement)
Now is the time to schedule incorporating the 2002 changes into your SPCC plan. Contact us today at 877-269-0194 or by clicking here.
Links:
EPA Summary of SPCC regulations
40 CFR 112 Oil Pollution Prevention
EPA Fact Sheet on SPCC Plans
May 24, 2004 Federal Register Notice of Clarification
June 17, 2004 Federal Register on dates for compliance
| 
