SPCC Plan Recertification

Last post 08-19-2016, 12:01 PM by dhaumann2. 1 replies.
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  •  07-31-2016, 12:33 AM 4540

    mlcarr01 is not online. Last active: 07-31-2016, 1:05 PM mlcarr01

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  • SPCC Plan Recertification

    I have a client that has requested my firm to update and recertify an SPCC plan for their facility and after reviewing the plan I conducted a site visit to the facility.  During the site visit I observed multiple issues and informed the facility that some of the issues were significant and should be addressed immediately.  Of my chief concerns was a refueling area outdoors where a 12,000 gal diesel AST is located on a concrete pad w/ no curbing (the tank is double walled), but it is obvious from significant amount of significant staining on the concrete area around the tank that there has been a lot of spillage during refueling operations over what looks like a very long time.  The tank is located at the top of a steep concrete driveway and the staining was observed to run down the length of the drive.  At the bottom of the drive is a flow through stormwater basin where an oil sheen was observed on top of the water in the basin at the outlet.  There are no methods for retaining or capturing the oil before it leaves the basin.  There is another outdoor uncovered  refueling area with similar signs of significant spillage, but this area has no concrete pad and the tank and refueling areas are gravel surfaced.  When reviewing their SPCC plan they have a schedule of improvements that include the addition of curbing and protection measures in these and other areas with dates that have long since passed.  They have asked that we just adjust all the dates to the future when we update the plan; so no real intentions on their part to really do any of the improvements  I only have a few years of experience preparing SPCCs and so far all of my clients have been large manufacturing facilities for companies that are very proactive and take environmental compliance very seriously so I was practically speechless as the client was walking me through the facility.  My first thought is that I do not want my name or certification to be to on any SPCC plan for this facility, at least until they make improvements.  What would you do?
  •  08-19-2016, 12:01 PM 4541 in reply to 4540

    dhaumann2 is not online. Last active: 08-19-2016, 12:04 PM dhaumann2

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  • Re: SPCC Plan Recertification

    Based on your description of the situation, you appear to have a difficult client with no apparent intention of compliance with SPCC requirements.  You may be able to get around the date issue simply by referring to the original plan dates and reference to the client's "verbal confirmation" (if provided) to implement corrective measures.  HOWEVER, from your description there appears to be some larger issues. 

    1. The double-walled tank requires an "environmentally equivalent" method of integrity testing.  Per EPA Guidance for SPCC Inspection (2013) this can be done by inspections - which are documented and should be part of the original SPCC plan supplements.  Have they done inspections and internally identified issues and/or concerns that need to be addressed (e.g. staining; spillage; sheen on water in collection system; etc.)
    2. Have they had any reportable spills?
    3. Did the sheen you noticed on water in the storm water basin reach any surface water?
    4. Do they have a written procedure for refueling the diesel tank?  Does it include ""active measures"" for spill / pollution prevention? If so, is it used?  If used, why is there staining?

    A few weeks ago I completed an SPCC Plan  re-certification for a client that had a lot of environmental awareness.  Although not originally anticipated, I had to rewrite most of the plan and, as required, provide a table showing where and what changes were made.  Many of the changes I made (and clearly identified) were due to a certain degree of neglect by the original engineering  SPCC authors (looked like a template was followed).  I had no trouble re-certifying THE CHANGES I MADE to the original and ensuring the document was in compliance with appropriate regulations (and EPA Guidance).

    Bottom Line: You should be able to re-certify an SPCC Plan Revision, assuming the revised document is consistent with regs and your observations.  Remember you are certifying the Plan (and your observations).  An authorized representative of the Client must sign and certify.  The Client is ultimately responsible for following the Plan.

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