Environmental Management and Compliance News, Tips and Tools

September 7, 2011

Your SPCC Plan – Is it up-to-date?

image: fuel storage tanks in containment

SPCC requirements apply to fuel and oil storage tanks…

By November 10 of this year, all regulated facilities storing more than 1,320 gallons of oil or fuel in above ground tanks and containers must comply with recently amended federal requirements for development and implementation of written Spill Prevention, Control and Countermeasure (SPCC) Plans. If you have existing SPCC Plans for your facilities, you should review them to make sure that they meet the amended rule (40 CFR part 112). If a plan has not been prepared, it should be completed and in use by the November deadline. Note that these federal requirements may be in addition to State regulations governing above ground fuel storage tanks.
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Filed under: Compliance,Rules and Regulations,Spill Prevention Plans,Uncategorized,USEPA — TCozzie @ 12:37 pm

November 1, 2010

Just a little more time – for SPCC Plan updates

The US Environmental Protection Agency (EPA) has extended the deadline for most facilities that are required to prepare or revise their oil Spill Prevention Control and Countermeasure (SPCC) Plans to comply with recent amendments to the SPCC rule.  The compliance date of November 10, 2011, applies to regulated facilities in a broad range of categories, including:

Onshore oil production, farms, electric utility plants, petroleum refining and related industries, chemical manufacturing, food manufacturing, manufacturing facilities using and storing animal fats and vegetable oils, metal and other manufacturing, real estate rental and leasing, retail trade, petroleum bulk stations and terminals, education, hospitals and other health care, fuel oil dealers, gasoline stations, transportation and other commercial, etc.

However, some facilities are not eligible for the extension, and must comply by November 10, 2010.  These include:

Drilling, production or workover facilities that are offshore or that have an offshore component, and

Onshore facilities required to have and submit facility response plans (FRPs), due to the potential threat of significant oil spills to navigable waters or adjoining shorelines from these facilities.

As we must always note, owners or operators of facilities in operation before August 16, 2002, must continue to maintain and implement an SPCC Plan in accordance with the regulations then in effect.

More information on the rule can be found at the EPA webpage,  http://www.epa.gov/emergencies/content/spcc/compliance_dates.htm.

Filed under: Compliance,Rules and Regulations,Spill Prevention Plans,USEPA — TCozzie @ 8:58 am

August 2, 2010

EPA to delay compliance deadline for Spill Prevention, Control and Countermeasure (SPCC) Plans

The Environmental Protection Agency (EPA) has proposed to extend the compliance date for some facilities subject to the Spill Prevention, Control and Countermeasure (SPCC) Rule amendments.

(aboveground storage tank in secondary containment) Drilling, production or workover facilities that are offshore or onshore facilities required to have and submit facility response plans (FRPs) will not be eligible for the proposed extension, and must prepare or update their SPCC Plans in accordance with the rule amendments by November 10 of this year. Other facilities, including onshore oil production facilities, farms, utilities, various manufacturers, petroleum bulk storage and retail, transportation and commercial operations may put off their plan and facility updates until November 10, 2011.

Provided, of course, that facilities that were in operation and subject to SPCC regulations before August 16, 2002, maintain and continue to implement their existing SPCC Plans in accordance with the regulations that were then in effect.

More information on SPCC requirements can be found at this page. Please comment below or contact T. Cozzie Consulting if you have questions or concerns about how these requirements affect your facility.

Filed under: Compliance,Spill Prevention Plans,USEPA — TCozzie @ 6:18 pm

April 14, 2010

SPCC (Spill Prevention, Control and Countermeasure) Plan Template for qualified facilities is now available

The Environmental Protection Agency has published its template Spill Prevention, Control and Countermeasure (SPCC) Plan for use by qualified Tier 1 facilities.  To use the template SPCC Plan, a facility can store no more than 10,000 gallons of oil in aboveground storage with no single storage container or tank larger than 5,000 gallons, and cannot have had within the past three years either one spill or release of more than 1,000 gallons or two spills that each exceeded 42 gallons within a 12-month period.
PDF download
You can download a fill-in PDF version of the SPCC Plan template by clicking (or right click to save) the PDF icon to the right.

Other versions of the SPCC Plan template (MS Word and Wordperfect) can be found on the EPA website.

Remember, the deadline to amend or prepare and implement an SPCC Plan meeting the latest requirements is November 10, 2010.  Visit our spill prevention page for additional information and guidance on compliance with SPCC Plan requirements. Or contact T. Cozzie Consulting if you have further questions about how the SPCC rule applies to your facility, or desire assistance with your SPCC Plan.

Filed under: Compliance,Spill Prevention Plans,USEPA — TCozzie @ 6:34 pm

January 29, 2010

What’s EPA been up to?

