The deadline dates by which owners or operators of regulated facilities must prepare or amend and implement a SPCC Plan have past. Continued Plan evaluation, facility inspection, testing and record keeping requirements, as well as employee training, are important components of implementing and maintaining a SPCC Plan.
The EPA page on the SPCC Rule site, SPCC for Agriculture, is a valuable resource. This page is dedicated to helping prevent oil spills as well as control a spill should one occur. Detailed information may be found on this site.
Important Elements of an SPCC Plan Include:
- Facility diagram and description of the facility
- Oil discharge predictions
- Appropriate secondary containment or diversionary structures
- Facility drainage
- Site security
- Facility inspections
- Requirements for bulk storage containers including inspections, overﬁll and integrity testing
- Transfer procedures and equipment (including piping)
- Requirements for qualiﬁed oil-ﬁlled operational equipment
- Loading/unloading rack requirements and procedures for tank cars/trucks
- Brittle fracture evaluations for aboveground ﬁeld constructed containers
- Personnel training and oil discharge prevention brieﬁngs
- Recordkeeping requirements
- Five-year Plan review
- Management approval
- Plan certiﬁcation (by a Professional Engineer (PE) or in certain cases by the facility owner/operator)
When aboveground storage capacity is added to a facility, the SPCC Plan should be amended within six months and implemented as soon as possible, but no later than six months after amending. A SPCC Plan must be developed and implemented if the additional capacity no longer allows the facility to be exempt from SPCC requirements.
The EPA's SPCC Farms Fact Sheet is perhaps the best place to start when evaluating responsibilities under the SPCC Program. Owners and operators of farms or gins should first establish whether they qualify as a regulated facility. Owners and operators are reminded that containers on separate facilities are not to be added together when determining total oil storage capacity. It is not uncommon for a farm to be comprised of multiple facilities with respect to oil storage. It is also recommended that owners and operators document and file any circumstances that exclude them from this rule. Exemption from this rule does not exclude responsibilities for cleanup of oil spills or any containment requirements for storage containers.
Owners or operators of qualified facilities should know when their Plan should be in place. They also are urged to contact a qualified Professional Engineer as soon as possible if self-certification is not an option.