Williams & Company Consulting, Inc. has joined with Environmental Advisors and Engineers, Inc. in putting together a team of specialists to assist AST owners in their compliance with the EPA's regulations on SPCC Plans. The team of specialists has skills in engineering, law, accounting, risk management, and information management.
Our SPCC program does not produce a plan that simply restates the regulations, though our plan follows the requirement of the regulations. A properly implemented plan will work toward the goal of spill prevention, control and countermeasures. Responsible owners must take all reasonable steps to protect the environment. But doing so does not always protect you from EPA fines.
What are the most common violations issued by the EPA?
- Lack of training for employees
- Lack of record keeping
- Failure of the plan to note areas of non-compliance. (Yes, that's right, you get a fine for non compliance and a second fine for not stating the non-compliance in the SPCC Plan)
Click Here to View a Sample Plan
Section 40 CFR 112.7 (f) requires all oil handling employees to be trained regarding the SPCC Plan and to maintain records of the training. We take photos of your site during the site visit and information from your Plan and compile a site-specific presentation. The presentation is web-based and available 24-hours a day.
A new employee logs onto the web site, enters a password, name, and reviews the presentation. A pass-fail test is given, a permanent record is created on who was trained and when. This is available to you any time.
As you can see from the training section, we can keep records of all the employees trained on your sites.
Other record keeping is required:
- Your periodic tank and piping self inspection
- Release report
- First response inventory checks
- Discharge prevention meeting
- Handling precipitation in the containment area
Our plan, like any good plan, provides forms for you to complete and maintain in the Plan. Unlike others, we provide you the ability to maintain these forms on the web. You can imagine – you have done your inspection or held the meeting, but the form never gets placed in the Plan. The web-based form will be a permanent record of the activities.
Many sites have some non-compliance issues. We note any non-compliance issue with an alternative plan to come into compliance.
You have until February 17, 2006 to address the issues.
This will stop the EPA from assessing two fines–
the first for non-compliance and
the second for failure to note the non-compliance in the SPCC Plan.
We can help you! Contact our office for more information.
Patrick J. Vuchetich
Williams & Company Consulting, Inc.
9237 Ward Parkway, Suite 220
Kansas City , Missouri 64114