As January closes, we take a quick look at the highlights (or lowlights, depending on your perspective) of actions taken by the US Environmental Protection Agency in the first month of 2010. Noteworthy actions included:

  • EPA proposes revisions to smog (ozone) standard
  • EPA to issue new standard for nitrogen dioxide (NO2)
  • EPA rejects confidentiality claims for toxic chemicals
  • EPA announces tip line for bad behavior in oil and gas drilling operations

In addition, EPA Administrator Lisa Jackson set forth the agency’s priorities for the coming year.

Summaries of these actions follow.  As always, feel free to contact T. Cozzie Consulting for more information.

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Filed under: Air Pollution,Reporting,Rules and Regulations,Spill Prevention Plans,Toxic Chemicals,Uncategorized,USEPA — TCozzie @ 6:17 pm

November 19, 2009

Final amendments to SPCC rules announced

On November 10, the US Environmental Protection Agency (EPA) announced that it has finalized amendments to requirements for facilities subject to the Oil Spill Prevention, Control and Countermeasure (SPCC) rule. The amendments are intended to clarify regulatory requirements, tailor requirements to particular industry sectors, and streamline certain requirements for a facility owner or operator subject to the rule. The rule changes were originally proposed in October 2007 and finalized on December 5, 2008, but the agency requested public comments again on February 3, 2009. The rule takes effect on January 14, 2010.

For the most part, the EPA is either taking no action or providing minor technical corrections on the majority of the December 2008 provisions. However, this action modifies the December 2008 rule by removing the provisions to: exclude farms and oil production facilities from the loading/unloading rack requirements; exempt produced water containers at an oil production facility; and provide alternative qualified facilities eligibility criteria for an oil production facility.

Additionally, because of the uncertainty surrounding the final amendments to the December 2008 rule and the delay of the effective date, EPA is expected to propose to extend the compliance date.
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Filed under: Compliance,Rules and Regulations,Spill Prevention Plans — admin @ 5:14 pm

October 9, 2009

Compliance Tip of the Week: Defining your “facility” for SPCC Plan requirements

The November 2008 amendments to Spill Prevention, Control and Countermeasure (SPCC) Plan requirements provided facility operators with flexibility in defining the extent of the facility to be addressed in an SPCC Plan. This flexibility can be particularly helpful for large properties or installations, such as farms, multi-structured industrial plants and university campuses, where several buildings or locations may be used for storage and management of oil and other petroleum products.

The rule amendments redefined the term “facility” to allow the owner or operator to designate operations in or on contiguous or non-contiguous lands, properties, buildings and so forth as separate facilities for the purpose of compliance with the regulations. The owner or operator can aggregate or separate containers to determine the facility boundaries, and may determine that certain installations or parts thereof are effectively exempted from the rule if, for example, less than 1,320 gallons of oil are stored in aboveground containers within the boundaries of a designated “facility.”

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Filed under: Compliance,Spill Prevention Plans,Tip of the Week — admin @ 4:36 pm

June 12, 2009

EPA extends compliance date for SPCC Plans

The US Environmental Protection Agency has extended the compliance date for facilities to meet amended Spill Prevention, Control and Countermeasure Plan requirements.  All facilities, including farms, must prepare or amend and implement an SPCC Plan by November 10, 2010.

Facilities that were in operation before August 16, 2002, must continue to maintain and implement their existing SPCC Plans until required to revise and implement their Plans under the amended regulations.

For more information on compliance with SPCC Plan requirements, visit www.tcozzie.com/spill_prevention.htm, or contact T. Cozzie Consulting for assistance.

Filed under: Compliance,Rules and Regulations,Spill Prevention Plans — admin @ 10:38 am

May 29, 2009

Hurricane (season) warning: take steps to minimize releases

With the onset of the hurricane season, the Environmental Protection Agency has issued an “alert” to remind facility operators to take preventive steps to minimize potential releases of hazardous substances in the event of a weather emergency.  Various regulations require that operators minimize chemical releases during process shutdown operations.  If releases occur, they must be reported immediately upon constructive knowledge of the discharge.

The EPA alert can be viewed at http://www.epa.gov/region4/r4_hurricanereleases.html.

Please contact T. Cozzie Consulting if you desire assistance with review and updating of your spill prevention and contingency plans and procedures.

Filed under: Spill Prevention Plans — admin @ 10:46 am

April 5, 2009

SPCC Rule has been finalized, again…

The Environmental Protection Agency on April 1 published the final rule promulgating revisions to Spill Prevention, Control and Countermeasure Plan requirements that were proposed in December 2008.  The published rule delays the effective date of the rule to January 14, 2010.  EPA also asked for public comment on whether a further delay of the effective date is warranted.

Revised dates for facilities to comply with the SPCC requirements will be published in a separate notice.

T. Cozzie Consulting is tracking the SPCC requirements and offers guidance on compliance at the page www.tcozzie.com/spill_prevention.htm.

Filed under: Rules and Regulations,Spill Prevention Plans — admin @ 6:25 pm