Implementing the New SPCC Plan Regulations and Tank Integrity Inspections

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Implementing the New SPCC Plan Regulationsand
Tank Integrity Inspections
Greg Gorman Burns McDonnell Engineering
Company 9400 Ward Parkway Kansas City, MO
64114 ggorman_at_burnsmcd.com 816-822-3322
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Spill Prevention Control Countermeasures (SPCC)
Plan Regulatory History
Originally Issued in 1973 Revisions
proposed in 1980, 1991, 1993, 1997, and 1999
but never issued Revision finally issued in
July 17, 2002 Federal Register
(http//www.access.gpo.gov/su_docs/fedreg/a020717c
.html) Extension issued January 9, 2003
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Spill Prevention Control Countermeasures (SPCC)
Plan Dates
SPCC Plan Revision Issued July 17, 2002
Effective Date of Rule August 16, 2002
Existing Plans Must be Revised April 17, 2003
Implementation Required October 18, 2003
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Potential Future Regulatory Changes

• January 9, 2003 EPA indicated they would
• propose to extend deadlines another 10 months
• Potential changes due to additional comments
• Potential changes due to current litigation

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Current Litigation
American Petroleum Institute challenges to the
revised rule - Navigable water
definition - Impracticality determination
should include cost considerations
- Loading rack definition
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Most Significant Changes Under the Revised SPCC
Regulations

• Changed thresholds for preparing plans
• Clarifies that use of oil not just storage is
  covered
• Clarifies role of professional engineer
• Changed Should to Must
• Clarifies inspection and testing requirements

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SPCC Plan Thresholds
Greater than 1,320 gallons of aboveground
storage or 42,000 gallons of belowground storage
Removed 660 gallon tank requirement Exempted
all containers with less than 55 gallon
capacities Exempted regulated USTs Exempted
permanently closed tanks
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Oil Use Covered by Regulations
Oil filled electrical equipment (transformers
including silicon filled transformers)
Hydraulic reservoirs Lubricating reservoirs
Heat transfer fluids Oil use not considered a
bulk storage container All petroleum and
non-petroleum oils are covered
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Professional Engineer Role
P.E. must certify
- Familiarity with the regulations
- P.E. or agent has visited the facility -
The plan has been prepared in accordance with
good engineering practice, including
applicable industrial standards, and the
provisions of the regulations -
Inspection and testing procedures have been
established - The plan is adequate for
the facility
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Professional Engineer Role (continued)
Non-technical amendments do not require P.E.
certification Rules allow waivers of the
requirements if P.E. certifies they provide
equal environmental protection If
containment is impractical implement a
contingency plan and integrity testing
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Technical Requirements in Rule LanguageChanged
from Should to Must
Containment for use of oil - transformers,
equipment, etc. Containment for aboveground
piping Containment for loading / unloading
racks Disconnect warning system
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Technical Requirements in Rule LanguageChanged
from Should to Must(continued)
Security measures - Fencing - Locking drain
valves - Locking pump starter controls New
underground piping must be wrapped, coated AND
cathodically protected
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Inspections and Integrity Testing
Inspections must follow written procedures and
industry standards Aboveground containers must
be integrity tested on a regular schedule and
whenever material repairs are made - Elevated
small shop fabricated tanks - Shop fabricated
tanks on the ground - Field erected tanks
Integrity testing must combine a non-destructive
testing examination method along with visual
inspections Brittle fracture evaluation when
field erected tanks are modified
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Other Changes
Establishes format for plan - Cross reference
table - Multi facility plans Specific
drawing requirements Five year review
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Other Changes (continued)
Plan must be maintained at facilities that are
manned 4 hours per day Written spill reporting
requirements have been modified Only
oil-handling personnel need training
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Other SPCC Considerations
Documentation and Recordkeeping -
Inspections - Training Substantial harm
determination
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Approaches to the SPCC Revisions
Working to comply with revised regulation
Requesting extensions to comply with the
regulations Establishing a schedule to obtain
compliance with the regulations Waiting to
see what happens
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Summary and Recommendations
1. Review the revised SPCC regulations
closely 2. Keep (abreast of ) EPA Guidance and
revised deadlines 3. Be creative (flexible ) in
defining containment and complying with
regulations 4. Develop and document a workable
integrity testing program 5. Make sure
inspections training are completed documented
as written in your plan 6. Enforcement
can and will happen