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Spill, Prevention, Control and Countermeasure (SPCC) Plans

Spill, Prevention, Control and Countermeasure (SPCC) Plans. April 20, 2005 Jeff Adams Regulatory Affairs Specialist. Agenda. Rule Overview Current Regulatory Requirements EPA Clarifications Outstanding Issues. Rule Overview. Original Rule: December 11, 1973

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Spill, Prevention, Control and Countermeasure (SPCC) Plans

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  1. Spill, Prevention, Control andCountermeasure (SPCC) Plans April 20, 2005 Jeff Adams Regulatory Affairs Specialist

  2. Agenda • Rule Overview • Current Regulatory Requirements • EPA Clarifications • Outstanding Issues

  3. Rule Overview • Original Rule: December 11, 1973 • Rule published as “guidelines” (i.e. should) • Some interpreted rule flexibility as being optional, not requirements • Revised Rule: July 17, 2002 • Finalized 14 Years of Discussions • Clarified EPA’s Intent • Changed Guidelines to Requirements • Contained Regulatory Relief

  4. More Stringent Provisions • Use of Oil vs Storage of Oil • Oil Volume: Stored Oil vs Container Capacity • Mixtures of Oil Considered Oil • Loading Racks vs Loading Areas • PE Certification More Stringent • Revised “Navigable Water” Definition • Preamble Language • Sufficiently Impervious • Impractical Containment Determinations – Technical, Not Economic • Explanations of Rule Compliance Required in Plan

  5. Less Stringent Provisions • Flexible Format, But Must Contain Cross Reference • Review Plans on Every Five Years vs Three Year • 1320 Gallon Oil Threshold vs 660/1320 Gallon Threshold • 55 Gallon Minimum Container Size • Removed Spill History Requirement • Waste Water Treatment Exemption • Changed Spill Reporting • 2 Spills >42 Gallons Within a Year vs 2 Spills Within a Year • SPCC Plan Submittal Not Required.

  6. Current Regulatory Requirements • Delayed Until: • Feb. 18, 2006 for SPCC Plan Certification • August 17, 2006 for Plan Implementation • Requirements Currently Active: • July 17, 2002 Requirements That Are Less Stringent (i.e. Five Year Review Cycle, Plan Format, etc.) • Old Requirements Were New Are More Stringent (i.e. Containment For Separators, Produced Water, etc.)

  7. EPA Clarifications API SPCC Litigation Issues • Loading/Unloading Racks • EPA Didn’t Expand Rule Beyond “Racks” • EPA Didn’t Intend to Define “Racks” • Practicability of Containment • EPA Didn’t Intend to Broadly Prohibit Use of Cost • Cost Can Be Used as a Component of “Engineering Judgment” • Produced Water – Waste Water Treatment Exemption • Produced Water at Oil Production Not Exempted • Produced Water at “Dry Gas” Production Is Eligible for the “Waste Water Treatment Exemption” • For FRP Purposes, Surface Sites Are Not Aggregated

  8. EPA Clarifications PMAA SPCC Litigation Issues • Security • Entire Property Does Not Need to be Fenced • Fence Needed for Risk to Tanks, Piping, Pumps, etc. • Integrity Testing of Small Shop Built Tanks • “Environmental Equivalent” for Tanks < 30,000 gallons • Visual Inspection Plus • Elevate Tank to Allow Visual Inspection of the Bottom, or • Place a Barrier Between Tanks and Ground for Immediate Detection of a Leak.

  9. Outstanding Issues • Small Facility Exemption • Manufacturing/Process Equipment & Piping • Oil Filled Equipment (i.e. Electrical Transformers, Engines, Hydraulic Systems, etc. • Mode of Power (Fuel Tanks) • Mobile/Portable Storage Containers • Waste Water Treatment – Containment for Oil Storage Portion • Integrity Testing of Small Containers (i.e. 55 gallon drums)

  10. Next Steps • No Further Rule Delays Expected • Potential for Issue Specific Requirement Stays • Rules Making in Progress • Electrical Operating and Manufacturing Equipment • Small Facility Exemption • Potential Rule Proposals • Mobile/Portable Tanks • Mode of Power • Potential Guidance • Small Vessel Integrity Testing • Waste Water Treatment – Stored Oil Requirements

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