by Jay Collert, Chmm, CET
As was updated in this column in the November/December 2007 issue, changes to the Spill Prevention, Controls and Countermeasures (SPCC) plan rules have been issued with regularity since the original 1974 rule was updated in 2002.
On Dec. 5, a final rule was released that finalized all the changes proposed in October 2007. Taking effect on Feb. 3, these changes have a wide impact on a number of facilities. Perhaps most specific for readers of this publication, it affects facilities with no more than 10,000 gallons of regulated petroleum stored aboveground, and in which no single container has a capacity to hold greater than 5,000 gallons. Facilities that fall into this category, called “Tier I” by the EPA, have the option to self certify their plans (no need for a professional registered engineer to stamp the plan) and comply with a number of other streamlined requirements. To help with development of this plan, the EPA has published a template in the final rule (see p. 74307) that provides an almost “fill in the blank” approach to complying with this regulation.
Additionally, and as was expected, the EPA also has proposed extending once again the deadline for complying with all of the “new changes” to the SPCC rule. This fourth extension to the deadline now requires facilities to update their plans from the old 1974 rule to the revised 2002 rule (which includes the modifications published in 2006 and 2008) by Nov. 20, 2009.
Stay tuned, as these changes may not be the last for the SPCC program.About the Author: Jay Collert is a nationally recognized environmental trainer and consultant with the Aarcher Institute of Environmental Training LLC, based in Houston, TX. Since 1994, he has focused on helping companies understand and comply with the complexities of environmental regulations. Contact: 281-256-9044, [email protected] or www.aarcherinstitute.com