We are adept in the development and implementation of SPCC Plans in accordance with 40 CFR, Part 112 for both onshore facilities excluding production facilities (40 CFR, Part 112, Subpart 112.8) and onshore oil production facilities excluding drilling and workover facilities (40 CFR, Part 112, Subpart 112.9). Members of our team have developed hundreds of SPCC Plans for various industries including oil and gas production and transmission, natural gas processing, general manufacturing, aerospace foundries, automotive, landfills, food processing, construction, drilling mud processing, electric utilities, and a bulk crude oil storage terminal.
We understand the proper classification of bulk storage containers, oil-filled operating equipment, oil-filled manufacturing equipment, and flow through process vessels. Our team is proficient in the development of oil spill contingency plans, passive measures, active measures, sized secondary containment, and general secondary containment and is experienced in their proper implementation and use.
Our SPCC Plans are formatted in accordance with the regulatory requirements in an easy to follow structure. They include regulatory citations for easy reference and are equipped with the required capacity calculations, emergency procedures, and forms. Easy to use forms include those required for the documentation of amendments, reviews, inspections, secondary containment precipitation discharges, spills and releases, and spill reporting.
We also develop aboveground storage tank (AST) inspection and integrity programs and flowline maintenance programs. These programs are developed in accordance with industry standards to ensure compliance with 40 CFR, Part 112, Subpart 112.8 and 112.9, as appropriate. They include standard procedures for the proper inspection, maintenance, testing, and repair or replacement of ASTs (non-oil production facilities) and flowlines (oil production facilities). These programs are typically prepared in a general format that can be implemented system, asset, or company-wide.
Our team is experienced in evaluation of the substantial harm criteria for all types of facilities and the development of facility response plans (FRP) for a bulk crude oil storage terminal. In accordance with 40 CFR, Part 112, Appendix C, Section 2.0, a facility that has the potential to cause substantial harm to the environment in the event of a discharge must prepare and submit a FRP to the USEPA. We develop FRPs that are specific to the facility and include all required components in an easy to read and implement format supported by a regulatory cross reference table to simplify USEPA compliance reviews.
An important aspect to the proper and successful implementation of a SPCC Plan, companion programs, and FRPs is employee training. Our environmental specialists provide SPCC training either on-site or in a classroom setting. Training typically includes a review of the SPCC Plan, companion programs, and/or FRP contents; proper operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; discharge prevention briefing; and spill response procedures. Field exercises and emergency response materials deployment exercises may also be performed. At the completion of training a copy of the attendee sign-in sheet and training materials is provided to the client for documentation. If you are looking for practical and affordable SPCC related solutions, please contact A & M. We would be glad to help you out.