Oil Spill Prevention, Control and Countermeasures Plan SPCC

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• Oil Spill Prevention, Control and Countermeasures
  Plan (SPCC)
• New Regulation Finalized July 2002

UPDATE EPA Announces Final Implementation
Timeframes
Jim Willcox Senior Project Manager
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EPA ExtensionFinal Rule

• Summary
• The Environmental Protection Agency (EPA or we)
  has extended the dates for a facility to amend
  its Spill Prevention, Control, and Countermeasure
  (SPCC) Plan and implement the amended Plan (or in
  the case of facilities becoming operational after
  August 16, 2002, prepare and implement a Plan
  that complies with the newly amended
  requirements). The EPA took this action to avoid
  the flood of individual extension requests it has
  become apparent we will otherwise receive from
  regulated facilities, and to allow for adequate
  consideration of comments we expect to receive on
  a proposed one-year extension of the dates
  published elsewhere in this issue of the Federal
  Register.

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Dates of Interest

• August 16, 2002 Effective date of ruling.
• August 17, 2004 Extension date from April 18
  and February 17, 2003. Organizations must assess
  the impact of the new regulation on their
  organization, prepare and develop new SPCC Plan.
• February 18, 2005 Extension date from October
  17 and August 18, 2003. New SPCC Plan must be
  implemented.

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Applies to Electric Utilities

• Section I, Entities Effected by This Rule, states
  Electric Power Generation, Transmission and
  Distribution
• Revised rule clarifies that users of oil are
  subject to the rule. Part 112.1 (b)
• Oil still defined to include, but not be
  limited to, petroleum, fuel oil, sludge, oil
  refuse and oil mixed with wastes. Part 112.2
• Petroleum oil still means petroleum in any
  form, including crude oil, fuel oil, mineral oil,
  sludge, oil refuse, and refined products. Part
  112.2

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SPCC Rule Thresholds

• 1,320 gallon total above ground storage at any
  facility
• Containers with capacity of less than 55 gallons
  excluded
• 660 gallon single container trigger eliminated

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Secondary Containment

• Secondary containment of containers is required,
  unless determined to be not practical (not
  practical does not pertain to economics)
• If not practical, then
• Explanation of why must be included in Plan
• Strong spill contingency plan must be included in
  Plan
• Written commitment to manpower, equipment and
  materials to expeditiously control and remove oil
  must be included in Plan
• Integrity testing and leak testing must be
  conducted and records maintained for 3 years

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Other Items of Interest

• A facility under the new ruling can be as small
  as a single piece of equipment
• Description of physical layout facility and
  facility diagram must be included in Plan
• Buried piping installed after August 16, 2002
  must have protective wrapping and coating and
  must be cathodically protected (or similar)

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Items Remaining to be Addressed by EPA

• Loading/unloading areas/racks
• Secondary containment and consideration of cost
• Oil filled equipment/process tanks
• Types of secondary containment
• Applicability to mobile storage containers
• Oil/water separators

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Let GDS Associates, Inc. assist you in the
development and implementation of your plan to
comply with this new EPA regulation.
Contact Jim L. Willcox Senior Project
Manager GDS Associates, Inc. 1850 Parkway Place,
Suite 800 Marietta, Georgia 30067 770-425-8100,
ext 127 Jim.Willcox_at_gdsassociates.com