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EPA Guidance on Oil Spills and SPCC Inspections

Posted on 10/14/2014 by Anthony Cardno

To ensure its Spill Prevention, Control, and Countermeasure (SPCC) guidelines are enforced consistently nationwide, the US Environmental Protection Agency (EPA) revised its SPCC guidance document for regional inspectors in August 2013. While the guidance document, titled “SPCC Guidance for Regional Inspectors,” is intended for inspectors, it is also useful to facility owners and operators who are subject to the SPCC plan requirements of 40 CFR 112.
 
How to Use the SPCC Guidance Document
 
Facilities may use the EPA guidance document to help them comply with the regulations and prepare for audits by State and regional enforcement personnel. That said, the guidance document is a guide only—it is not a statute or regulation and does not carry the same weight as laws or regulations. In any situation where the guidance and regulations are at odds, the regulations take precedence.
 
What’s in the EPA Guidance Document?
 
The guidance is divided into seven chapters:
  1. Introduction discusses the scope and history of 40 CFR 122;
  2. SPCC Rule Applicability reviews in depth the applicability criteria and sample scenarios;
  3. Environmental Equivalence discusses how a facility might get approval for deviations from what the regulations require for controls;
  4. Secondary Containment and Impracticality Determinations compares and contrasts various secondary containment requirements, including how to reach a determination of impracticality and the documentation needed to support such a determination;
  5. Oil/Water Separators provides a number of sample scenarios detailing how the SPCC rules apply to oil/water separators and similar devices;
  6. Facility Diagram and Description gives examples on the level of detail required for site maps, diagrams, and written descriptions;
  7. Inspections, Evaluations, and Testing presents an overview of where and when testing, inspection, and evaluation are required and how to comply with the requirements.
The guidance also includes eight appendices, which include a variety of checklists, interpretive letters from the Agency, the text of that portion of the Clean Water Act relevant to the SPCC program, templates for SPCC plans, and sample capacity calculations for tanks and for secondary containment.
 
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Ongoing Revisions to the SPCC Guidance
 
The guidance is what the EPA calls a “living document’; the Agency continues to revisit and revise it as necessary. In addition to the major revision in August 2013, the EPA also revised the document in November and December of that year. The November revision included linking to the Office of Water’s page regarding the definition of “Navigable waters” and a revision of the summary of integrity testing and inspection documentation. The December revision added the text of a settlement agreement between EPA and two oil companies. Because the SPCC guidance is a living document, future revisions or amendments will not necessarily be announced in the Federal Register.
 
Submitting Your Comments to EPA
 
Because the SPCC Guidance for Regional Inspectors is an ever-changing document, EPA encourages ongoing commentary from regulated entities and other interested parties. Comments should reference the specific page or section number being commented on and can be submitted to EPA via e-mail at SPCC.OilSpill@epa.gov.
 
Expert Training on EPA Rules
 
Be confident your team is prepared to comply with the latest requirements for spill reporting under the SPCC regulations. Lion’s Complete Environmental Regulations Workshop is presented in cities nationwide and covers the critical elements of the EPA’s air, water, and chemical rules. Designed for environmental managers, plant engineers and managers, and corporate attorneys, this two-day workshop will help you identify your legal requirements under the Clean Air Act, Clean Water Act, SDWA, FIFRA, TSCA, and more, as required for ISO 14000.

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