Roaring Brook News

Some of the many items that are now mandatory are listed below:

· A Professional Engineer (PE) must prepare the SPCC plan.

· Piping, valves and tanks must have a testing program specified by the PE.

· The plan must be reviewed every five years

· Personnel must be trained annually.

· Security fencing is required around tanks and loading/unloading areas.

· Secondary containment is required at loading/unloading areas.

· Security lighting is required at tanks and loading/unloading areas.

Many of these were listed as "should do" in the old regulations but are now required.

Accidents do happen. Your best defense is a well- prepared and implemented SPCC plan. Give us a call to set up a time to begin the review of your SPCC.

What changed?

The EPA's stance is that most of the changes were editorial in nature. While this may be true in a literal sense, it is not true from a practical sense. One of the big changes was changing all the "shoulds" to" shalls." This changes the context from, "It would be nice if you did this," to, "You must do this." Every existing SPCC plan needs to be reexamined in light of these changes to determine the impact to the facility.

The engineer creating the plan can present creative methods to achieve the objectives of an SPCC, but the engineer must also certify that the plan will meet the requirements of Part 112.

Security is a hot button topic everywhere now, including at the EPA. According to the presenters at a recent seminar on SPCC compliance sponsored by the New England Fuel Institute, security fencing and lighting will be required. The EPA is very concerned about potential vandalism, and the message from the EPA is that they will not waiver on this requirement.

Engineering A Better Future