Plan update due November 10, 2010. There’s still time to get yours updated!

Inspectors are looking for sheens on water, the ground, or pavement, oil storage containers without secondary containment or with improperly sized secondary containment, lack of alarm systems to notify personnel of spills, missing records and failure to train personnel.

SPCC Plans must describe equipment, workforce, procedures, and training to prevent, control, and provide adequate countermeasures to a discharge of oil. Before a facility is subject to the SPCC Rule, it must meet three criteria: 1) it must be non-transportation-related; 2) it must have an aggregate aboveground storage capacity greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons; and 3) there must be a reasonable expectation of a discharge into or upon navigable waters of the United States or adjoining shorelines (advice – review this term in the rule prior to assuming there is no reasonable expectation).

The term oil means oil of any kind or in any form, including, but not limited to: petroleum; fuel oil; sludge; oil refuse; oil mixed with wastes other than dredged spoil; fats, oils or greases of animal, fish, or marine mammal origin; vegetable oils, including oil from seeds, nuts, fruits, or kernels; and other oils and greases, including synthetic oils and mineral oils.

SPCC Plans generally require certification by a Professional Engineer unless they are “qualified facilities”. Tier I qualified facilities may complete and implement a streamlined, self-certified SPCC Plan template (Appendix G to the rule); all other qualified facilities are designated Tier II qualified facilities and can be self-certified but cannot use the plan template.

Once you have an SPCC Plan in place it is critical to conduct site inspections, personnel training and periodic review and renewal of the plan. Severe penalties have been assessed against companies who had SPCC Plans in place but had not conducted proper training and implementation of the plan. If an inspector determines that site personnel do not know how to respond to a spill, you are likely to face severe penalties, regardless of whether there has been an incident. If you have not conducted SPCC or storm water training, call us for a FREE PowerPoint presentation that you can present and read to your personnel to immediately satisfy this training requirement.

If you have questions or need any assistance with any aspect of the SPCC program you may first wish to review a PowerPoint overview which is available on the EPA website at:

http://www.epa.gov/osweroe1/docs/oil/spcc/spcc_rule_amendments_nov09.ppt

If you have additional questions or need assistance with any aspect of the rule, feel free to call us at 800-634-3947 or visit us at www.argentenv.com.

The call and the PowerPoint slides are free. Failure to comply is not.